Digital Asset & Commodity Exchange
Digital Asset & Commodity Exchange
Digital Asset & Commodity Exchange
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Digital Asset & Commodity Exchange
Content
1. Introduction ................................................................................................................ 4
3.4 Assets........................................................................................................................... 15
3.8 Features....................................................................................................................... 19
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7. Team ........................................................................................................................ 31
8. Advisors ................................................................................................................... 33
9. Risks ........................................................................................................................ 34
11. Appendix................................................................................................................. 36
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1. Introduction
DACX, a London based fintech/blockchain start-up located in the famous Technology
Accelerator known as LEVEL39. The DACX project was conceived during Q3 2018, with a
vision to provide a next generation digital asset exchange which leverages machine learning
and DLT to ensure a safe and compliant marketplace. Our goal is to provide a platform for
both primary and secondary markets beyond traditional cryptocurrencies, by venturing out
into the world of tokenized securities and commodities. Therefore, our product offerings
cater solutions to the retail sector, professional and institutional grade clientele.
Since inception, DACX has come a long way, our MVP was launched in January 2019,
whereby the team made the decision not to not seek external funding for the project at such
a premature stage. This proved influential in driving;
This allowed the organization to stay focused and remain relevant in respect of the
changing regulatory landscape and investor appetites towards ICO’s.
During this journey we have made progress not only on the product side but also within the
blockchain community by forming affiliations and working relationships with established
organizations in this space. On the regulation front, being a centralized exchange with goals
of listing STO’s in the near future, it was in our interest to design compliance in the core of
our architecture to mitigate current and future regulatory risks. Therefore, our platform
integrates KYC, AMM, and AML to monitor real-time risks which mitigates suspicious
market behaviors.
By pitching our cross-border testing proposal to the FCA lead consortium of regulators,
formally known as GFIN (Global Financial Innovation Network). DACX was one of eight
successful firms to have been shortlisted for the pilot. Our proposal entailed utilization of
DLT and machine learning to facilitate cross-border transactions of multi-currency
payments, assets and commodities via tokenization, smart contracts and escrows.
This will be an ongoing journey where DACX intend to write the standard for quality and
attainment within this sector, and as such from the 23rd September 2019 we shall open
registrations for client on-boarding (see 3.11 for the Affiliate/Referral Program).
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Since the inception of cryptocurrencies, time after time the market has witnessed a history
of security breaches resulting in loss of client funds and trust. Therefore, this has adversely
affected the wider option adoption of digital assets. Below is a timeline of notable events
of thefts/hacks which span over the last 8 years
In adverse market conditions, it has been a common occurrence, that during high order
flows trades suffer from poor execution and slippage. The cause is high volatility which
results in system overloads, especially for matching engines built on a Single Threaded
Architecture.
A system overload happens when the number of orders to be processed by the trading
matching engine surpasses its handling capabilities. The system then handles orders as
they come and cannot accept any new orders until the queue is cleared. This means that
traders either cannot take advantage of the market or are losing more than they should as
their orders are pending due to technical difficulties instead of lack of bids/offers.
System overloads happen very often on many exchanges with a single-threaded matching
engine and should be one of the major concerns of traders looking to choose an exchange
as it may greatly impact their trading experience and profits and losses.
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Unregulated exchanges operating Fiat on/off ramps do not segregate customer funds as
should be the case. The unregulated nature of their business model, leads to a lack of
compliance towards AML and CFT regulation resulting in failed banking relationships. This
leaves the customers in limbo with their funds at risk.
Non-Disclosure of beneficiaries
Some rogue exchange on purpose do not disclose their senior management, and are
operating from offshore havens. This leads to the lack of accountability.
Rogue market participants resort to unfair practices to feed them profits. This has been
practiced in mainstream financial markets and the outcome of which is the 2010 Flash
Crash, 2012 Libor rate scandal, & Bitcoin Flash Crash [links below]
Spoofing can be used with layering algorithms and front-running, activities which are also
illegal. High-frequency trading, the primary form of algorithmic trading used in financial
markets is very profitable as it deals in high volumes of transactions.
