MOS Trading Rules

1.  INTRODUCTION AND SCOPE

1.1 MOS issues these Electronic Platform Trading Rules (“Rules”) to users of MOS’s services to clearly define the framework within which MOS operates its Exchange and RFQ platforms. These Rules are designed to:

(a) ensure MOS’s compliance with all applicable laws, regulations, and ancillary legislation;

(b) facilitate MOS’s cooperation with any competent law enforcement, regulatory, or governmental authority;

(c) clearly define MOS’s role, rights, and authority in operating the Exchange and RFQ platforms, including the discretion to amend, supplement, or issue new rules for their operation; and

(d) promote fairness, transparency, integrity, and orderly market conduct in the operation of the Exchange and RFQ platforms for the benefit of all users.

1.2 MOS may publish rules, requirements, decisions, directions, notices, circulars, or similar instruments as deemed necessary for the operation of the Exchange and RFQ platforms. Any such instrument published by MOS will take effect from the date of publication, or a later date if specified.

1.3 In the event of any inconsistency between provisions of these Rules, MOS shall have the sole and absolute discretion to determine the resolution of such inconsistency. Where there is a conflict between these Rules and a more specific agreement between MOS and a user, the specific agreement shall prevail only to the extent expressly stated; otherwise, these Rules shall govern. Users acknowledge and agree that they are bound by these Rules in conjunction with the Client Terms and Conditions, and MOS shall not be liable for any losses, damages, or claims arising from a user’s failure to comply with these Rules or from any inconsistency between these Rules and other agreements, except to the extent prohibited by applicable law. Unless otherwise defined herein, capitalized terms used in these Rules shall have the meanings assigned to them in the Client Terms and Conditions.

1.4 MOS may, at its sole discretion or upon application by a user or other relevant party, vary or waive any provision of these Rules by publishing a notice of such variation or waiver. MOS may amend these Rules at any time, including by adding, varying, or deleting provisions, without prior notice to users. Any amended Rules will be published on MOS’s website and shall become effective upon such publication unless otherwise specified. Users are responsible for reviewing the Rules before each use of MOS’s Exchange or RFQ platforms.

1.5 MOS will cooperate with any lawful request from a regulator, law enforcement, or other competent authority. MOS may be required to make disclosures to regulators or law enforcement, including user information and records of a user’s activities on the Exchange or RFQ platforms.

2. ELIGIBILITY AND CLIENT REQUIREMENTS

2.1 Eligible Users: Clients of MOS may be granted access to the Exchange and other services, including RFQ services, upon meeting applicable qualification criteria. Access to these services is subject to MOS’s assessment and approval.

2.2 Qualification Requirements: Access to MOS’s services, including but not limited to the Exchange and RFQ platforms, is contingent upon the completion of all required client suitability assessments and risk evaluations. These processes may result in restrictions or limitations on the products or services available to the User.

2.3 Additional Eligibility Conditions: Access to services may be subject to additional eligibility requirements as determined by MOS from time to time, including but not limited to compliance with applicable regulations or internal risk management protocols.

2.4 Funded Account Requirement: Clients must maintain a fully funded account with an available balance in the relevant asset sufficient to cover the full notional value of any order, together with all applicable fees and charges, prior to submitting such order. MOS may decline to accept or process any order that does not meet this requirement.

2.5 Order Hold and Availability of Funds: Once an order is submitted and not immediately filled, the corresponding amount of assets and/or funds will be placed on hold and rendered unavailable for withdrawal or other use until such time as the order is executed, expires, or is cancelled. MOS shall not be responsible for any delay, opportunity loss, or other consequences resulting from such hold or from the rejection, partial execution, or cancellation of an order.

