Public Disclosures

We, at Koshayojan Services DMCC, operate the SMART, a prominent virtual asset exchange platform specializing in the listing of tokenized Real-World Assets. Our unwavering commitment to adhering to the highest standards of regulatory compliance within the virtual asset ecosystem is paramount to us. We deeply understand the critical importance of safeguarding the interests of our esteemed customers. It is with this unwavering dedication that we have implemented comprehensive processes and procedures meticulously designed to align with the exacting Virtual Asset (VA) Standards as prescribed by the Virtual Assets Regulatory Authority (VARA).

Our primary focus is on preserving transparency, security, and trust within the virtual asset landscape. To achieve this, we have instituted robust measures that not only meet but exceed the regulatory requirements laid out by the VARA. These encompass a wide spectrum of factors, including but not limited to, rigorous customer due diligence, robust anti-money laundering (AML) protocols, thorough know-your-customer (KYC) procedures, vigilant transaction monitoring, and effective reporting mechanisms.

We firmly believe that our strict adherence to the VARA's VA Standards not only fortifies the integrity of our platform but also establishes a commendable benchmark for the industry as a whole. By steadfastly adhering to these standards, we aspire to contribute to the long-term sustainability and legitimacy of the virtual asset ecosystem.

CONFLICT OF INTEREST:

Koshayojan Services DMCC is committed to upholding transparency, fairness, and the highest standards of corporate governance in all our endeavors through our Conflict-of-Interest Policy. Our policy underscores our dedication to safeguarding the interests of our stakeholders, including shareholders, employees, vendors, clients and users.

We address conflicts of interest comprehensively, recognizing situations where personal interests may intersect with professional obligations. A robust framework has been established for the identification, documentation, management, and mitigation of such conflicts, fostering ethical behavior and prudent decision-making.

Our Associates are guided by a set of principles that prioritize the Koshayojan and its subject’s best interests. They are expected to comply with local laws, internal policies, and employment agreements, ensuring that personal interests do not compromise their professional responsibilities. In addition, stringent measures have been put in place to prevent any improper influence or undue advantage in transactions conducted on our platform.

For further information, please refer to our detailed Conflict of Interest Policy [download]

WHISTLEBLOWING:
We dedicated to formulating a comprehensive framework for safeguarding whistleblowers, guaranteeing that no individual who has disclosed information will:

  • Incur civil or contractual liabilities.
  • Face termination from their current employment, or encounter any other measures taken by their employer (or its affiliates) that could reasonably lead to their detriment.

Koshayojan's Corporate Information disclosures:

  • Koshayojan Services, DMCC incorporated under the Laws of Dubai and having its License number- [*]
  • Koshayojan DMCC has obtained in-principal approval for setting up Virtual Asset Exchange from VARA.
  • Koshayojan will list out all Virtual Assets activities that are licensed by VARA to carry out in the Emirate [including any restrictions stated by VARA as condition their license].
Koshayojan officers in charge and their contact information:
Mr. Naveen Sachdeva - CBDO
naveen.sachdeva@mai.io
Mr. Mohit Bajaj - CFO
mohit.bajaj@mai.io

GRIEVANCE REDRESSAL:
At Koshayojan DMCC, we have implemented a robust and user-friendly system for receiving and addressing any concerns or feedback from our valued platform users. We understand the importance of transparent communication and take all complaints seriously. To ensure a seamless process, we have set up a dedicated Grievance Redressal Portal, which can be accessed at compliance@smartdubai.io. Through this portal, users can easily submit their reports or complaints, allowing us to promptly investigate and resolve any issues that may arise.

We are committed to continuously improving our services and appreciate the trust our users place in us. Rest assured, all complaints received will be treated with utmost confidentiality and diligence in accordance with the Complaints Handling Procedures detailed in Market Conduct Rule Book of VARA. For more information, please refer to VARA Market Conduct Rule Book- Rule III A & B. [download]

For further details, please refer to SMART market conduct rulebook [download].

SMART EXCHNANGE LICENSE:
We are delighted to inform you that Koshayojan is currently in the process of obtaining a license for Virtual Assets Exchange Services, under the regulation of VARA in Dubai. VARA, a distinguished regulatory authority in Dubai, has recently unveiled the Virtual Assets and Related Activities Regulations for 2023. These regulations provide a comprehensive framework for Virtual Assets (VAs), underpinned by principles of economic stability and global financial security. [download]
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Further, we want to assure our customers onboarding the exchange that we are fully committed to adhering to these regulations and upholding the highest standards of integrity and compliance in all our operations. This step underscores our dedication to providing a secure and trustworthy platform for virtual asset transactions in accordance with VARA guidelines.

KOSHAYOJAN’S COMMITMENT TO VIRTUAL ASSET STANDARDS:
In compliance with the Virtual Asset (VA) Standards set forth by the Virtual Assets Regulatory Authority (VARA), we would like to provide you with a summary of key considerations we undertake in relation to all Virtual Assets:

  • Market Analysis: This includes metrics such as market capitalization, fully diluted value, and liquidity, with a focus on trends over time.
  • Design and Use Cases: We assess the design, features, and potential use cases of the Virtual Asset, irrespective of the original intentions of the Issuer or developers. 
  • Regulatory Compliance: We ensure adherence to applicable laws, Regulations, Rules, or Directives, encompassing AML/CFT, sanctions, securities, and intellectual property. 
  • Regulatory Approvals: We verify whether the issuance of the Virtual Asset has received regulatory approvals from VARA and other pertinent authorities. 
  • Prohibitions: We confirm if the Virtual Asset is prohibited by VARA or any other relevant authorities, both within and outside the UAE, in jurisdictions where we provide VA Activities.
  • DLT Protocol Security: We evaluate the security and immutability of the underlying DLT protocol. 
  • Future Development: We consider the communicated development roadmap provided by the Issuer and/or relevant developers. 
  • Price Manipulation: We assess susceptibility to price manipulation and implement relevant mitigations.
  • Periodic Review: We regularly review Virtual Asset terms and conditions to ensure conformity with standards and practices in the relevant physical market, if applicable.

