Digital Asset Trading Rules (Trading Rules)

1. Objective
As a digital asset exchange, the Company is required to establish fair trading rules so that trading conducted through the Company’s system is orderly and consistent with the rules approved by the Securities and Exchange Commission. The Company will disclose these trading rules to its customers.
2. Rule Approval Process
The Company assigns the Operations Department, through the Chief Operating Officer, responsibility for preparing and presenting the digital asset trading rules to the Executive Committee for consideration before submitting them to the Board of Directors for approval. After approval by the Board of Directors, the Company will submit the trading rules to the Securities and Exchange Commission for its consideration and approval before they are officially announced.
Where the establishment of the trading rules may affect the business operations or the interests of service users or related persons, the Company will arrange a public hearing of opinions from such persons, conducted in a general manner, and submit a report of that public hearing to the Securities and Exchange Commission to support its consideration and approval.
In summary, the rule approval process follows these steps:
The Operations Department, through the Chief Operating Officer, prepares the digital asset trading rules.
The Chief Operating Officer presents the rules to the Executive Committee for consideration and approval.
If the conditions requiring a public hearing are met, the Operations Department, through the Chief Operating Officer, arranges the hearing accordingly (if the conditions are not met, skip to step 5).
The Operations Department, through the Chief Operating Officer, incorporates the opinions received to revise the digital asset trading rules and presents them to the Executive Committee for consideration and approval again.
The rules are then submitted to the Board of Directors for approval and forwarded to the Securities and Exchange Commission for its consideration and approval before being officially announced.
3. Service Days and Hours
The Company provides services 24 hours a day, every day. However, if a necessary event requires a change to the service days and hours or a temporary suspension of service — such as a shutdown for system performance maintenance — the Company will notify customers in advance through its application, email, and website, following the operating procedures set out in the rules governing the digital asset trading system, which are published on the Company’s website.
4. Order Ranking and Order Matching Principles
For order matching, the Company establishes rules for ranking the buy and sell orders that buyers and sellers submit through the Company’s trading system using Automatic Order Matching, under which the Company’s system automatically ranks and matches orders. Under this principle, when an order is submitted, the trading system retains the order from the time it is submitted until the customer cancels it. The system ranks orders in the Order Book, separating Buy Orders from Sell Orders, by the best price and time (Price then Time Priority), on the following basis:
For buy orders: the buy order with the highest bid price is ranked first. If a higher bid price is subsequently submitted, the system ranks the higher bid price first. If there is more than one order at a given price, they are ranked by time, with the order that appears in the trading system earlier ranked ahead.
For sell orders: the sell order with the lowest offer price is ranked first. If a lower offer price is subsequently submitted, the system ranks the lower offer price first. If there is more than one order at a given price, they are ranked by time, with the order that appears in the trading system earlier ranked ahead.
For the matching principle, once an order enters the trading system, the system checks whether the order can be immediately matched with an order on the opposite side. If it can be matched immediately, the system matches it. If it cannot be matched, the system ranks the order according to Price then Time Priority.
5. Order Types and Their Meanings
6. Order Placement Rules
The Company establishes rules for placing orders, comprising the conditions set out below, and will disclose these rules on its website. These rules apply to all types of cryptocurrencies and digital tokens, although certain rules may differ depending on the quantity, price, or value of each coin. The Company provides the following examples of order placement rules for BTC, ETH, XRP, and XLM:
Minimum Trade Amount — the smallest number of coins that can be placed in a buy or sell order. From the XRP example above, this means a customer must place a buy or sell order of at least 1 XRP.
Minimum Amount Movement — the smallest increment by which the coin quantity in each buy or sell order can be increased or decreased. From the XRP example above, the smallest adjustment per order is 1 XRP. A customer may therefore increase a buy order for XRP from 1 XRP to 2 XRP or 3 XRP, but cannot adjust from 1 XRP to 1.5 XRP.