3. EXCHANGE

3.1 Maintenance and Order Acceptance

3.1.1 Except during scheduled or unscheduled downtime, the Exchange will ordinarily be available 24 hours a day, 7 days a week. MOS may conduct regularly scheduled maintenance windows for the Exchange, which shall generally not exceed thirty (30) minutes unless otherwise published. All such maintenance periods will be disclosed on the Exchange website, and Users will be provided with notice via MOS’s official communication channels. MOS reserves the right to conduct emergency or unscheduled maintenance at any time without prior notice.

3.1.2 The Exchange will accept orders from Users during operational hours, except during outages, system halts, maintenance periods, or other events as determined necessary by MOS in its sole discretion. MOS shall not be liable for any losses, costs, or damages arising from any delay, failure, or rejection of order acceptance.

3.2 Order Types and Execution Rules

3.2.1 Limit Orders: A Limit Order is an order to buy or sell a specified quantity of a Virtual Asset at a designated price. Limit Orders are deemed “Good until Cancelled” (GTC), unless otherwise specified. Orders may be fully or partially executed, and MOS assumes no responsibility for unexecuted portions.

(a) Maker Orders: A Maker Order is entered into the Exchange’s order book in accordance with the Sorting Rules.

(b) Taker Orders: A Taker Order results in the immediate execution against existing orders in the book, in whole or in part. Any unfilled portion may be re-entered as a Maker Order.

(c) Fill-or-Kill (FOK) Orders: A FOK Order is executed only if it can be filled in its entirety immediately. If not, it is cancelled in full.

(d) Immediate or Cancel (IOC) Orders: An IOC Order is executed immediately in whole or in part, and any remaining unfilled portion is cancelled.

(e) Post Only Orders: Post Only Orders will only be entered into the order book as Maker Orders. If such an order would immediately match with an existing order, it is cancelled automatically to ensure liquidity is not removed.

3.2.2 Market Orders: A Market Order is an instruction to buy or sell a specified quantity of a Virtual Asset at the best available price in the market at the time of execution. Market Orders shall be matched against orders in the Exchange order book and executed at the most favourable price available at the time of execution. Users should note that for orders of a size significant relative to available liquidity, the execution price may differ from the top-of-book price (i.e., the best bid or best ask). All Market Orders are subject to the trading limits, risk parameters, and other controls established by MOS, including price bands, maximum order sizes, and liquidity constraints. MOS shall not be liable for any deviation in execution price, partial fills, or inability to fully execute Market Orders resulting from such parameters or market conditions.

Execution of a Market Order may result in:

(a) Partial Fills, due to insufficient liquidity; and

(b) Automatic Cancellation of the unfilled portion where execution would exceed price bands, thresholds, or other controls applied by MOS to preserve orderly market conditions.

MOS shall not be responsible for any inability to fully execute a Market Order, or for any impact on execution price resulting from such controls.

(Collectively, the foregoing are “Eligible Exchange Orders”).

3.3 Participants, User Priority, and Client Order Handling

Users whose Eligible Exchange Orders are accepted will be placed into the Exchange order book, where the Exchange’s order matching engine evaluates orders based on price, category, and time priority. Explicitly, orders within the order book are prioritised according to the following rules (the “Sorting Rules”): 

(a) Price Priority: Orders are prioritized based on the price level, with higher bids and lower asks being given priority. 

(b) Time Priority: Within the same price level, orders are prioritized according to the time at which they are received, with orders received first being executed before later ones.

3.4 Exchange Order Routing and Order Cancellation

3.4.1 All Eligible Exchange Orders are executed solely within the Exchange and will not be routed externally.

3.4.2 Order cancellations are processed sequentially in the order received. Cancellation is not guaranteed until confirmed by the Exchange.

3.4.3 MOS maintains operational controls to ensure the functioning of the Exchange, including:

(a) Development, testing, and monitoring of the platform;

(b) Oversight of technology infrastructure;

(c) Monitoring of execution and settlement processes;

(d) Compliance and surveillance monitoring.

Users acknowledge that despite such controls, system errors, failures, or outages may occur, and MOS shall not be liable for any resulting losses.

