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  • Privacy Notice
  • Site Terms of Use
  • Exchange Terms of Service
  • Market Rules
  • Additional Terms for AMM Instructions
  • Risk Warnings
  • Fee Schedule
  • Bullish Event Privacy Notice
Last Updated: October 18, 2022

Market Rules

1. Interpretation and Application of Rules

1.1. Purpose of the Rules

1.1.1. These Market Rules are issued by Bullish to provide a framework for the operation of the Platform. They apply to Bullish as provider of the Platform and to all Customers. 

1.1.2. These Market Rules, together with the Bullish Rules, are intended to:

  • describe the responsibilities and duties of Bullish as a DLT license holder; 
  • ensure Bullish fulfils its general regulatory responsibility as set out in the Gibraltar Financial Services legislation and specifically that it complies with the Nine Regulatory Principles of the DLT Regulations;
  • set out criteria for Customers using the Platform; 
  • set out trading rules and ongoing supervision of the Platform to ensure a fair and orderly market; and
  • specify custody and settlement arrangements.

1.2. Introduction

1.2.1. Bullish (GI) Limited is a private limited company incorporated in Gibraltar on 2 April 2020, number 119714 and licensed by the Gibraltar Financial Services Commission as a DLT Provider under license number FSC1038FSA. The registered office of Bullish is at Suite 23, Portland House, Glacis Road, Gibraltar.

1.3. Key Terms

AMM Algorithmmeans the Bullish automated market-making algorithm
Assetsmeans any assets, including Digital Currency and Fiat Currency, that Bullish receives, holds or makes available for trading on the Platform
Assets Listmeans the list of Assets that are admitted for trading on the Platform
Available Balancesmeans Assets available in a Customer Account that are not subject to a Hold or otherwise unavailable at a given point in time
Bullishmeans Bullish (GI) Limited, a private limited company registered in Gibraltar with company number 119714 and having its registered office at Suite 23, Portland House, Glacis Road, Gibraltar
Bullish Rulesmeans the aggregate set of rules and obligations applicable to Bullish and/or its Customers, including these Market Rules, the Terms of Service and other rules and terms as relevant and updated from time to time
Customermeans any individual or corporate entity who has an Account to access the Platform
Customer Assetsmeans any assets, including Digital Currency and Fiat Currency, that Bullish receives from or holds for, or on behalf of, any Customer
Digital Currenciesmeans any digital currency that uses distributed ledger technology as the basis for recording transactions
DLT Regulationsmeans the Gibraltar Financial Services (Distributed Ledger Technology Providers) Regulations 2020, pursuant to which Bullish is regulated and licenced to operate the Platform by the GFSC
Employeemeans persons employed or appointed by Bullish to conduct its business, including a:director;officer;staff member;part-time employee;service provider (including any consultant, agent, advisor or contractor); andany other person that is designated by Bullish as an Employee from time to time.
Fiat Currencymeans a government issued currency
Filling (Trades)means the fulfilment of an Order, in part or in full and references to “Fill” and “Filled” shall be construed accordingly
Garnishmentmeans a court order directing that money or property of a third party be seized to satisfy a debt
GFSCmeans the Gibraltar Financial Services Commission
Holdmeans the temporary setting aside of Customer Assets by Bullish at the time a Order is entered on the Platform
Hybrid Order Bookmeans the order book where Orders are executed against matching Orders
Matched or Matchingmeans the matching of an Order with another Order in the Hybrid Order Book
Matching Enginemeans the order book technology that determines that Orders are Matched according to specified priority
Ordermeans an order to buy or sell Assets on the Platform
Platformmeans the digital currency exchange platform owned and operated by Bullish
Regulatory Authoritymeans the authorities under whose relevant rules and regulations Bullish must operate, including the GFSC
Subpoenameans a court order which requires the recipient to produce information
Tax Levymeans an action by a governmental agency to seize Assets to satisfy a tax liability 

1.4. Other Defined Terms

1.4.1. Unless defined above, capitalised words used in these Market Rules shall have the same meaning given to them in the Appendix to the Exchange Terms of Service.

2. Compliance

2.1. Laws and Regulations

2.1.1. Bullish must comply with the applicable laws and regulations of Gibraltar.

2.1.2. Bullish must comply with the orders, directives, rules and notices issued by the Regulatory Authority. 

2.1.3. Bullish must comply with all other laws or regulations applicable to its activities and the jurisdictions in which it operates. 