Minimum Price Movement — the smallest increment by which the price in each buy or sell order can be increased or decreased. From the XRP example above, the smallest price adjustment per order is THB 0.01. A customer may therefore increase the buy price for XRP from THB 1 to THB 1.01 or THB 1.02, but cannot adjust from THB 1 to THB 1.005.
Minimum Order Size — the smallest value for which each buy or sell order can be placed, with a minimum of THB 100 per order. If a customer places an order with a value of THB 100 but the resulting coin quantity is below the minimum trade amount under (a) above, the system will notify the customer that the transaction cannot be completed because the order must also meet the minimum coin quantity.
The Company does not set a maximum order quantity (Maximum Market Order Amount), i.e., the largest number of coins that can be placed in a buy or sell order. Therefore, if a customer places a buy or sell order with a very large quantity, the order will be partially matched to the extent that opposite-side orders are available in the market at that time. For a Market Order, the customer’s remaining portion will be cancelled (whereas for a Limit Order, the customer’s remaining portion will remain effective).
In addition, the Company specifies the methods for amending or cancelling orders in the terms of use published on its website.
7. Order Placement, Clearing, and Settlement Mechanisms
The Company establishes mechanisms for order placement, clearing, and settlement, with methods, mechanisms, and processes designed to avoid creating settlement default risk for buyers or sellers trading through the system, as well as a reasonable method for valuing digital assets, as published on the Company’s website, as follows:
The method for clearing and settling digital assets, which enables buyers or sellers to settle and deliver digital assets according to the agreed transactions and to mitigate the risks that may arise from settlement default.
Before a customer can confirm an order, the Company’s system sends the order to verify the customer’s assets — both Thai Baht and/or digital assets — to check whether they are sufficient for the order. If the customer’s assets (Thai Baht / digital assets) are insufficient, the customer cannot confirm the order, and the system will notify the customer to first deposit Thai Baht or digital assets into the system before the buy or sell order can be placed. The system displays the maximum asset amount the customer holds and can transact; if the customer attempts a transaction exceeding the stated value, the system will not record the order for the excess amount.
Where the customer has sufficient cash or digital assets, the Company’s system records the order and immediately reserves that amount of the customer’s cash or digital assets for clearing and settlement. The customer therefore cannot place another transaction using the same cash or digital assets unless the order is cancelled.
Once an order has been successfully and fully matched, the Company’s system deducts the price and trading fee from the digital assets or Thai Baht to be delivered. The customer is notified of the fee deducted from their assets once the system has completed the matching.
In calculating the value of transactions between digital assets and Thai Baht, the Company applies the following rules:
Thai Baht deposit/withdrawal value: all Thai Baht deposits and withdrawals for trading and exchange through the Company’s system must be conducted in Thai Baht only.
Digital asset deposit/withdrawal value: each digital asset deposit or withdrawal is recorded in US Dollars at the time the deposit or withdrawal transaction occurs on the Company’s system (using the reference exchange rate from www.coinmarketcap.com). The Company then converts the recorded US Dollar amount into Thai Baht using the average exchange rate that commercial banks use for transactions with customers, as announced by the Bank of Thailand on the last business day before the date of the deposit or withdrawal transaction.
Digital asset–Thai Baht trading transaction value: the value of digital asset trading and exchange transactions in Thai Baht is based on the actual value traded directly through the Company’s digital asset exchange, without any further exchange-rate calculation.
A method that displays the increase or decrease in the customer’s outstanding asset balance in the trader’s account immediately upon matching, so that the trader can check the asset balance as soon as a trade or digital asset transfer occurs.
When an order is submitted to trade or exchange, the customer’s account is updated immediately, showing open orders awaiting matching, and the customer’s order appears in the Company’s order book to be matched with subsequent orders. To place an order, a customer may submit it through the Company’s website or application, specifying the following: (1) whether to buy or sell; (2) the type and quantity of the digital asset to buy, sell, or exchange; and (3) the order type, which the customer may place as follows:
Limit Order — an order that specifies the price at which to buy or sell, together with the quantity. Matching occurs only when:
for a buy order, the offer price is equal to or lower than the price specified in the buy order; or
for a sell order, the bid price is equal to or higher than the price specified in the sell order.
