1. Purpose
This Framework describes IDSX systems, controls and procedures for monitoring trading, identifying abusive or disorderly conduct, investigating unusual activity and protecting market integrity. Objectives include fair and orderly trading; detection of manipulation, suspicious patterns and misuse of material non-public information; monitoring wash or coordinated trading, Digital Securities and compliance; supporting investigation and enforcement; and lawful cooperation with authorities.
2. Scope
Surveillance may cover orders, amendments, cancellations, executions, accounts, Clients, Trading Participants, Brokers, Market Makers, Issuers, Sponsors, Underwriters, Digital Securities, approved wallets, token transfers, settlement and other activity connected with IDSX.
3. Surveillance Principles
Surveillance is risk-based, proportionate, independent, confidential, timely, evidence-based, technology-neutral and directed to market integrity. An automated alert is an indicator for assessment, not proof of misconduct.
4. Surveillance Architecture
IDSX may combine real-time, near-real-time, end-of-day and historical review; account, beneficial-owner and cross-account analysis; blockchain and statistical analysis; behavioural analytics; rule-based, machine-learning or other automated tools; and manual investigation.
5. Data Sources
Sources may include order books, trades, timestamps, routing, Client and beneficial-owner identifiers, KYC, Broker and Participant information, wallets and blockchain transactions, settlement, Issuer disclosures, corporate actions, Market Maker quotes, sanctions and compliance information, public information and Participant submissions.
6. Identity-Based Surveillance
Where lawful, IDSX may associate activity with verified identity and analyse Client → Account → Beneficial Owner → Broker → Wallet → Order → Trade → Token Transfer relationships, revealing patterns not apparent from separate accounts or addresses.
7. Beneficial Ownership Analysis
IDSX may analyse accounts and wallets under common ownership or control, considering beneficial ownership, shared directors or operators, funding and withdrawal destinations, linked wallets, lawfully available device or technical indicators, coordinated orders and other evidence of common control.
8. Digital Security Activity
Digital Securities can generate exchange trading records and blockchain transfer records; IDSX may analyse both. Relevant activity includes exchange trades, deposits, withdrawals, wallet and off-market transfers, minting, burning, whitelisting, forced transfers, freezes and other administrative blockchain activity.
9. Real-Time Surveillance
During market operation IDSX may monitor sudden price or volume moves, order concentration, rapid entry and cancellation, disorderly conditions, abnormal spreads, deviations from recent prices, activity before announcements and potential manipulation. IDSX may intervene to maintain orderly trading.
10. Post-Trade Surveillance
Post-trade analysis may examine repeated or extended behaviour, account relationships, transaction sequences, profitability around material announcements, ownership transfers, blockchain movement after execution and recurring suspicious patterns.
11. Wash Trading
IDSX monitors transactions without meaningful beneficial-ownership change that create or may create a misleading appearance of trading activity, demand, liquidity, price formation or investor interest.
12. Self-Trading
Trading between accounts under common beneficial ownership may be reviewed but is not automatically prohibited if legitimate. Self-trading intended to create artificial volume, price movement or market appearance may be prohibited conduct.
13. Matched Orders
IDSX may monitor apparently coordinated orders by two or more persons in price, quantity, timing, security, execution pattern or beneficial ownership, and investigate orders designed to create a false or misleading market.
14. Spoofing
IDSX may investigate orders placed without genuine execution intent to mislead participants about supply, demand, available liquidity or likely price direction.
15. Layering
IDSX may monitor multiple price-level orders intended to mislead about depth or directional pressure, including repeated large orders away from intended execution, rapid cancellation after execution, recurring directional or asymmetric behaviour, and order-book pressure without genuine intent.
16. Quote Stuffing and Excessive Messaging
IDSX may monitor excessive order entry, amendment or cancellation. Where it disrupts systems, interferes with Participants, misleads the market or lacks legitimate purpose, IDSX may require corrective action.
17. Momentum Ignition
IDSX may investigate conduct apparently intended to trigger rapid price moves or induce directional trading, including aggressive sequential orders, coordinated trades, concentrated activity, misleading public communications and subsequent position reversal.
18. Marking the Open or Close
IDSX may review transactions near opening, closing or valuation times that appear intended to influence opening, closing or reference prices, portfolio valuations, indices or another benchmark.