3. Participation

3.1. Eligibility and Account Opening

3.1.1. The eligibility, Account opening and participation requirements are set out in the Terms of Service. 

4. Admission and Suspension of Assets

4.1. Assets List

4.1.1. Bullish must at all times maintain the Assets List of all Assets admitted to trading on the Platform.

4.1.2. Bullish will ensure that the Assets List is available at all times on the Platform Site or the Platform interface.

4.2. Admission of New Assets

4.2.1. Bullish may admit any Asset to trading on the Platform and may do so in its sole discretion.

4.3. Removal or Suspension of Assets

4.3.1. Bullish may suspend trading of any Asset for any Customer or category of Customers and/or for all Assets and Customers (or any combination thereof) and may do so in its sole discretion.

4.3.2 Bullish may only remove or suspend Assets from trading provided that such removal or suspension would not compromise the integrity of the Platform. 

4.3.3. Bullish will announce any removal or suspension of any Asset from trading by issuing a formal notice on the Platform Site and via the Platform interface.

4.3.4. Bullish reserves the right to cancel any Orders, to place a Hold and/or to liquidate any open positions in removed or suspended Assets and/or for any removed or suspended Customer or category of Customers as necessary to maintain the effective, fair and orderly functioning of the Platform.

4.3.5. Cancellation of Orders, Holds and/or liquidation of open positions will only be undertaken if it will not compromise the integrity of the Platform.

4.4. Restoration of Trading and Suspended Assets

4.4.1. Bullish may restore to trading any Asset that has been suspended from trading and may do so in its sole discretion. 

5. Trading

5.1. Accessing the Platform

5.1.1. Customers may access the Platform by the following methods: 

  • the web Platform interface;
  • approved Bullish Application Programming Interface (API) connections; or
  • the mobile Platform interface (when activated).

5.2. Trading Hours

5.2.1. The Platform is operational 24 hours a day, 365 days per year except in the case of scheduled and unscheduled maintenance.

5.3. Hybrid Order Book

5.3.1. Bullish will operate the Hybrid Order Book in which Orders are Filled against matching Orders from other Customers, including those generated by the AMM Algorithm. 

5.3.2. The AMM Algorithm will provide Orders from Customers according to a continuous price-at-quantity algorithm for certain listed Assets.

5.4. Placing Orders

5.4.1. In order to place an Order, a Customer must have Available Balances of the relevant Asset in its Account sufficient to cover the total value of the Order plus any applicable fees

5.4.2. When an Order is placed and accepted, the relevant quantity of the relevant Assets will be subject to a Hold until the Order is Filled or cancelled. 

5.4.3. Open Orders may be cancelled at any time prior to being Filled subject to the sole discretion of Bullish.

5.4.4. Customers will receive notification of Order receipt via the Platform interface or API connection and will receive ongoing confirmation data as outlined in Section 5.10.

5.5. Limit Orders

5.5.1. A Limit Order is an Order to buy or sell a specified quantity of an Asset at or better than a specified price. 

5.5.2. A Limit Order will only ever be Filled at the specified price or a better price. 

5.6 Stop Limit Orders

5.6.1 A Stop Limit Order is an Order to buy or sell a specified quantity of an Asset only if and when the stop price is reached and then only at or better than a specified price. 

5.7. Market Orders

5.7.1. A Market Order is an Order to buy or sell a specified quantity of an Asset at the best available market price having regard to existing Orders placed by other Customers on the Hybrid Order Book. 

5.7.2. A Market Order may Fill at a range of different prices based on the size of the Market Order.

5.8. Good Till Cancelled Orders

5.8.1. A Good Till Cancelled Order is an Order to buy or sell a specified quantity of an Asset only at or better than a specified price which remains pending until Filled or cancelled.

5.8.2. A Good Till Cancelled Order will only ever be Filled at the specified price or a better price.

5.9. Filling, Matching and Priority

5.9.1. The Hybrid Order Book Matches and Fills Orders based on price-time priority. 

5.9.2. Price-time priority means that prioritisation for Matching and Filling of Orders is based on the timestamp of the Order with the same price. If two Customer Orders are submitted in relation to the same Asset pair at the same price, the Customer Order which was entered earliest (having regard to the time stamp) will be Filled first.  If an AMM Algorithm Order and a Customer Order are submitted in relation to the same Asset pair at the same price, the AMM Algorithm Order will be Filled first. All AMM Algorithm Orders submitted in relation to the same Asset pair at the same price will be given equal priority and Filled proportionately.