Market Order — an order that specifies the quantity to buy or sell but not the price. It is matched immediately against the best-priced orders then available in the order book sufficient to fill the customer’s placed quantity. If only partially filled (where there is insufficient opposite-side quantity), the remaining portion is cancelled.
Stop Limit Order — a buy or sell order in the form of a Limit Order, but with a price condition (trigger price) that must occur first before the Limit Order is placed. The customer must specify both the trigger price and the desired buy or sell price of the Limit Order. The submission of the Limit Order is deemed effective when the trigger price occurs (not when the Stop Limit Order is submitted).
Once a customer places an order through the Company’s system, the system ranks orders to build the order book according to Price then Time Priority, namely: (a) for buy orders, the buy order with the highest bid price is ranked first, and if a higher bid price is subsequently submitted, the system ranks the higher bid first; if there is more than one order at a given price, they are ranked by time, with the earlier order ranked ahead; or (b) for sell orders, the sell order with the lowest offer price is ranked first, and if a lower offer price is subsequently submitted, the system ranks the lower offer first; if there is more than one order at a given price, they are ranked by time, with the earlier order ranked ahead.
8. Trading Fees
The Company publishes its trading fee rates on its website.
9. Trading Suspension
1. Case-by-case suspension of a specific customer
This applies to a specific customer whose transaction behavior is abnormal and may cause market misunderstanding. The process is as follows:
Detection of abnormal trading conditions and unfair trading-related conduct, namely the use of inside information (Insider Trading), misleading the public about trading price or volume (Market Manipulation), and spreading rumors or making false statements (Misstatement).
The responsible officers — the Market Surveillance Department — analyze, investigate, and verify the facts and evidence as to whether the conduct actually occurred, and propose an initial course of action to the Head of the Market Surveillance Department for approval. (The course of action is determined according to the severity of the offense: a warning for a first offense; a warning and a 1-day trading suspension for a second offense; and a warning and a 7-day trading suspension for a third and subsequent offenses. However, where the offense is clear-cut and the offender is subject to a complaint or enforcement by the SEC Office, the Market Surveillance Department refers the matter to the Executive Committee to consider decisive measures, namely termination of the relationship and account closure.)
If the Head of the Market Surveillance Department agrees that the conduct actually occurred, they report to the most senior executive of their function, namely the Chief Operating Officer, for consideration and approval of the action.
If the Chief Operating Officer determines that the event is not true (considering the weight of the evidence — for example, where verifiable evidence is inconsistent with the conduct, or the offense cannot yet be clearly established), the Market Surveillance Department terminates the investigation and records the reasons supporting the decision as evidence for future review (recorded in electronic form and retained for at least 10 years from the date of recording, with the Head of the Market Surveillance Department reviewing whether the record is accurate and complete). However, if the Chief Operating Officer determines that the event is true and that the customer should be warned and/or suspended, as the case may be, the Market Surveillance Department notifies the Exchange Operations Department to coordinate the warning and/or suspension of that customer as approved by the Chief Operating Officer (as the case may be). (The outcome of the above consideration is also reported to the Chief Executive Officer and the Chief Legal, Compliance, and Risk Officer.)
Where the measure is a warning only, the Exchange Operations Department issues the warning by notifying the customer via email. Where the measure is a warning and trading suspension, the Exchange Operations Department first carries out the suspension and then issues the warning by notifying the customer via email (without prior notice to the customer). The warning is issued in a form approved by the Legal Department, and the customer need not sign any additional acknowledgment, as it is sent to the customer’s email already on file with the Company.