Quote Stuffing
This refers to a form of market manipulation employed by API traders that involves quickly
entering and withdrawing a large number of orders in an attempt to flood the market. This
can create confusion in the market and it can create trading opportunities for high-speed
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traders. By quote stuffing, trading systems delay price quotes while the stuffing is
occurring, simply by placing and canceling orders at a rate that substantially surpasses the
bandwidth of market data feed lines or the matching engine.
The orders pile up in buffers and the delay (increased latency) lasts until the buffer drains.
It has been established that quote stuffing occurs frequently – when thousands of
replacement orders for one market are crammed into a second, each order is valid for less
time than it takes for the news of the order (traveling at close to the speed of light) to reach
anyone not at the exchange; no one can execute a trade against the phantom order.
Momentum Ignition
This refers to a market manipulation strategy that attempts to trigger a large number of
trades from multiple market participants in order to cause rapid price movements. This
abuse method is similar in concept to spoofing and layering, except that instead of merely
creating orders and canceling them, actual trades are processed. This method is also known
as “pump and dump.” By instigating multiple traders to buy or sell quickly, the manipulator
can profit either by having taken an early position or by laddering the book, knowing the
price is likely to revert after the initial rapid price movement. Momentum Ignition is
extremely difficult to detect and requires the use of machine learning.
Hammering
This is rapid and concentrated selling by traders who perceive a market to be overvalued.
These are forms of market manipulation in which a trader simultaneously sells and buys
the same financial instruments to create misleading, artificial activity in the marketplace.
First, a trader will place a sell or buy order, then place an opposite buy or sell order to take
the trade from himself. This may be done for a number of reasons:
To artificially increase trading volume, giving the impression that the instrument is
more in demand than it actually is.
Wash trading has been illegal in the United States since the passage of the Commodity
Exchange Act (CEA) of 1936.
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It is the process of concealing the origins of digital assets obtained illegally by passing it
through a complex sequence of tumblers and exchanges. The overall scheme of this
process returns the money to the launderer in an obscure and indirect way. Money
laundering occurs on digital assets exchanges when traders intentionally lose money on
trades while intentionally permitting specific other traders to recover the lost trades.
Failure to comply has hit some exchanges in particular EtherDelta where The Securities and
Exchange Commission announced settled charges in 2018 against Zachary Coburn, the
founder of EtherDelta , a digital "token" trading platform. This was the SEC's [Securities and
Exchange Commission] first enforcement action based on findings that such a platform
operated as an unregistered national securities exchange. [reference Sec.gov press release
2018-258]
SEC regulations are clear with the "Howey Test" which was created by the Supreme Court
for determining whether certain transactions qualify as "investment contracts." If so, then
under the Securities Act of 1933 and the Securities Exchange Act of 1934, those
transactions are considered securities and therefore subject to certain disclosure and
registration.
For information purposes, a transaction will be considered a security if all of the following
requirements are met:
Financial Exclusion
Beside the fact that the use of financial services makes more and more part of a standard
life, the way to access and use those services may be more and more demanding on various
aspects as geographical, technical, cultural, educational or about guarantee and risk
analysis criteria. This leads to a large range of access and use difficulties that are deeply
related to each country's market structure. Financial products will be considered
“appropriate” when their provision, structure and costs do not lead the customer to
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encounter access and/or use difficulties. These difficulties are caused simultaneously by
the characteristics of the products and the way they are sold (supply side) and the situation
and the financial capability of the 10/136 customer (demand side). The analysis of each
structure (both demand and supply sides) may, for each country, highlight the way supply
meet demand, and how appropriate it is.
Much of the exclusion appears to arise from a failure of the mainstream commercial
providers to supply a range of products and services that are appropriate to the needs of all
sections of society.
Banking, access to banking has become challenging for some segments of society, from
adverse credit scores to having no credit record making it a complex situation for these
consumers to get simple banking services. (solution cross border payments via Remit and
prepaid debit card program)
Savings, due to fiscal and monetary policies in some economies it is negatively incentivised
for the citizens to keep their savings in a bank due to low and even negative interest rate
policies (solution matching global borrowers and savers, and using DLT smart contracts,
and digital escrows)
Credit Exclusion, during the financial crisis of 2007 the global economy was hit by a liquidity
crunch towards all forms of lending, which took consumer lending a good number of years
to recover to a healthy state. (solution DEFI)
Investment opportunity exclusion, high barriers to entry e.g. ticket price (solution;
structured BTC bonds, Foundry, fractionalization, disrupting capital markets)
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Lack of Liquidity
Thin market liquidity significantly affects both retail and professional users. Having a
shallow order book depth implies high risk of slippage during trade execution, which results
in traders incurring the opposite of best price execution. For Example, Ethereum flash crash
from $319 to 10 cents.