19. Artificial Price Formation
IDSX may investigate activity apparently establishing or maintaining a price detached from genuine supply and demand, including related-party trades, artificial quotes, circular transactions, trades without apparent economic purpose, coordinated activity or improper Market Maker conduct.
20. Pump-and-Dump Activity
IDSX may investigate position accumulation followed by misleading promotion, coordinated buying, artificial appreciation, disposal into increased demand and a subsequent price collapse.
21. Short-and-Distort Activity
Where relevant, IDSX may investigate establishing a short or negative economic position, spreading materially false or misleading information, coordinated selling and benefiting from resulting price declines.
22. Insider Trading Surveillance
IDSX may monitor activity before or around earnings, capital raisings, acquisitions, disposals, mergers, control changes, major contracts, regulatory decisions, material litigation, dividends, insolvency events and other material disclosures. Unusual trading alone does not establish insider trading.
23. Material Non-Public Information
Where trading may involve material non-public information, IDSX may examine traders, beneficial ownership, Issuer and director/employee links, Sponsor, Underwriter and adviser relationships, timing, lawfully obtainable communications and other evidence.
24. Front-Running
IDSX may monitor a Broker, Participant, employee or related person trading before a Client order executes where confidential knowledge of that order may have been misused.
25. Improper Use of Client Orders
Do not misuse Client order information for improper advantage. Potential misconduct includes trading ahead, delaying orders, routing for improper benefit, misuse of aggregate Client demand or disclosure of confidential order information.
26. Market Maker Surveillance
IDSX may monitor quote obligations, minimum size, maximum spread, required presence, unusual liquidity withdrawal, coordinated quoting, artificial price support, related-party trading and conduct during volatility.
27. Sponsor and Underwriter Activity
Where appropriate, IDSX may review Sponsor, Underwriter and related-person trading around admission, capital raising, underwriting, placements, stabilisation, lock-up expiry and significant corporate actions.
28. New Listing Surveillance
New securities may receive enhanced surveillance due to limited history, concentrated ownership, low free float or liquidity, retail interest, Market Maker dependency, volatility or promotional activity.
29. Concentrated Ownership
IDSX may enhance monitoring where ownership is concentrated, considering risks of artificial scarcity, manipulation, related-party trading, limited liquidity, misleading volume and rapid price moves.
30. Low-Liquidity Securities
Limited trading may make small trades price-sensitive. IDSX may consider free float, average trade size, depth, spreads, active investors, Market Maker activity and ownership concentration.
31. Abnormal Volume
IDSX may review volume increases against historical averages, announcements and corporate events, investor concentration, public or social commentary, related-party activity and market conditions.
32. Abnormal Price Movement
Review may consider magnitude and speed, public information, order-book activity and depth, related securities, investor concentration and subsequent reversal.
33. Volatility Controls
IDSX may use price bands, volatility interruptions, temporary pauses, auctions, order rejection controls or manual intervention to manage extreme volatility.
34. Trading Halt Surveillance
Activity immediately before or after a halt may be reviewed, including whether a person traded while holding information relevant to the halt.
35. Cross-Market Activity
Where a security or related product trades elsewhere, IDSX may consider lawfully available external prices, volume, timing, announcements, related securities and other indicators.
36. Blockchain Transfer Surveillance
Where relevant, IDSX may review blockchain transfers before or after trading, between related wallets, around corporate events, following large price moves or during investigations.
37. Wallet Clustering
Analytics may identify wallets potentially under common control using transaction patterns, funding or withdrawal sources, contract interactions, timing, custody relationships and other technical indicators. Clustering is not conclusive proof of common ownership.
38. Off-Market Transfers
IDSX may review off-market transfers affecting beneficial ownership, concentration, free float, eligibility, potential manipulation, settlement or market integrity.
39. Circular Token Transfers
Repeated transfers among related wallets or accounts that return to an original holder may be reviewed for concealed ownership, false activity, disguised related-party trades or avoidance of restrictions.
40. Surveillance Alerts
Automated alerts may use thresholds, statistical deviations, behavioural patterns, relationship analysis, machine learning, blockchain analytics or manual referral. Assess each in context.
41. Alert Prioritisation
Prioritisation may consider potential harm, price impact, volume, recurrence, Participant involvement, insider relationships, connectivity, value, market sensitivity and regulatory significance.