Currently Koshayojan does not have any live Virtual Asset offered in the market regulated by VARA.As a part of our commitment to transparency and regulatory compliance. Here's key information on each Virtual Asset we will offer:

  • Name and Symbol.
  • Date of Issuance.
  • Market Capitalization and Fully Diluted Value.
  • Circulating Supply (as a percentage of maximum total supply, if applicable).
  • Smart Contract Audit Status and Date.
  • Largest Price Fluctuation (in both absolute amount and percentage change) and Date.

For more information, please download Exchange Policy of VARA [Rule II.B.1]

Securing and Respecting Client Ownership: Virtual Asset Protection Mechanisms
SMART employs a sophisticated key management system emphasizing utmost security and user privacy through:
  • Private Key Creation
  • Private Key Security
  • may not be liquid;
  • CSR and Identity Verification
Ensuring Privacy and Control
The combination of certificate issuance and client-side transaction signing (including key generation and storage) offers users an unparalleled level of privacy and control. Users are assured that their transactions and identities are secure and protected from possible compromises. This system significantly mitigates the risk of identity theft or fraudulent transactions, making it a robust security solution for our blockchain ecosystem.
Guarantees Provided
The governance layer's system of certificate issuance and client-side transaction signing provides strong security guarantees. It assures the authenticity of users' identities linked to their public keys, validated by the digitally signed certificates from the governance layer. The public keys are also linked to their KYCed identities fulfilling our promise of a regulated ecosystem maintaining privacy and security.

By enabling client-side transaction signing, the system provides strong privacy guarantees, ensuring that private keys never leave the user's device. This setup also allows users to have control over their transactions, ensuring that only they can authorise and submit transactions to the network.
User Control and Privacy:
  • Self-Custody: Users have complete control over their private keys, meaning they fully own and control their assets.
  • No Personal Data Collection: The extension operates with minimal user data, enhancing user privacy.
Easy Integration:
  • Seamless Blockchain Interaction: Simplifies the process of interacting with Kalptantra blockchain networks and managing transactions.
  • Compatibility: Works efficiently across various browsers, ensuring a broad user base can securely access their assets.
Virtual Asset Pricing Mechanism: Ensuring Transparency and Accuracy
We've established robust operational benchmarks to evaluate underlying asset quality and mitigate associated risks. This entails thorough scrutiny by credible third-party partners, encompassing financial, legal, and technical due diligence before listing. Additionally, reputable global IPCs are mandated to provide inline valuations. Further, the asset price is market-driven in the secondary market.
Screening
  • Prioritizing and ranking of prospective assets through a quantitative screening framework featuring various checkpoints.
  • Only a Selected Few Properties to Pass the Exhaustive Due Diligence And Valuation Process.
  • We estimated less than 2% success rate
Valuations
  • Third-party independent valuation of the asset or business for the listing company /firm.
  • Mandating a detailed valuation report to provide an accurate assessment of the asset's worth.
  • Customized techniques tailored to the specific nature of the asset being tokenized.
  • These reports encompass a meticulous analysis of the asset's market value, taking into account factors such as location, condition, comparables, and market trends.
Technical Due diligence
  • In-depth examination of the current market conditions and trends.
  • Performance benchmarking and recent sale transactions
Financial due diligence
  • Thorough examination of the asset's financial health.
  • Review of financial statements, tax returns, expenses, tax exposure, and evaluate tax attributes for the listing company/firm.
  • Verification of revenue streams and financial projections.
Tax advisory
  • Evaluate corporate tax
  • Indirect tax and regulatory implications.
Legal Due Diligence
  • Scrutiny by legal experts to ensure compliance with regulatory requirement.
  • Examination of contracts, agreements, and legal documentation related to the asset.
  • Identification and mitigation of any legal risks associated with the asset.
Risk assessment
  • Assess risk profile of the asset
  • Lease worthiness/marketability, tenant stickiness, market dynamics, process risks.

VIRTUAL ASSET - RISK DISCLOUSRE STATEMENTS:
VASPs shall publish a detailed description of all material risks associated with Virtual Assets, including but not limited to a specific statement that Virtual Assets:
  • may lose their value in part or in full and are subject to extreme volatility at times;
  • may not always be transferable and some transfers may be irreversible;
  • may not be liquid;
  • some transactions are not private and may be recorded on public DLTs; and
  • Smart Contract Audit Status and Date.
  • may be subject to fraud, manipulation, theft, including through hacks and other targeted schemes and may not benefit from legal protections.
ADDITIONAL DISCLOSURES:
  • We affirm that neither the Board Members nor Senior Managers possess any prior convictions or prosecutions in UAE courts or any other jurisdictions.
  • Koshayojan banking partner in Dubai {*}

    For any further information regarding the Public Disclosure, feel free to reach out to us at compliance@smartdubai.io