Due Diligence & Compliance

TM2 has implemented a comprehensive due diligence program to identify, verify and monitor its platform participants in accordance with our strict compliance guidelines.

Onboarding due diligence

The KYB check includes verifying:

  • The corporate undertaking’s status, good standing and source of funds
  • The identity and address, financial and professional standing, experience and competence of UBOs, directors and key personnel
  • Assessing fitness and probity
  • Public & Private keys generated through the TM2 Desktop Application.

The KYC check includes verifying:

  • The identity and address, financial and professional standing, experience and competence
  • Source of funds and wealth
  • Public & Private keys generated through the TM2 Desktop Application.
TM2 Comliance & Aml

Transactional Compliance

  • The TM2 Platform compliance technology checks the sender and receiver address within the Registry to enforce any applicable restraints using the registry as an authority on identity.
  • TM2 restricts technological metals holders from trading to any address that has not passed the required verification process.
  • The restrictions provide Issuers assurance that their technological metals will only be held by authorized traders in full compliance.
  • TM2 deploys surveillance and monitoring tools to detect and escalate suspected incidents of market abuse and market manipulation.

TM2 is the Central Counterparty

TM2 is the central counterparty to all trades on a matched principal basis, clearing all trades in the primary and secondary markets and delivering financial and operational efficiencies to market participants.

Clearing & Settlement of Trades​

All trades are settled directly with TM2 through the TM2 Platform, our proprietary financial and trading engine.

Conditions can vary, due to certain Issuer or Custodian procedures, please refer to each individual technology metals’ specification for precise and up to date information.

  • Trade settlement and the corresponding transfer of title occurs immediately upon trade execution.
  • Purchased technology metals can be sold on TM2 immediately.
  • Physical delivery of technology metals varies with each product and geographical location.

Protection of Member’s Funds

For trading purposes, TM2 Member’s cash balances are kept in segregated accounts. Balances can be used to purchase metals or can be withdrawn and returned by bank wire transfer according to TM2 ‘s Withdrawal Policy and TM2 Rules.

TM2’s Swiss licensed payment services provider is MOGLI, an e-wallet service owned and operated by 3ATex GmbH. 3ATex’s main custodian for cash deposits is Zurich Cantonal Bank (ZKB). ZKB is the fourth largest bank in Switzerland and is wholly owned by the Canton of Zurich who, under Swiss law, guarantees all of ZKB's liabilities should ZKB default.

NOTE: These protections do not apply against a decline or loss in market value

Protection of Member's Metals

TM2 acts as the Member’s agent and bailee with respect to the safeguarding and administration of the physical technology metals underlying any of the traded technology metals a Member holds. All technology metals recorded in a Member’s custody account are fully reserved and redeemable pursuant to the law of bailment and TM2 Rules.

Members and each accredited Custodian (vault or warehouse) has TM2’s distributed ledger with registry information installed and running on its servers. The TM2 registry is shared, replicated, and synchronised amongst the verified users of TM2, ensuring that accurate, secure and up to date trading status, balance and positions, permissions and due diligence information and data are always available. Each user is identified by a unique ID, built from a hash of personal information that keeps identification privacy safe and secure at all times.

TM2 has entered into safeguarding and administration arrangements with accredited and independent sub-custodians suitable for Issuers and each listed technology metals product.

Custodians are responsible for safekeeping and administering physical technology metals and also hold the title information for each ultimate beneficiary owner on TM2’s synchronized distributed ledger technology and are the immutable last line providers of security and title assurance.

Member’s metals are segregated and separately identified.
Reconciled and audited inventory positions are available at any time. End-of-Day (“EOD”) files provided daily.

Safeguarding and Administration Fee

  • All Members pay a safeguarding and administration fee.
  • The fee is calculated daily and is a [basis point] percentage charge of the number and amount of technology metals inventory currently in a Member’s custody wallet.
  • Fees per different traded technology metal may vary.
  • Every month, the Member is notified about the payment of the safeguarding and administration fees.
  • Member has 10 days to pay the fee.
  • If a Member does not pay the fee within 10 days, TM2 suspends their access to the platform.
  • Safeguarding and administration fee details can be found on tm2.com.

Insurance

Technology metals held in custody are fully insured against theft and destruction.

Audit

TM2’s statutory auditor undertakes physical audits of all TM2 technology metals positions on a quarterly basis. Digital to physical metals positions are verified and published on the TM2 website every day.

Member Responsibilities

As a Member, it is your responsibility to review and monitor your account through the TM2 Platform.
TM2 also urges Members to review current balance and position daily. If you believe your account does not accurately reflect your current balance or position or any other issue, contact us immediately.
Before you begin carrying out transactions on TM2, you should carefully review TM2 Rules, procedures and guides available at www.tm2.com.

Risk Disclosure

Trading of metals involves risk of loss and is not suitable for every trader. The value of the metals fluctuates, and as a result, you may lose more than your original inventory.
Members of TM2 are fully responsible for all the risks and financial resources used. TM2 is not liable for any loss, without limitation, which includes damages for any incidental and consequential losses, damages for lost opportunity, damages for lost profit, statutory damages, nominal damages, punitive damages, restitutionary- damages for costs, including legal costs, and damages for any other indirect loss.

You should not engage in metals trading unless you fully understand and accept the nature of the transactions you are entering into and the extent of your exposure to loss. If you do not fully understand these risks you should seek independent advice from an advisor. All trading strategies are used at your own risk.

It is your responsibility to confirm and decide which trades to undertake. You should only trade with risk capital that, if lost, will not adversely impact your lifestyle and your ability to meet your financial obligations as and when they fall due.

Online trading has inherent risks due to system responses/reaction times and access times that may vary due to market conditions, system performance and other factors, and on which you have no influence. You should be aware of these additional risks.

Legal and Regulatory:

Technology Metals Market Limited (“TM2”) is incorporated and registered in England and Wales with company number 12181988 whose registered office is at First Floor, 140 Brompton Road, London, England SW3 1HY. The commercial sale and purchase of investment-grade physical precious metals is not in itself a regulated activity requiring authorization or exemption under the Financial Services and Markets Act 2000. Accordingly, TM2 has not sought or obtained such authorization or exemption.
No securities or derivative products are offered or traded through TM2 and there is no functionality for short selling through the TM2 platform.

TM2 membership agreements and TM2 Rules provide the contractual terms governing the participation on the platform by Members and other market participants. TM2 does not provide investment advice. Any decision to purchase or sell technology metals is ultimately the trader’s own decision.

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