42. Surveillance Review
Initial review may consider order and trade data, identity and beneficial ownership, wallets, market conditions, Issuer announcements and public information, account history and previous alerts.
43. Investigation
Unresolved alerts may lead to investigation, including trade reconstruction, relationship analysis, Participant enquiries, Client-information requests, blockchain tracing, announcement and related-trading review, interviews, internal records and other reasonable steps.
44. Requests for Information
IDSX may request relevant Client identity, beneficial ownership, onboarding, order instructions, communications, internal trading, wallet ownership, funding, routing, employee activity and other information.
45. Participant Cooperation
Participants must cooperate and must not knowingly conceal information, provide false information, destroy or alter records, delay responses without reasonable cause or interfere with investigations.
46. Escalation
Material concerns may be escalated to IDSX Compliance, senior management, internal enforcement, Issuers, relevant Brokers or Trading Participants, external experts, regulators or law enforcement as appropriate and lawful.
47. Interim Protective Measures
During review, IDSX may enhance monitoring; restrict accounts or Participants; cancel open orders; restrict trading or transfers or wallets; suspend trading or a security; or take other reasonable protective measures.
48. Trading Suspension
IDSX may suspend a security to maintain order, investigate activity, disseminate material information, address technical disruption or suspected manipulation or settlement risk, or protect investors.
49. Account Restrictions
As permitted by rules and law, IDSX may require no new purchases, sell-only status, withdrawal or transfer restrictions, enhanced approvals or temporary suspension for an account associated with suspicious or abusive activity.
50. Market Integrity Reviews
IDSX may conduct thematic or periodic reviews of Market Makers, new listings, illiquid securities, high-frequency activity, Digital Security transfers, Broker controls, insider-trading risk, routing or other themes.
51. Surveillance of Algorithmic Trading
Where automated trading is permitted, IDSX may monitor order frequency, cancellation ratios, message rates, repeated patterns, runaway algorithms, price impact, feedback loops and compliance with technical limits.
52. Erroneous Orders
IDSX may identify and review orders with abnormal prices or quantities, technical malfunctions, duplicates, incorrect instruments or other operational errors, and act under Trading Rules.
53. Trade Cancellation and Correction
Surveillance may prompt review whether a trade is maintained, corrected, cancelled or adjusted where Trading Rules permit. A surveillance finding does not automatically cancel a trade.
54. False or Misleading Statements
IDSX may investigate trading associated with apparently materially false or misleading statements from Issuers, directors, Participants, investors, promoters, social media or other public communications.
55. Social Media and Public Information
IDSX may consider Issuer announcements, news, websites, social media, forums and regulatory announcements, assessing reliability.
56. Confidentiality
Treat surveillance information and investigations as confidential. Disclosure is permitted where required by law or authority, needed for enforcement or market integrity, or otherwise permitted by IDSX Rules.
57. Independence
Surveillance personnel should be sufficiently independent from commercial functions. Commercial considerations must not improperly prevent alerts, investigations, escalation, restrictions or regulatory referral.
58. Conflicts of Interest
Apply appropriate conflict controls where surveillance concerns a Participant, Issuer or person materially connected with IDSX personnel.
59. Surveillance Records
IDSX must maintain appropriate alert, review, investigation, analytical, Participant-response, escalation, enforcement-referral and closure records.
60. Audit Trail
Surveillance systems should record alert generation time, supporting data, review actions, investigator decisions, escalation, closure and subsequent enforcement where applicable.
61. Model Governance
Automated or machine-learning tools should be governed through testing, validation, threshold calibration, false-positive review, false-negative assessment, version control, performance monitoring and human oversight.
62. No Sole Reliance on Automation
Automation does not replace judgement. Human review may consider commercial context, legitimate strategies, liquidity, Issuer events, Participant explanations and other circumstances.
63. Surveillance Calibration
Thresholds may reflect liquidity, volume, price, market capitalisation, ownership concentration, volatility, market age, investor composition and other relevant factors.
64. Small and Medium-Sized Issuers
Surveillance should distinguish, where reasonably possible, legitimate illiquidity and ordinary price discovery from manipulation in smaller issuers, whose securities may have lower liquidity and greater natural volatility. Low liquidity alone is not evidence of abuse.
65. Referrals from Participants
Participants may refer suspicious activity with enough information for assessment and must not knowingly make false or malicious referrals.