Customer service is key to any business, companies which constantly deliver poor
customer service can go out of business. Customers today have so many options and will
turn to a competitor if encountered with a bad service experience. No matter what type of
business you are, your customers always want to be heard and treated well. Some
challenges seen within our industry are;
Response times
Accepting responsibility
A damaged reputation
Lack of respect where the key to winning over your customers is to treat them with
utmost respect. This requires training customer support staff to be extremely
courteous and friendly towards all customers no matter what the medium of
communication is.
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3. DACX Exchange
New technology enables a global business to reach new audiences around the globe to
ensure a pathway for international clients now than ever before. Organization have been
hampered with not ensuring multi-language support is part of the ongoing strategy,
customers should always be at the core of your business objectives, and part of this is
providing them with a seamless experience. A multilingual help desk, whether in-house or
acquired through outsourcing companies is key as the product grows
A trading matching engine is a software used to match buy orders, bids, and with sell orders,
offers. It is the most crucial part of any exchanges as this is what allows users to trade with
one another and the entire reason why they registered on the platform. Trading matching
engines follow an algorithm that determines a set of rules they must abide by, how they
work, how many orders they can handle across how many pairs and how long it takes. A
multi-threaded process is more advantageous, but only a few crypto exchanges
implemented it as it requires more work, experience, and time to build.
Their high-frequency trading solution, enables DACX to provide ten million transactions per
second from the get go and scalable up to 8X if and when required.
By comparison, Bitfinex can handle circa one million transactions per second, and Binance
only a little more— circa 1.4 million. With latency as low as 40 nanoseconds, your portfolio
can now rise and crash 1.5 billion times in a single minute. Even the NASDAQ, with 400
microsecond latency is 10 times slower.
Unlike Nasdaq SMARTS, the Modulus solution tracks money laundering within crypto
exchanges. Our system uses a deep learning neural network to identify hidden relationships
within the exchange and even within blockchains.
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Through the use of machine learning, the AMM/AML solution uses deep insights to connect
the dots within markets and between market participants, providing trade surveillance and
pre-trade, at-trade, and on-trade risk management and customizable alerts and reports.
Pre-Trade and At-Trade Risk Management are performed before trades are created, and at
the time of trades, which permits the exchange to cancel, reject, or modify orders and
trades, depending on pattern sensitivity settings. It is critical that Pre and At-Trade Risk
Management processes run as fast and as efficiently as possible, so as to minimize latency
within the exchange matching engine. While it is technically possible to programmatically
utilize these functions from external processes or from external matching engines,
performance is optimized when the processes are embedded within the actual matching
engine itself. Rate limiting of trades can also be managed within this process.
Post-Trade Surveillance
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3.2 Security
To ensure the safety of digital assets in our custody, we will be utilizing four types of crypto
wallets:
1. Hot Wallets
These are the wallets kept on our internal servers for frequent transfers. Only a fraction of
funds will be kept available for frequent transfers. All Hot Wallets come in encrypted form
and decryption keys are only applied by authorized personnel at predetermined intervals to
approve outgoing transactions. This prevents any asset loss in case our internal servers
are compromised.
4. Cold Wallets
These wallets are kept offline and transactions are signed on offline computers by senior
management executives.
3.3 Orders
An order is simply an instruction to open or close a trade. There are two main types of order:
entry orders and closing orders.
Order Types
Market Orders
Limit orders
Stop orders
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Market Orders
A market order is an instruction from a trader to execute a trade immediately at the best
available price
Limit Orders
A limit order is an order to buy or sell at a specific price or better. A buy limit order can only
be executed at the limit price or lower, and a sell limit order can only be executed at the limit
price or higher.
Stop Orders
A stop order, also referred to as a stop-loss order is an order to buy or sell once the price of
the asset reaches a specified price, known as the stop price.
Types of Stop Orders on DACX Exchange
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Order Durations
An order duration is the length of time your order will remain active in the market until it
expires. Different order durations allow you to control how long your order remains active.