5.10. Account Data and Confirmations

5.10.1. Bullish will maintain and provide Account information for all Customers at as close to real time as possible, including account balances.

5.10.2. Bullish will provide confirmations to Customers of all Platform trading activity including Orders placed, cancelled or Filled.

5.10.3. Confirmations will provide information relevant to the trading activity, including activity type, order type, order time stamp, limit prices, Fill price, order and Fill size.

6. Fair and Orderly Market

6.1. Fair and Orderly Conditions

6.1.1. Bullish is committed to maintaining an effective, fair and orderly Platform for all Customers. As a result, Bullish may take any action that it considers necessary to ensure that the Platform is operating in an effective, fair and orderly manner, including:

  • rejecting Orders or other electronic messages submitted to the Platform;
  • suspending or halting trading in all or part of the Platform;
  • cancelling or amending any relevant transaction; 
  • taking, or refraining from taking any specified action in connection with the Platform; 
  • modifying, restricting or suspending access by one or more Customers to all or part of the Platform. 

6.1.2. Customer transactions must be founded on an economic and/or rational basis.

6.1.3. Customers are prohibited from undertaking any trading activities that are intended to artificially manipulate the prices or liquidity of Assets on the Platform or to otherwise engage in any activity intended to undermine the effective, fair and orderly functioning of the Platform. Behaviours that are expressly prohibited on the Platform include, but are not limited to: 

  • attempting to sell and repurchase the same Asset in quick succession for the account of one and the same beneficial owner or in collusion with other beneficial owners (‘wash trading’) without a supporting economic and/or rational basis like market making; 
  • attempting to pre-arrange the entry of equal and opposite buy and sell Orders in the same Asset subsequent to prior mutual agreement with the intent to distort liquidity or market prices (‘daisy chains’); 
  • attempting to affect liquidity and price distortion by deliberately creating an overhang of buy or sell Orders (‘ramping’, ‘capping’, or ‘pegging the market’) without the intent of executing those Orders; 
  • attempting to assume large positions with the intent to constrict the market (‘squeezing’ or ‘cornering the market’); or
  • attempting to place large size Orders with the intention of immediately cancelling the Orders (‘spoofing’ and ‘layering’).

6.1.4. Customers are prohibited from undertaking activities or engaging in behaviour that directly or indirectly undermines the effectiveness, fairness, orderliness of the Platform and/or the reputation of Bullish, the Platform or other Customers, including but not limited to: 

  • fraudulent acts;
  • violation of laws relevant to Bullish;
  • wilfully seeking to bring Bullish, the Platform or other Customers into disrepute;
  • wilfully undertaking any action in the interest of causing detriment to Bullish, the Platform or other Customers; or 
  • engaging in any form of intimidation or coercion with respect to Employees and/or other Customers.

6.1.5. The Platform and Customer activity will be subject to ongoing monitoring and investigation as outlined in Section 8.

6.2. Access Credentials

6.2.1. Bullish is committed to maintaining the security of the Platform and Customer information and Assets and will only permit access to the Platform using approved multi-factor authentication methods.

6.2.2. Customers are required to protect their Platform login credentials, passwords and any security devices at all times. Under no circumstances may a Customer share their Platform login credentials, passwords and/or security devices with an unauthorised third party.

6.3. Disclosure regarding market participation

Bullish is part of a global group that engages in a range of businesses. Bullish group entities and related parties may trade their own Assets on the Platform and participate in other services and transactions on the Platform. Bullish group entities and related parties may own or have other interests (which may include short interest) in or derivative of Assets. Bullish has policies in place to identify and manage conflicts of interest. These policies require segregation of responsibilities and information where necessary to protect clients’ interests.

7. Settlement and Custody

7.1. Settlement

7.1.1. Settlement on the Platform shall occur upon an Order being Matched in the Hybrid Order Book.

7.1.2. When an Order is submitted to the Hybrid Order Book the corresponding Assets are placed on Hold for the Order duration until it is cancelled, at which point the Hold will be lifted and the Assets will be made available for trading again, or it is Filled, at which point the Order will be settled.

7.1.3. Although settlement of transactions carried out on the Platform shall be as close to instantaneous as possible, there may be circumstances that introduce some latency into the settlement process, either as a result of direct action by Bullish to maintain an effective, fair and orderly Platform, or due to circumstances outside of the control of Bullish. 

