Coin Acceptance and Delisting Policy

1. Introduction and Scope

This Coin Acceptance and Delisting Policy ("Policy") defines the principles, procedures, and internal risk framework applied by Bitprime to assess, support, monitor, and discontinue support for Digital Assets available through the Bitprime platform (bitprime.io).

The platform is operated by MBI.COM Sp. z o.o., a company incorporated under the laws of the Republic of Poland, registered in the National Court Register (KRS) under number 0001117984, with NIP: 6783218579 and REGON: 529217342 (hereinafter referred to as "Bitprime", "Company", "we", "us", or "our").

Bitprime operates as a Virtual Asset Service Provider (VASP) and conducts its activities in accordance with applicable European Union regulations, including Anti-Money Laundering Directives (AMLD) and relevant provisions of the Markets in Crypto-Assets Regulation (MiCA), where applicable.

This Policy describes:

  • the criteria used to evaluate Digital Assets prior to listing
  • ongoing monitoring practices
  • circumstances under which support may be suspended or terminated

2. Nature of Services (Execution-Only / Transit Model)

Bitprime operates under a strictly execution-only, transaction (transit) model, limited to fiat-to-crypto transactions.

The Company:

  • does not provide crypto-to-crypto or crypto-to-fiat services
  • does not maintain client accounts or stored balances
  • does not provide custodial services
  • does not retain control over client assets beyond transaction execution

Any handling of Digital Assets is:

  • temporary
  • strictly limited to transaction processing
  • executed solely for the purpose of completing the user's order

Digital Assets are transferred directly to the user's designated external wallet without storage on the platform.

As a result:

  • traditional safeguarding and segregation mechanisms are not applicable
  • Bitprime has no ongoing exposure to market risk or asset volatility
  • Bitprime does not engage in proprietary trading or use of client assets

Bitprime does not issue, promote, or endorse any Digital Asset.

3. Digital Asset Evaluation Framework

Prior to supporting any Digital Asset, Bitprime conducts a risk-based due diligence assessment covering legal, technical, operational, and market factors.

Support for any Digital Asset is not guaranteed and remains subject to ongoing review.

3.1 Legal and Regulatory Assessment

Bitprime evaluates whether the Digital Asset:

  • complies with applicable EU and local regulations
  • may be classified as a financial instrument or security
  • is subject to regulatory restrictions or enforcement actions
  • is linked to sanctioned individuals, entities, or jurisdictions
  • presents legal or compliance risks under AML/CFT frameworks

3.2 Technological Security and Network Integrity

The underlying protocol must demonstrate:

  • resilience against network attacks (e.g., 51% attacks)
  • protection against double-spending and manipulation
  • stable and reliable network performance
  • secure smart contract architecture (if applicable)

3.3 Development Transparency and Governance

Bitprime may assess:

  • level of ongoing development activity
  • availability and transparency of source code
  • results of independent security audits
  • governance structure and degree of decentralisation
  • token issuance, allocation, and supply mechanisms

3.4 Market Liquidity and Execution Feasibility

Digital Assets must demonstrate sufficient liquidity to ensure:

  • reliable execution via liquidity providers
  • minimal slippage during transactions
  • adequate market depth across supported venues

3.5 Project Credibility and Sustainability

The Company may consider:

  • reputation and track record of the development team
  • transparency of the project
  • long-term viability of the ecosystem
  • adoption, use cases, and community support

4. Dependence on Liquidity Providers

Bitprime relies on third-party liquidity providers for transaction execution and does not act as a principal or market maker.

The availability of any Digital Asset is therefore dependent on external providers.

If a liquidity provider:

  • suspends
  • restricts
  • or terminates support

Bitprime may immediately suspend or discontinue support for the relevant Digital Asset without prior notice.

5. Restricted and Prohibited Digital Assets

Bitprime does not support Digital Assets that present elevated regulatory or compliance risks, including but not limited to:

5.1 Privacy-Enhancing Assets

Assets designed to obscure transaction traceability or ownership.

5.2 Algorithmic Stablecoins

Assets relying on non-collateralised or opaque stabilisation mechanisms.

5.3 Sanctioned or High-Risk Assets

Assets associated with:

  • sanctioned jurisdictions
  • restricted entities
  • high-risk counterparties

(as defined by EU, UN, and OFAC frameworks)

6. Stablecoins and Fiat-Referenced Tokens

As of the effective date of this Policy, Bitprime does not support stablecoins or fiat-referenced tokens.

7. Compliance Monitoring and Risk Controls

Bitprime operates a risk-based AML/CFT compliance framework, combining automated monitoring tools and internal oversight.

This includes:

  • automated screening and risk scoring (via third-party providers such as Sumsub)
  • transaction monitoring (TM) procedures
  • manual review of flagged activity
  • escalation to the Money Laundering Reporting Officer (MLRO)

The Company may:

  • restrict transactions
  • suspend asset support
  • block execution

where elevated risk is identified.

8. Forks, Airdrops, and Network Events

Due to the execution-only model, Bitprime does not support network distributions.

8.1 Airdrops

Bitprime does not:

  • claim
  • manage
  • distribute

airdrops. Any distribution occurs directly on the blockchain to the user's external wallet.

8.2 Forks

In case of a fork, Bitprime may support only one chain, as determined at its sole discretion or by liquidity providers.

Support for forked assets is not guaranteed.

9. Suspension and Emergency Measures

Bitprime may suspend support for any Digital Asset at any time, including without prior notice, in response to:

  • security vulnerabilities or exploits
  • network instability
  • regulatory developments
  • liquidity disruptions
  • abnormal market conditions

10. Delisting

Bitprime reserves the sole and absolute discretion to delist any Digital Asset.

Reasons may include:

  • regulatory or legal concerns
  • security risks
  • insufficient liquidity
  • extreme volatility
  • project abandonment
  • decisions by liquidity providers

Bitprime is not obligated to provide advance notice.

11. Transaction Handling During Delisting

Due to the execution-only model:

  • no withdrawal periods apply
  • no balances are held

If a transaction is pending during delisting:

  • it may be cancelled
  • funds may be returned where technically feasible

Refunds:

  • fiat → original payment method
  • subject to applicable fees

12. Internal Governance

All listing, suspension, and delisting decisions are made under internal:

  • risk management
  • compliance
  • operational review procedures

Digital Assets are subject to continuous monitoring.

13. Policy Updates

Bitprime may amend this Policy at any time.

Updates become effective upon publication. Continued use of the platform constitutes acceptance of the updated Policy.

14. Governing Law

This Policy is governed by the laws of the Republic of Poland.

Any disputes shall be subject to the jurisdiction of Polish courts.