The following is a list of durations available in our trading platforms.
GTC orders remains active until either the order is filled or cancelled by trader.
Immediate or Cancelled
Fill or Kill
Fill or kill (FOK) is a type of time-in-force designation used in securities trading that
instructs a brokerage to execute a transaction immediately and completely or not at
all.
Day Only
3.4 Assets
DACX Exchange will be listing USD Stable coin and BTC pairs for all high cap exchange
coins and utility tokens. We will be phasing in the listings by taking the input from the
members of the community.
More coins will be added over time. We generally will only add exchange coins and utility
tokens that have strong credibility, user base, and liquidity. For existing or upcoming
projects that wish to be listed on DACX Foundry for primary offering or for secondary market
trading on DACX Exchange, should reach out to benefit from our promotional listing terms
and fees.
DACX Exchange platform is scalable in terms of tech and practical application therefore by
in by Q1 2020 we intend to have a phased roll out of STOs for primary issuance and
secondary trading. Our roadmap is online for an Up-to-date progress indicator.
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3.5 Foundry
Introducing DACX Foundry, current starting off with our IEO platform. Foundry would be an
avenue for new creative projects to be brought out of concept to life via kickstart funding
opportunities. This allows new blockchain startups to launch their own compliant initial
exchange offering on completion of our internal assurance process.
With relevant licenses in place Foundry would later integrate technical infrastructure to
enable primary issuance of tokenized securities (STOs) and would support beyond ERC20
token standards and be compatible with multiple blockchains.
This enables us to disrupt capital markets, commodities and commercial real estate
sectors. Our Unique location in the fintech capital of Europe, and the heart London financial
district of Canary Wharf presents us with a strong position to leverage openings and attract
investors. In addition to this we are strategically placed to vet many upcoming Fintech and
AI startup companies inclusive of SME, providing an alternative liquidity solution from
different subset of investors, and therefore give these high growth tech startups an
opportunity to grow into future unicorn companies.
DACX native utility token is the first official IEO project launching on DACX Foundry. The
DACX Foundry token sale is on a first-come, first-served basis. The sale will be based on
USD and the actual price in USD stablecoin will be announced on the day of sale.
Users must complete identity authentication (KYC) in advance, before their purchase. To
comply with local regulations, users in some countries and regions cannot participate in the
sale.
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Fees Details
DACX will charge a 0.1% fixed fee per trade. There will be other
Exchange Fee fees that may include, but not limited to promotions, maker-
taker fees, and volume-based tier.
Withdrawal Fee
DACX may charge fees for withdrawals.
Listing Fee DACX will hand select project coins and other assets to be listed
on the exchange. We may charge a fee for any listings.
Other Fees There may be other fees DACX may charge for different
services.
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3.8 Features
Some of DACX’s key features are, but not limited to
2FA
Crypto to Fiat
Banking Rails & Settlements
Anti DDOS
Hardware Wallet Support
Foundry
MultiSignature Wallets
Universal Wallet-Remit Cross border payments
Virtual Debit Card
Security Tokens
3.9 UI Preview
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Our support system pulls customer emails from an email address and lists them in a
single place. It allows a help desk executive to answer calls from customers and log
them easily. It enables customer support executives to listen and respond to
customer feedback on social media, such as Facebook and Twitter.
When customers require a more elaborate solution, they can submit their tickets from
the Help Center, and keep an eye on the ticket status from the same interface.
➢ Automation:
Our help desk automation allows an agent to ensure that questions from
customers are redirected to employees who can answer them satisfactorily. It
enables the coordinator to monitor when a support executive hasn't responded
to a ticket, or when a ticket is taking too long to get resolved, or one of the
several other possible cases.
Knowledgebase Articles
Knowledge Base Articles are to answer your frequently asked questions. By creating
a repository of articles and FAQs in the Knowledge Base, customers can find their own
answers without waiting for an agent.
We enable customers to engage in discussions with each other and with your
company. With Communities and forums, customers can ask and answer
questions and share ideas on a common platform.
Live Chat
We have enabled our live chat system to understand customer’s concerns better, and
give them more timely, personalized help. If a customer has an issue that requires
more time and attention, agents can convert the chat conversation into a ticket. This
lets agents save all the context of the chat conversation, with no time lost. This will
help with the response time instead of having customers wait longer for a response.
