Secondary market arrangement: what the decision maker looks at
When a token moves from issuance to secondary trading, one person or committee decides whether the file is ready. The decision maker checks three things: completeness of the token file, the outcome of counterparty checks, and whether internal sign-offs are in place. Nothing else sets the date.
What changes once the arrangement starts
Once the arrangement is opened, the clock runs on two fronts. First, internal readiness: does the file contain everything the decision maker needs to say yes or no. Second, counterparty readiness: has the other side answered the checks sent to it. A gap on either front does not stop the arrangement, but it does stop the date moving forward. The practical effect is a queue, not a refusal.
Risk sits in the same place as timing. An incomplete file is reviewed slower, and a slower review means the token sits in a holding state longer than planned. This is the most common cause of delay we see, well ahead of anything to do with the token itself.
Stages, in order
| Stage | What is reviewed | Typical duration | Who signs off |
|---|---|---|---|
| Intake | Token file completeness, prior issuance records | 1–2 business days | Compliance officer |
| Counterparty check | Identity, ownership structure, adverse findings | 2–4 business days | Legal counsel |
| Internal sign-off | Risk assessment, readiness for listing | 1 business day | Decision maker (officer or committee) |
| Point of no return | Final confirmation, no further changes accepted | same day | Head of trading operations |
These durations describe our own practice. They are not fixed by any external deadline, and a file with cross-border elements usually sits at the upper end of each range.
What to do
- The person opening the arrangement submits the token file to the compliance officer, complete or not.
- The compliance officer flags missing items within one business day and returns the file if it is not ready.
- Legal counsel sends counterparty checks as soon as the file is accepted, not after it is complete.
- Whoever holds the file keeps a copy and the extracts received, following the same discipline described in Retention: the report, the extracts and our copy step.
- The decision maker reviews the assembled file and either signs off or sends it back with a specific reason.
- Once signed off, the head of trading operations confirms the date and closes the window for changes.
Who decides, and how long it takes
The decision maker is named at the start of the arrangement, not chosen afterwards. For most files this is a single compliance officer; for larger or cross-border files it is a small internal committee. The forum is internal, not a court or a regulator, and there is no external appeal against a hold. A typical file clears intake to sign-off within five to seven business days if nothing is outstanding. A file with an unresponsive counterparty extends without a fixed ceiling, because the review cannot close on an incomplete check.
Common scenarios
If the token has already been through issuance with us, then the file is largely pre-populated and intake is short. If the token is new to us but the issuer is known, then intake takes longer but the counterparty check is faster. If both the token and the counterparty are new, then expect the full sequence above, with no stage shortened.
If the counterparty does not respond within the check window, then the arrangement is paused, not cancelled. The decision maker either extends the window once or asks the requesting party whether to proceed without that counterparty. If the file arrives incomplete and stays incomplete after one return, then the arrangement is closed and must be reopened as a fresh file.
What this page does not cover
This page describes the internal sequence and who signs off on it. It does not set out what a counterparty report can or cannot establish; that scope is fixed at the level of the report itself, not the arrangement around it. For a worked example of what a finished file looks like, see Sample counterparty report, as delivered.
It also does not cover what can be confirmed once documents sit in a specific country. That depends on the register queried and the document type, which is described separately for Document in Estonia.
Nor does it cover what a jurisdiction check can establish once the counterparty sits there. That scope is set out on its own page, for example Jurisdiction in Latvia.
Verified
This page reflects the internal procedure as we currently apply it, not a statutory timetable. We review the sequence each quarter and update the stage table if durations change. No external source is cited because none governs an internal arrangement decision of this kind.
Related reading
The nearest procedure to this one covers what happens after the arrangement, when trading is paused rather than started: Suspension of an offer step by step.
Frequently asked questions
How long does secondary market arrangement take in practice?
A clean file with a responsive counterparty clears in five to seven business days. Missing items or an unresponsive counterparty extend this without a fixed ceiling, because the review cannot close until the outstanding item is resolved.
Which documents are needed to start?
Intake needs the token file itself and, where the token was issued through us, the prior issuance record. Everything else, including counterparty checks, is requested after intake, not before.
What happens if the other side does not respond?
The arrangement is paused, not cancelled. The decision maker either extends the check window once or asks whether to proceed without that counterparty. Silence beyond the extended window closes the file.