3.5 Instrument Controls

To maintain market integrity and ensure an orderly trading environment, the Exchange implements the following instrument controls, which may be configured differently for each Virtual Asset pair and are subject to modification at the MOS’s sole discretion without prior notice:

3.5.1 Min Price: The minimum price allowed for a single order. 3.5.2 Max Price: The maximum price allowed for a single order. 3.5.3 Min Quantity: The minimum quantity allowed for a single order. 3.5.4 Max Quantity: The maximum quantity allowed for a single order. 3.5.5 Min Value: The minimum value allowed for a single order. 3.5.6 Max Value: The maximum value allowed for a single order. 3.5.7 MaxQuoteUp: The maximum allowable increase (upward movement) from the last traded price for orders. This may be expressed as an absolute value or percentage. 3.5.8 MaxQuoteDown: The maximum allowable decrease (downward movement) from the last traded price for orders. This may be expressed as an absolute value or percentage.

Orders breaching such parameters may be rejected, cancelled, or partially filled without liability to MOS.

3.6 Settlement of Orders

When a Maker Order is matched with a Taker Order, execution occurs automatically, in whole or in part depending on liquidity. MOS settles such trades by adjusting Users’ accounts. Settlement is subject to platform rules, withdrawal limits, and applicable compliance checks. MOS does not guarantee immediate availability of assets for withdrawal.

3.7 Suspension and Market Disruptions

3.7.1 MOS may suspend the Exchange, in whole or in part, without notice and without liability, under circumstances including but not limited to:

(a) Compliance with legal or regulatory obligations;

(b) Technology or infrastructure failures;

(c) Market disruptions or extraordinary volatility;

(d) Events where MOS deems suspension necessary to preserve market integrity or protect Users.

3.7.2 During such suspension, MOS may, at its discretion:

(a) Disable deposits or withdrawals;

(b) Cancel open orders;

(c) Restrict or disable sign-in or API connectivity;

(d) Restrict platform access;

(e) Transition to Cancel-Only Mode.

The Exchange may resume full operations only after MOS determines, in its sole discretion, that market and system conditions are safe.

In the event of a Network Event (including forks, protocol changes, or chain splits), MOS may determine, in its sole discretion, whether to support one or more resulting chains. MOS shall not be obligated to support any particular outcome and shall not be liable for any losses, claims, or opportunity costs arising therefrom.

4. RFQ (REQUEST FOR QUOTE)

4.1 An RFQ is a request by a User for a quotation on one or more approved Virtual Assets, specifying quantity or value. The response to the RFQ is an automatically generated quotation, valid for a predefined period unless withdrawn by MOS. Users should refer to the Client Agreement for additional information on the RFQ process.

4.2 Accepted RFQ Orders: Orders resulting from accepted RFQs are considered facilitation trades, and unless explicitly agreed upon with MOS in writing, best execution principles do not apply to these transactions.

4.3 RFQ Platform Operations

Users may request a quote for the specified quantity or value of Virtual Assets via the RFQ Platform. A quote will be returned and remain valid for a predefined period. Once the quote acceptance period expires, the User may re-quote or, at MOS’s discretion, the system will generate a new quote based on the initial parameters, initiating a new acceptance period.

While the quote acceptance period is active, Users may accept the quote by selecting “Confirm.” Upon acceptance, the trade will be automatically executed, and the User will receive confirmation of the trade execution.

4.4 Limits on RFQ Orders

MOS may impose limits on RFQ Orders, including but not limited to per-quote limits and a maximum daily notional limit, at its sole discretion.

4.5 MOS may suspend or withdraw the automated RFQ facility through its platform’s user interface or via API for reasons including but not limited to:

4.5.1 Regulatory compliance requirements 4.5.2 Technology-related issues 4.5.3 Network events

Users will be notified promptly of any service suspension via a system-generated warning message or statement on the platform’s user interface.