AI Configured Bot
Customers can chat with AI Bot from our website or mobile apps. Our Bot processes
their questions and automatically answers them based on content present in our
knowledge base.
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Blue Print
At every stage of the process, Blueprint makes it easy for every stakeholder to
adhere to the process. They only see the actions applicable to them and cannot
move forward unless all their mandatory actions are completed.
Workflows automate email alerts, task assignments, and field updates when a
certain rule is triggered. On the other hand, a Blueprint mandates an entire sequence
of actions, taking tickets from state to state until they're resolved. Unlike a workflow,
a blueprint defines all the actions that happen to a ticket until it's resolved.
Total Number of DACX Rewards are limited to a maximum of 5,000,000 Tokens. Rewards
will be distributed at the end of the campaign based on completion period.
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4. DACX Remit
DACX Remits is a hybrid project which entail using DLT and Fintech for merging traditional
financial services with the efficiency of blockchain technology. By creating an interoperable
blockchain infrastructure along with Oauth 2.0 the industry standard protocol for
authorization.
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Fiat Money
Crypto Currencies
Utility Tokens
Security Tokens (STO)
Stable Coins
Commodity Tokens
Universal Wallet handles storage and transfer of all mentioned assets seamlessly in the
background, using traditional banking rails and is interoperable with multiple blockchains.
4.3 Custody
DACX Remit makes use of various custodians in the background, to deposit, withdraw and
transfer all assets held by Universal Wallet to make sure:
As the project evolves, DACX Custody will also be offered as a service for Institutional
Investors.
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In case destination currency for payment is not available in Universal Wallet or does not
have enough balance for that particular payment, enough amounts of other assets defined
in the list will be auto converted to destination currency through DACX Exchange and
payment will be completed.
Web-based client
Android native client
iOS native client
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4.6 UI Preview
DACX Remit App is currently under heavy development & testing. Following images are from
working alpha version of the app and are subject to UI & feature changes.
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We have issued our own utility token, called the DACX Token. A strict limit of 786,786,786
DACX has been created, never to be increased and total supply will be reduced through
frequent token burns. DACX token will run natively on the Ethereum blockchain under ERC
20 token standards.
5.1 Allocation
5% 39,339,339.30 Bounty
Exchange fees
Withdraw fees
Listing fees
Any other fee
❖ When you activate DACX to pay for trading fees, you will receive a significant discount:
No
Discount Rate 50% 25% 15%
Discount
Initial Exchange Offerings (IEO) on our platform will only be available to DACX Token
holders that register and have their accounts identification verified before the start of
the IEO. Offerings will be priced in DACX Token and a percent of the IEO supply will be
reserved for DACX Token Holders, based on their holdings, at the start of each IEO
phase.
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5.4 IEO
After Pre-Registrations are done and before launch, the IEO will be launched on the DACX
Exchange. As an incentive, first IEO of DACX Token will grant “No Base Listing Fee” ticket
applicable to one future IEO or Token Listing, for buyers & holders of a certain amount of
DACX Tokens. Minimum amount & hold duration to qualify for “Free Ticket” will be
announced prior to IEO. Usage of this “Free Ticket” requires minimum DACX Token balance
for the applicant’s account to not fall below minimum amount required, from the time of
purchase till usage of the ticket.
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6. Road Map
What When
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7. Team
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PETER MACDONALD
Business Strategist & Partnership Commodities Division
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8. Advisors
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9. Risks
There are many risks involved in running an exchange. We understand this and have the
skills, experience, and leadership to overcome them.
9.1 Security
Exchange platforms store and interact with high amounts of wealth on an online
environment. Due to this open and high prize nature of the platform security of the platform
is a top priority. In order to reduce attack vectors, we will not be disclosing full nature of
security protocols that will be used. Main security practices that will be used (but not limited
to) are:
All other company employees will be using external API based access points to have
access to the system, with restricted features based on their role
Access to internal systems will require usage of predefined terminals & smart cards.
Assets will be stored using a combination of multi-signature wallets and 3rd party
custodians with insurance
DACX has been quite active in the blockchain community, our first exhibition was
during London Blockchain Week of Feb 2019. When not exhibiting DACX team
members frequently attend as delegates to maximize commercial opportunities and
explore potential partnerships e.g. Consensus 2019, Malta Blockchain Summit,etc.
