5th October - Update on the FCA Promotions Act

Hi all,

As you will be aware there have been no social media posts for a while, and a little less communication than normal. It has been mentioned previously that this is due to the FCA Financial Promotions Act however I thought I would explain the details further in an update.

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As of 8^th October, the FCA is introducing rules as to how crypto companies promote to customers. While they were issuing guidance and putting the act into place, we decided that it would be best to pause on our marketing efforts as they explicitly expressed that they needed to see evidence of companies preparing for the act and they needed to see that there were being steps taken along with active thought ahead of the rules. For us to continue to post on social media and communicate the way we were would have gone against this.

Now that we are a few days out from the promotions act coming into place you may start to see some changes to the website. We will be adding and removing parts and changing the wording to ensure that we are in line with the rules.

Unfortunately, this is not something we are able to get around, the FCA are extremely strong on these rules and a breach can mean prison time for the individuals responsible. We will be taking this extremely seriously.

Here are a few details of the act that hopefully explain the large changes:

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·      Applies to website, apps, social media, blog posts and traditional marketing.

·      There can be no invitations or inducements to engage in investment activity.

·      We can communicate with customers to allow them to transfer, withdraw or sell but when doing so need to communicate the customer journey and disclose fees, costs and charges associated. This only applies to existing customers and we need to refrain from promoting further investment to that customer.

·      Even if we are registered abroad, if the UK customer has access to the website or socials it is still a breach.

·      We are banned from promoting the rewards element of the crypto platform as it is classed as an incentive to invest.

·      We are unable to have incentives such as referral schemes or governance now as they class this as incentives to purchase and therefore this is classed as a promotion.

·      Risk warnings - we will need to put risk warnings on everything that gets mentioned. This will also include a 24-hour cooling-off period as part of the customer journey.

·      Social media – we are unable to mention ‘rewards’ as this is an incentive to invest. We must say that we are unregulated by the FCA.

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In conclusion of course there are far more intricate details than the above, however, that is a good summary of the general things we are needing to change. This does mean a huge change to the business and to the token and while we are still navigating what this means for the company, please remember that this is unfortunately out of our control and we have no way of getting around this.

Essentially talking about the token is going to be difficult, we will struggle to market the token and the platform and we must be careful with our communication moving forward.

I know this is not what token holders wish to hear, and likewise, as a team, we wish the reality was different. We hope you understand that for the last few months, we have had to put a lot on hold due to this and to ensure the safety of the project and our team.

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