66. Whistleblower Information
IDSX may receive misconduct information from employees, investors or others. Assess independently; a report alone does not establish the facts.
67. Regulatory Cooperation
IDSX may provide information to competent authorities where required or permitted by law and relevant to suspected abuse, financial crime, investor protection or lawful cooperation.
68. Cross-Border Cooperation
IDSX may cooperate lawfully with overseas regulators or market operators where activity involves overseas Participants, investors or Issuers.
69. Relationship with AML Monitoring
Market surveillance may identify AML/CFT-relevant wash or circular trading, linked-wallet activity, unexplained transfers, unusual patterns or coordination. Escalate relevant information to the appropriate compliance function.
70. Relationship with Cybersecurity
Alerts may indicate account, credentials, API or wallet compromise, unauthorised algorithmic activity or another cyber event; escalate to relevant security personnel.
71. Market Maker Exceptions
Some apparently unusual conduct may reflect legitimate Market Maker activity, but Market Maker status is not an exemption from surveillance. Consider authorised obligations and strategies.
72. Corporate Action Periods
IDSX may enhance surveillance around dividends, rights, splits, mergers, tender offers, redemptions, token migrations and other material corporate actions.
73. Token Minting and Burning Surveillance
IDSX may monitor minting and burning against authorised securities, corporate actions, Issuer disclosures, registry records and Digital Securities Rules. Unauthorised supply changes may be escalated immediately.
74. Administrative Wallet Activity
IDSX may monitor privileged wallets able to mint, burn, freeze, force-transfer, administer contracts or change compliance status. Unusual activity may trigger immediate investigation.
75. Manipulation Through Off-Exchange Activity
Off-book conduct may be relevant when intended to influence IDSX prices. IDSX may consider off-market transfers, related-market trading, public communications, blockchain activity and other available evidence.
76. Surveillance Outcomes
Reviews may end with no action, continued monitoring, information requests, compliance guidance, account or Participant restrictions, trading suspension, enforcement or regulatory referral, or another action permitted by IDSX Rules.
77. No Presumption of Misconduct
An alert, investigation or information request creates no presumption of misconduct. IDSX assesses available evidence before reaching a conclusion.
78. Enforcement Referral
Evidence of a potential breach may be referred for action under applicable IDSX Enforcement Rules.
79. Participant Responsibilities
Participants must maintain monitoring required by law or IDSX Rules. Exchange surveillance does not replace Broker or Trading Participant supervision, Market Maker controls, AML monitoring, Issuer systems or other Participant duties.
80. Continuous Improvement
IDSX may improve surveillance as markets grow, products and strategies change, technology and regulation develop, manipulation techniques emerge, Digital Securities evolve or investigations identify lessons.
81. Surveillance Testing
IDSX may test systems through scenarios, alerts, threshold and data-quality reviews, historical replay, model validation and review of missed or known incidents.
82. Data Quality
Effective surveillance depends on complete, accurate data. Participants must provide data required by IDSX Rules and promptly correct material errors.
83. System Resilience
IDSX must maintain reasonable arrangements to preserve surveillance during outages, trading-system failure, cyber incidents, data-feed interruptions and other material operational events.
84. Access Control
Restrict surveillance-system and investigation access appropriately, using controls such as role-based access, authentication, audit logs, segregation of duties and privileged-access monitoring.
85. Surveillance Personnel
Surveillance personnel must receive role-appropriate training in market abuse, order books, Digital Securities, blockchain analysis, insider trading, algorithms, investigations, AML indicators and IDSX Rules.
86. External Specialists
IDSX may engage forensic accountants, blockchain analytics providers, cybersecurity specialists, lawyers, data scientists and other experts to support surveillance or investigations.
87. Surveillance Framework Is Not Exhaustive
Abuse techniques evolve. IDSX may investigate conduct not expressly listed, considering its substance and purpose.
88. Relationship with Other IDSX Rules
Read this Framework with the IDSX General, Trading, Market Conduct, Broker, Market Maker, KYC / AML, Digital Securities and Enforcement Rules and other applicable requirements.
89. Amendments
IDSX may amend this Framework to reflect market, regulatory, surveillance, technology, product, manipulation-technique or market-structure developments.
90. Effective Date
This Framework takes effect on the date determined and published by IDSX.
IDSX · Market Surveillance Framework — Version 1.0