5. SELF-TRADE PREVENTION

Users are strictly prohibited from engaging in any activity that may result in self-execution of trades, whereby the same User acts as both the maker and the taker for the same order. Without limitation, if two or more Orders are placed that would result in self-execution, MOS reserves the absolute right, at its sole discretion, to cancel, withdraw, or modify any such Orders to prevent self-trading. Users acknowledge and agree that MOS shall not be liable for any losses, costs, or damages arising from the cancellation or modification of such Orders.

6. MARKET MANIPULATION

6.1 Users are unequivocally prohibited from engaging in any form of Market Manipulation, whether directly or indirectly, and whether on or off the Exchange and RFQ platforms. Market Manipulation refers to any activity by a User, or by any person acting in concert with a User, intended to:

(a) deceive, mislead, or create a false or misleading appearance of activity to other Users;

(b) artificially influence, control, or manipulate the price or trading volume of any Virtual Asset; or

(c) facilitate, aid, abet, finance, support, or otherwise participate in any of the foregoing activities.

6.2 Market Manipulation specifically includes, but is not limited to:

(a) Front-running;

(b) Wash trading;

(c) Spoofing;

(d) Layering;

(e) Churning;

(f) Pump-and-dump schemes;

(g) Quote stuffing.

6.3 Any User found, or reasonably suspected, to have engaged in Market Manipulation may be subject to immediate corrective action by MOS, at its sole discretion, including without limitation:

(a) suspension, restriction, or termination of account access;

(b) cancellation, reversal, or adjustment of any affected trades or Orders;

(c) reporting to any applicable regulatory authority or law enforcement body; and

(d) any other measures MOS deems necessary to preserve market integrity and compliance with applicable laws and regulations.

6.4 Users acknowledge and agree that MOS shall not be liable for any direct, indirect, or consequential losses, damages, or costs arising from the enforcement of these provisions, including actions taken pursuant to Sections 5 and 6.

7. FEES AND REFUNDS

7.1 MOS shall charge a Maker fee for each Maker Order and a Taker fee for each Taker Order posted to the Order Book. Such fees shall be denominated in the Quote Asset and calculated as a percentage of the Order quantity. Fees will be automatically debited from the User’s available balance at the time the Order is posted. In the event an Order is partially posted as a Maker Order and partially as a Taker Order, the applicable Maker fee shall apply to the Maker portion and the applicable Taker fee shall apply to the Taker portion. Fees may differ between Order Books and MOS reserves the right, at its sole discretion, to amend, vary, or update the fee structure at any time. The current fee rates shall be published on the MOS website or otherwise communicated by MOS to Users.

7.2 If an Order is cancelled, any fees associated with such Order may be refunded at MOS’s sole discretion, subject to applicable platform rules, limitations, or conditions. Users acknowledge and agree that MOS shall have no liability for any fees, costs, or losses incurred as a result of any cancellation, amendment, or adjustment of Orders, or any delay or failure in processing refunds.

8. CIRCUIT BREAKERS

8.1 MOS does not operate circuit breakers, automated trading halts, or any other mechanisms based on predetermined price bands. Users acknowledge and agree that MOS shall have no liability for any losses, damages, or missed trading opportunities arising from market volatility, system performance, or the absence of such mechanisms.

9. ACCESS TO INFORMATION

9.1 All Users are entitled to access Market Data on a fair and non-discriminatory basis. Market Data is provided through the web interface or via Application Programming Interfaces (APIs) and may include, without limitation:

(a) All Limit Orders placed on the Order Book, including price, quantity, and timestamp;

(b) All cancelled Orders on the Order Book, including price, quantity, and timestamp; and

(c) All fills or executions, including price, quantity, and timestamp.

9.2 Market Data does not include information that identifies the Users placing or cancelling Orders. MOS makes no representation or warranty regarding the accuracy, completeness, or timeliness of Market Data and shall not be liable for any errors, omissions, delays, or reliance on such data. Users access and use Market Data at their own risk, and MOS reserves the right to modify, restrict, or suspend access to Market Data at its sole discretion.