7.2. Custody

7.2.1. All Digital Currencies in custody with Bullish will be held in a cryptographically secure hybrid wallet custody service. Most of the Digital Currencies will be secured in cold custody where the majority of keys are permanently offline. Bullish may in its sole discretion use third party custodians to provide Digital Currencies custody services. 

7.2.2. Private keys are locked in hardened devices on a secure closed network and offline keys are distributed globally. To process withdrawals a multi-signature design ensures that a number of encrypted keys are required to process withdrawals. Bullish may in its sole discretion limit withdrawals under certain circumstances as detailed in the Terms of Service. 

7.3. Unclaimed Customer Assets

7.3.1. Bullish may transfer to a registered charity of its choice Customer Asset balances which have been allocated to a Customer but remain unclaimed in instances where:

  • this is permitted by law and is consistent with the arrangements under which the Assets are held; 
  • the Assets have been held for at least 6 years following the last transaction in the Customer’s Account; and
  • it can be demonstrated that reasonable steps have been taken to trace the Customer concerned and return the balance.

8. Monitoring and Investigation

8.1. Monitoring

8.1.1. Bullish will monitor the Platform, the activities of Customers on the Platform and the execution of relevant transactions for the purpose of ensuring an effective, fair and orderly market.

8.1.2. Bullish will monitor compliance with these Market Rules and all applicable laws and regulations, and may at any time investigate the activities of any Customer and any relevant transaction. 

8.2. Investigation

8.2.1. Bullish reserves the right to investigate the activities of any Customer and any relevant transaction for any reason, including under routine and/or randomised monitoring, on the basis of alerts generated by real-time electronic monitoring systems, in connection with other monitoring or investigation activities or in response to requests from Regulatory Authorities or law enforcement agencies.

8.2.2. Requests for investigation from Regulatory Authorities or law enforcement agencies may be issued in connection with potential or suspected regulatory breaches or financial crimes, including market abuse, money laundering, proliferation financing and/or financing of terrorism. 

8.2.3. As part of any investigation, Bullish may require a Customer to provide certain information, documents or records, that are in the Customer’s possession, custody, power or control, relating to the Customer’s activities in connection with the Platform or the Customer’s trading and financial activities. 

8.2.4. Bullish may require the immediate provision by a Customer of accurate information about its transactions in a format, electronic or otherwise, as specified by Bullish.

8.2.5. Bullish may give any direction to a Customer, in relation to an investigation by Bullish under these Market Rules, that Bullish considers is reasonable and necessary to preserve the integrity of any investigation or that is otherwise appropriate, having regard to the obligations of Bullish pursuant to any requirements of a Regulatory Authority.

8.2.6. Customers are required to cooperate with all investigation requests from Bullish. 

9. Cooperation with Authorities

9.1. Requirement to Cooperate

9.1.1. Bullish is required to cooperate with all relevant Regulatory Authorities, including but not limited to the Gibraltar Financial Services Commission (GFSC) and the Gibraltar Financial Intelligence Unit (GFIU). 

9.1.2. Bullish reserves the right to respond to any legal documents served in relation to the Platform and/or Customers, including but not limited to Subpoenas, Garnishments and Tax Levies. Any response to such legal documents will be made at the discretion of Bullish on the basis of advice from its in-house and/or external legal counsel.

9.1.3. Bullish will only notify a Customer of any served legal documents relating to their account or activities, and any actions taken in association with such documents, in circumstances where such notification is not prohibited and will not expose Bullish, the Platform or any other Customers to risks, legal or otherwise.

9.2. Regulatory Notifications

9.2.1. Bullish is required to provide all necessary information to the relevant Regulatory Authority relating to any regulatory notification issued under any applicable law, regulation, order, directive, rule or other such instruments issued by the relevant Regulatory Authority. 

9.3. Consent Requirements

9.3.1. Bullish will comply with all consent requirements imposed by a relevant Regulatory Authority.

10. Powers

10.1. Power to Make Rules

10.1.1. Bullish shall have the power to amend or supplement these Market Rules and to create new rules so as to ensure the effective, fair and orderly functioning of the Platform. 

10.1.2. Bullish may issue any notice, guidance and circular it considers necessary for the effective, fair and orderly functioning of the Platform. 

10.1.3. Any amendment, supplement, rule, notice, guidance and circular will be effective on issue or such other date specified by Bullish.