Notes
Because trading suspension is a measure that significantly affects customers, the Company requires the Compliance Department to review the operations of the Market Surveillance Department and the suspension decisions of the Chief Operating Officer on a random basis at least once per year.
Any buy or sell orders the customer placed before being suspended are deemed expired and cancelled after the suspension takes effect.
Upon expiry of the suspension period as notified to the customer, the customer can resume trading as normal.
1.2 Suspension of a specific customer posing risk under anti-money laundering law
This applies to a specific customer whose characteristics pose a risk under the law on anti-money laundering and counter-terrorism financing. The process is as follows:
Detection, through the name-screening system, of factors that classify the customer as high money-laundering risk — for example, being on a list of persons with high money-laundering risk, or being a designated person or on the UN list as prescribed by the AMLO Office.
The responsible officers as the 1st line — the Identity Verification Department — analyze, investigate, and verify the facts and evidence on a preliminary basis as to whether the screening result is correct, and then forward the result to the Anti-Money Laundering Department for further consideration.
The Anti-Money Laundering Department, as the 2nd line, considers whether the preliminary result of the Identity Verification Department is correct, and then notifies the most senior executive of its function, namely the Chief Legal, Compliance, and Risk Officer, for consideration and approval of the action.
If the Chief Legal, Compliance, and Risk Officer determines that the event is not true, the Anti-Money Laundering Department instructs the Identity Verification Department to terminate the investigation and record the reasons supporting the decision as evidence for future review (recorded in electronic form and retained for at least 10 years from the date of recording, with the Anti-Money Laundering Department reviewing whether the record is accurate and complete).
However, if the Chief Legal, Compliance, and Risk Officer determines that the event is true and that the customer should be suspended, the Anti-Money Laundering Department notifies the Identity Verification Department and instructs the Exchange Operations Department to suspend that customer’s trading as approved by the Chief Legal, Compliance, and Risk Officer. Where it is found that the customer is a designated person or on the UN list as prescribed by the AMLO Office, the Chief Legal, Compliance, and Risk Officer approves termination of the relationship with that customer as required by anti-money laundering law.
The Exchange Operations Department carries out the trading suspension in the system, or terminates the relationship with the customer (as the case may be), and notifies the customer via email. However, it must not disclose the reason for the suspension or termination (as the case may be) arising from matters relating to anti-money laundering actions, as this may constitute tipping off the customer and would contravene anti-money laundering law.
Notes
To align with the 3 lines of defense principle, the Company defines the roles and responsibilities of the relevant units as follows:
(a) Identity Verification Department, as the 1st line: analyzes, investigates, gathers, and verifies preliminary evidence and facts, and carries out the trading suspension or relationship termination and the notification to the customer.
(b) Anti-Money Laundering Department, as the 2nd line: considers and verifies the results of the fact and evidence checks relating to anti-money laundering law presented by the Identity Verification Department.
(c) Chief Legal, Compliance, and Risk Officer: acts as the 2nd line for considering and approving the management measures presented by the Anti-Money Laundering Department.
(d) Internal Audit: acts as the 3rd line for reviewing the operations of the various units involved in trading suspension.
Any buy or sell orders the customer placed before being suspended are deemed expired and cancelled after the suspension takes effect.
A case-by-case suspension of a specific customer arising from characteristics posing a risk under anti-money laundering law remains in effect until the relevant risk factor is removed or lifted, after which the customer may resume trading.
2. General trading suspension
This applies where the digital asset exchange’s operating system is shut down for maintenance, which is a planned and pre-arranged action. The process is as follows:
The Chief Information Officer notifies the Executive Committee of the need to shut down the digital asset exchange’s operating system, covering at least the following: the reason for the shutdown; the duration of the shutdown (which must allow at least 15 days’ advance notice to customers before a general trading suspension); the date and time of the shutdown; and the expected date and time the system will resume service.
