Zerion Inc. (“Zerion”) provides a self-custodial wallet interface (the “Interface”) that enables users to interact with decentralized protocols and distributed ledger trading systems using their own self-custodial wallets. Zerion is not registered with or regulated by the U.S. Securities and Exchange Commission (“SEC”) as a broker-dealer in connection with the creation, offering, or operation of the Interface.
This Policy describes how Zerion evaluates, onboards, and audits the trading venues and distributed ledger trading systems (“Venues”) to which the Interface connects. This Policy is maintained in accordance with the SEC Division of Trading and Markets Staff Statement dated April 13, 2026 (File No. 4-894).
This Policy applies to all Venues to which the Zerion Interface connects or interacts for the purpose of facilitating user-initiated crypto asset transactions, including:
Zerion evaluates each Venue against the following objective criteria before connecting it to the Interface. These same criteria are used during periodic audits of existing Venues.
Zerion assesses each Venue’s capacity to support user transactions at reasonable price levels, including available liquidity depth, historical trading volume, concentration of liquidity providers, and availability across chains supported by the Interface.
Zerion evaluates transaction processing speed and quote freshness, including response times for quote requests, block confirmation times on the Venue’s underlying chain(s), and historical uptime.
Zerion assesses the extent to which the Venue’s operations and fee structures are publicly documented and understandable, including the availability of public documentation of protocol mechanics, fee structures, and governance, and whether core smart contracts are open-source.
Zerion evaluates whether the Venue’s operations can be independently verified, including whether smart contract code is publicly available and verified on block explorers, whether third-party smart contract audits have been conducted, and whether transaction execution, pricing, and fee deductions are verifiable on-chain.
Zerion assesses whether the Venue treats all participants and connected interfaces on equal and non-discriminatory terms, including the absence of preferential treatment for specific participants and the governance structure and concentration of control over the protocol.
Zerion evaluates the Venue’s capacity to support oversight and post-trade analysis, including the availability of comprehensive on-chain transaction records and any off-chain logging or reporting capabilities.
Zerion assesses the Venue’s security posture and track record, including the history of exploits or loss-of-funds incidents, smart contract audit history and remediation of findings, availability and scope of a bug bounty program, access control mechanisms and upgrade key management, and any MEV protection measures implemented at the protocol level.
Before a new Venue is connected to the Interface, Zerion conducts the following due diligence:
Zerion reviews the Venue’s smart contract code and architecture, assesses available audit reports (including the identity of auditors, scope of audits, severity of findings, and remediation status), reviews upgrade mechanisms and administrative key management, and evaluates oracle dependencies and price feed reliability where applicable.
Zerion evaluates the Venue against each of the criteria described in Section 3 of this Policy. A Venue must meet Zerion’s minimum standards across all seven criteria to be approved for connection.
Zerion determines whether a proposed Venue is an Affiliated Venue. If a Venue is affiliated with Zerion, the affiliation is disclosed to users and the Venue is connected on the same terms and conditions as unaffiliated Venues.
Zerion reviews each proposed Venue integration for conflicts of interest, including any revenue-sharing, referral, or incentive arrangements between Zerion and the Venue, and any financial interests held by Zerion in the Venue or its governance token. Identified conflicts are addressed before the Venue is connected.
Zerion monitors connected Venues on an ongoing basis, including monitoring for smart contract upgrades or changes, security incident disclosures, material changes in liquidity, and governance proposals that could materially affect the Venue’s operations, fee structure, or security posture.
Each connected Venue is subject to periodic audit, during which Zerion reassesses the Venue against the evaluation criteria in Section 3, reviews the Venue’s incident history since the prior audit, verifies that any identified conflicts of interest remain adequately addressed, and confirms that user-facing disclosures remain accurate. For Affiliated Venues, Zerion additionally verifies that the Venue continues to be connected on the same terms as unaffiliated Venues.
If Zerion identifies a material concern affecting a connected Venue — such as a security incident, unresolved exploit, material governance change, or failure to meet Zerion’s evaluation criteria — Zerion may suspend or permanently remove the Venue from the Interface.
The following events trigger a reassessment of a connected Venue outside the regular audit cycle:
Contact
For questions about this Policy, please contact [email protected].
