HDR Global Trading Limited and its subsidiaries (collectively, “HDR”) take compliance matters extremely seriously and are committed to managing risks of the different business areas. HDR is regularly refining and strengthening its controls, to address evolving risks and threats.
Regulators globally have made substantial progress by agreeing new global standards that will prevent virtual assets and Virtual Asset Service Providers (“VASPs”) from being misused for transactions with links to crime or terrorism. To that end, one of the key missions for HDR is to significantly reduce money laundering and terrorist financing risks through the development of a robust Anti-Money Laundering (“AML”) Programme.
HDR has no tolerance for knowingly, or through willful negligence, facilitating activities related to money laundering, terrorist financing or financial crimes more broadly. HDR will not enter into, or maintain, business relationships with customers who HDR has identified as outside of its AML risk-tolerance, or who have been identified as, or are associated with, sanctioned parties.
HDR’s AML Programme articulates its commitment to take reasonable measures to detect and deter money laundering, terrorist financing, and other financial crimes. Additionally, it outlines HDR’s commitment to comply with economic and trade sanctions administered and enforced by governments and supranational bodies.
Transaction screening is another effective way to detect accounts that HDR suspects may involve the proceeds of crime including, but not limited to, activities related to child abuse, darknet markets, sanctions, terrorist financing, scams and stolen funds. HDR will make appropriate filings to relevant authorities and place restrictions on accounts where necessary.
HDR will continue to implement appropriate processes to mitigate and alleviate risks posed to the business and address evolving Regulatory requirements.
Trust and transparency are important to HDR because HDR believes that every BitMEX user deserves safe, secure, and fair markets. Under HDR Terms of Service , users are prohibited from being involved in or initiating any form of market manipulation. This guidance clarifies some of the behaviours that HDR considers would constitute market manipulation (but is not an exhaustive list).
To ensure an equitable trading environment, HDR monitors for signs of market abuse. HDR considers market abuse as including the following behaviours:
a. Accommodation Trades - A type of trading in which one person accommodates another by entering into a non-competitive purchase or sale order. Accommodation trades often happen when two persons are participating in off-market trading e.g. pre-arranged trades.
b. Insider dealing - A type of trading that occurs on the basis of inside information. This information is of a precise nature about any product being traded which has not been made public.
c. Price and volume manipulation - A type of trading which gives a false impression of a price move or the liquidity of any product being traded. A few common examples are wash trades, spoofing, layering, and quote stuffing.
d. Dissemination of false and misleading information - When a person tries to move the price of a product in a particular direction by giving false information using electronic or other media.
HDR undertakes surveillance on all trading activities to detect and mitigate any abusive behaviors. If HDR discovers any potential market manipulation, HDR will take further action. These actions may result in enquiries and warnings, and may ultimately lead to banning of accounts in severe or repetitive cases.