Conflict of interest register: stages and deadlines
A conflict of interest register during token issuance moves through four stages: identification, disclosure, review by the governing body, and periodic re-assessment. There is no fixed statutory clock for each stage. The practical deadline is set by the issuance timetable itself — a conflict left unresolved becomes the point at which the offering cannot proceed to the next milestone.
What triggers an entry
An entry is triggered whenever a person involved in the issuance — a director, a controlling shareholder, an adviser, or a service provider — has an interest that could compete with the interest of prospective token holders. Common triggers include a founder holding tokens on preferential terms, an adviser also acting for a competing project, or a custody provider owned by the same group as the issuer. Each of these needs a written entry before work on the affected task continues.
The register itself is a working document, not a formality filed once and forgotten. It is updated every time a new interest appears, and closed entries are kept, not deleted, so a reviewer can see how a conflict was resolved and when.
Stages in practice
| Stage | Who acts | Typical timing |
|---|---|---|
| Identification | Person with the interest, or compliance function on discovery | Before the related task starts, or immediately on discovery |
| Written disclosure | Person with the interest | Within days of identification, not after the decision is taken |
| Review and classification | Compliance officer or equivalent function | Before the next governance meeting |
| Decision on mitigation | Governing body (board or equivalent) | At the first meeting where the item can be tabled |
| Periodic re-assessment | Compliance function | At each material change and at fixed intervals set internally |
The gap between disclosure and decision is where most delay accumulates. If the governing body cannot meet quickly, the conflicted task is paused rather than left to proceed under an unresolved entry.
What to do
- List every person with a decision-making or advisory role in the issuance, and note their other interests.
- Ask each person to confirm in writing whether any interest could conflict with the issuance or with token holders.
- Record every disclosure in the register with the date, the parties involved, and the task affected.
- Route each entry to the compliance function for classification as material or immaterial.
- Bring material entries to the governing body for a documented decision — recuse, mitigate, or proceed with disclosure.
- Set a date for the next review of the entry and keep the closed record on file.
Who decides and by when
Classification is normally done by the compliance function or the person carrying that responsibility in a smaller team. The decision on how to handle a material conflict — recusal, restructuring the task, or proceeding with enhanced disclosure — sits with the governing body, not with the conflicted individual. There is no external filing deadline for the register itself; the working deadline is the next point in the issuance timetable that depends on the conflicted task.
If your situation differs
- If the conflict involves a member of senior management, the decision is taken by the remaining members of the governing body, with the conflicted member recorded as recused.
- If the conflict surfaces after a decision has already been taken, the entry is still made, backdated to the date the interest arose, with a note on when it was discovered.
- If a third-party service provider raises the conflict rather than the issuer, the disclosure is logged the same way, and the provider's own register entry is requested for cross-reference.
Related publications
The same staged approach applies to arrangements around asset custody: Custody arrangement review step by step sets out the equivalent sequence for that file.
Sources and limit
This page does not set out the exact register format expected by every national competent authority, and it does not cover conflicts arising after the tokens are already trading — that sits under a separate ongoing-compliance file. Where a related check needs a report rather than a procedure, the relevant starting point is elsewhere.
If the open question is about a counterparty rather than an internal conflict, see Counterparty report before extending credit.
If a disclosed document itself needs checking before it is relied on, see Document report before relying on it in a dispute.
If the register in question sits in a jurisdiction your team does not normally work with, see Jurisdiction report when a register is unfamiliar.
This page was reviewed for accuracy on 2025-06-01, against our internal file-handling methodology rather than a single external source. The file for a given issuance is built by the in-house team; if you are curious how that team is put together, see How the team hires.
FAQ
How long does the conflict of interest register take in practice?
Identification and disclosure usually take days. The bottleneck is the governing body's next available meeting, which sets the real timeline for a material entry.
Which documents are needed to start?
A list of the people involved in the issuance, a short written disclosure from each on outside interests, and the register template itself, which should already exist before the first disclosure arrives.
What happens if the disclosed party does not respond to a conflict notice?
The task affected by the possible conflict is paused. The compliance function logs the non-response with a date, and the governing body decides whether to proceed without confirmation or to remove the person from the task.