Our next exhibition is on 17 October 2019 during European Trading show in London.
We aim to capitalize on word of mouth marketing and focus our major efforts in
building a community in social media and engage them through mediums such as
Facebook, Instagram, Twitter, Reddit, Telegram and our own blog. To maximize
engagement, we will target the community in multiple languages through Facebook,
Twitter, Instagram and Telegram.
Our goal is to gain users and grow our community to increase the conversion rate and
the value of the user. After gaining a sizeable community we would invite our
members to periodic meetup events to connect with us to share ideas and
suggestions on how to improve their experience and future developments.
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Sponsorship is also key to promote brand awareness; we intend to support local talent
at grass root level which is in keeping with our core principles.
3. Rewards Programs
You can visit our DACX Website to see our most recent and up to date affiliations and
partnerships.
We have a few applications in the pipeline with different jurisdictions but due to
confidentiality obligations can only be communicated when an outcome has been reached.
Therefore, we are phasing in digital assets which are not in the remit of regulation e.g. utility
tokens and exchange coins (BTC, LTC, etc.,) and as we get our licenses we would phase in
tokens which fall under the definition of STOs.
The following countries that are currently restricted from participating in DACX services are:
North Korea
Iran
Syria
Sudan
Cuba
United States
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11. Appendix
11.1 Official DACX Token Wallets
// Angel Wallet: Initial distribution to Angel Investors will be made through this wallet
// Team Wallet: Initial distribution to Team Members will be made through this
wallet
// Locked Wallet: All remaining team funds will be locked for at least 1 year
// Crowdsale Wallet: All token sales (Private/Pre/Public) will be made through this wallet
// Bounty Wallet: Holds the tokens reserved for our initial and future bounty campaigns
https://etherscan.io/address/0xf6ba659b419392b722ed63d4f5232822eceff262
https://etherscan.io/address/0xf6ba659b419392b722ed63d4f5232822eceff262#code
https://etherscan.io/token/0xf6ba659b419392b722ed63d4f5232822eceff262
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12. Glossary
AML
AMM
Anti Market Manipulation prevents market manipulation which is a type of market abuse
where there is a deliberate attempt to interfere with the free and fair operation of the market
and create artificial, false or misleading appearances with respect to the price of, or market
for, a product, security, commodity or currency.
CFT
Combating the Financing of Terrorism (CFT) involves investigating, analyzing, deterring and
preventing sources of funding for activities intended to achieve political, religious or
ideological goals through violence and the threat of violence against civilians.
DLT
DEFI
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DDoS
Distributed denial of service is a type of DoS attack where multiple compromised systems,
which are often infected with a Trojan, are used to target a single system causing a Denial
of Service (DoS) attack.
ERC 20
ERC-20 is a technical standard used for smart contracts on the Ethereum blockchain for
implementing tokens.
FCA
The Financial Conduct Authority (FCA) is a financial regulatory body in the United Kingdom,
but operates independently of the UK Government, and is financed by charging fees to
members of the financial services industry.
ICO
An Initial Coin Offering (ICO) is the cryptocurrency space's rough equivalent to an IPO in the
mainstream investment world. ICOs act as fundraisers of sorts; a company looking to create
a new coin, app, or service launches an ICO.
IEO
KYC
Know Your Customer (KYC) is the process of a business identifying and verifying the
identity of its clients. The significance of “Know Your Customer” (KYC) is becoming
increasingly important. “KYC” refers to the steps taken by a financial institution (or
business) to: Establish the identity of the customer.
MVP
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Oauth 2.0
OAuth2.0 is an open authorization protocol, which allows accessing the resources of the
resource owner by enabling the client applications on HTTP services such as Facebook,
GitHub, etc.
Primary Offering
A primary offering is the first issuance of stock from a private company for public sale. This
is the means by which a private company can raise equity capital through financial markets
in order to expand its business operations.
The secondary market trading is where securities are traded after the company has sold its
offering on the primary market.
SME
STO
STO stands for security token offering. It is a process similar to an ICO where an investor
exchanges money for coins or tokens representing their investment. They are linked to an
underlying investment asset in a way like stocks, bonds, real estate investment trusts (REIT)
or other funds.
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