The Executive Committee considers the action, taking into account necessity and minimizing the impact on customers as much as possible (for example, if the shutdown is about 1 hour, considering a time slot of 03:00–04:00). Once the Executive Committee considers it appropriate to proceed as proposed by the Chief Information Officer, the relevant units carry out the following:
The Chief Marketing Officer and the Chief Legal, Compliance, and Risk Officer jointly prepare the content to be used to communicate with customers.
The Chief Operating Officer communicates with customers using the content prepared by the Chief Marketing Officer and the Chief Legal, Compliance, and Risk Officer, through the prepared channels, namely email and an announcement on the Company’s website.
The Chief Legal, Compliance, and Risk Officer reports to the SEC Office.
If an additional shutdown is required, the Chief Information Officer promptly acts and seeks approval from the Executive Committee, explaining at least the reason for the additional shutdown, its duration, its date and time, and the expected date and time the system will resume service. If the Executive Committee agrees that an additional shutdown is necessary, the relevant units carry out the following:
The Chief Marketing Officer and the Chief Legal, Compliance, and Risk Officer jointly prepare the content to be used to communicate with customers.
The Chief Operating Officer communicates with customers using the content prepared by the Chief Marketing Officer and the Chief Legal, Compliance, and Risk Officer, through the prepared channels, namely email and an announcement on the Company’s website.
The Chief Legal, Compliance, and Risk Officer reports to the SEC Office.
Once the shutdown is complete, the Chief Information Officer reports to the Executive Committee for its consideration and approval to resume normal service.
Note: Because customers are notified in advance in this case, any buy or sell orders the customer placed before the suspension are deemed expired and cancelled after the suspension takes effect.
3. Suspension of a particular trading pair
This applies where an abnormal event occurs, or an event that may materially and adversely affect customers’ interests. The process is as follows:
The Analysis Team monitors and watches for events that occur and may adversely affect the interests of customers in relation to the cryptocurrencies or digital tokens the Company offers, and notifies the Digital Asset Selection Committee for acknowledgment and consideration of approving a trading suspension. In an urgent case, the Chairperson of the Digital Asset Selection Committee convenes a meeting through the Company’s internal electronic communication system to consider the matter as quickly as possible, so that an appropriate management measure can be decided in a timely manner.
The Digital Asset Selection Committee considers the event as reported by the Analysis Team and whether a trading suspension should be approved, taking into account that events that may materially and adversely affect customers’ interests include changes affecting coin holders’ interests and changes in the price of the digital asset, and also include the issuer experiencing serious problems or ceasing business, dissolution, bankruptcy, insolvency, changes to the white paper, or any change that materially affects the issuer’s revenue or the digital asset offered.
If the Digital Asset Selection Committee approves the trading suspension, the relevant units carry out the following:
The Chief Marketing Officer and the Chief Legal, Compliance, and Risk Officer jointly prepare the content to be used to communicate with customers.
The Chief Operating Officer communicates with customers using the content prepared by the Chief Marketing Officer and the Chief Legal, Compliance, and Risk Officer, through the prepared channels, namely email and an announcement on the Company’s website, with at least 6 hours’ advance notice.
Because customers are notified in advance in this case, any buy or sell orders the customer placed before the suspension are deemed expired and cancelled after the suspension takes effect.
However, once the cause of the suspension has been resolved, the Analysis Team reports to the Digital Asset Selection Committee for consideration and approval to lift the suspension. If the Analysis Team determines that the trading pair under suspension should be delisted, the Analysis Team presents this to the Digital Asset Selection Committee for consideration and approval of the delisting in accordance with the prescribed process.
10. Display of Warning Signs and Disclosure of Information
To further enhance the protection of customers in trading and using digital assets, the Company requires the digital asset exchange system to display warning signs together with disclosure of information in the following events:
11. Channels for Disclosing the Trading Rules to Customers
Customers can study information about the digital asset trading rules through the Company’s application and website under the Support section, and can contact the Company directly through its Chatbot or Live Chat.