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Initial token issuer of the VOW token.
VOW LIMITED, Jersey Company Registration Number 131911, was registered on 16/07/2020.
It was tasked with the initial deployment and distribution of $VOW tokens.
It was granted the authority to legally commence operations and distribute the tokens through a consent issued under the Control of Borrowing (Jersey) Order, 1958 ("COBO") from the JFSC. This allowed it to kickstart the Vow Ecosystem.
The Jersey Financial Services Commission is protected by the Control of Borrowing (Jersey) Law 1947, as amended, against liability arising from the discharge of its function under that Law.
By July 2023 VOW LIMITED had achieved its initial goals of professionally distributing the entirety of minted VOW assets. VOW tokens are now held by well over 12,000 community members around the world.
All initial subscribers to the VOW token sale hold an asset with more utility value than the day they purchased it - an asset that can be immediately used at, and by, thousands of businesses around the world.
In achieving these goals, VOW LIMITED and its management, have successfully ensured that the VOW token is decentralized in its use by attracting a wide network of independent market participants - companies committed to using and consuming VOW tokens.
In addition, VOW LIMITED has ensured sufficient liquidity for the token to flourish on Ce-fi and De-fi markets. It has also gathered a large community who consume and utilize the currency throughout the world, thousands of social media followers, and a good reputation.
In achieving these objectives VOW LIMITED is no longer necessary for promoting or maintaining the ecosystem any longer.
Vow Limited does not provide any investment advice, make any investment recommendations or opine on the merits of any transaction in connection with the VOW token. You are wholly responsible for ensuring that all aspects of the investment in the VOW token are acceptable to you and if in any doubt you should seek appropriate professional advice. Investment in the VOW token may involve special risks that could lead to a loss of all or a substantial portion of such investment. Unless you fully understand and accept the nature of and the potential risks inherent to an investment in the VOW token you should not invest in the VOW token.
Jersey Treatment of Vow Limited (the "issuer")
There are currently no existing capital markets regulations in Jersey specifically governing initial coin offerings ("ICOs") which are a highly speculative form of investment. However, the Jersey Financial Services Commission (the "JFSC") is aware of the desire of ICO promoters to use a Jersey incorporated issuer because of Jersey's reputation as a well-regulated and reputable jurisdiction.
Accordingly, the JFSC has established certain conditions that any issuer of an ICO registered in Jersey is required to satisfy. These are implemented through a consent (a COBO Consent), which any Jersey entity wishing to issue an ICO must obtain.
The conditions require the issuer of the ICO to take certain measures to manage, amongst other things, financial crime and investor risks. The conditions reflect the guiding principles pursuant to which the JFSC discharges its functions as the Island's financial services regulator (the "Guiding Principles") which are to have regard to:
- the reduction of the risk to the public of financial loss due to dishonesty, incompetence, malpractice or the financial unsoundness of financial service providers;
- the protection and enhancement of Jersey's reputation and integrity in commercial and financial matters;
- the best economic interests of Jersey; and
- the need to counter financial crime both in Jersey and elsewhere.
However, whilst the JFSC has established certain conditions that issuers of ICOs are required to satisfy, it does not regulate or supervise the ICOs or the issuers.
The COBO Consent imposes on the issuer certain requirements which reflect the Guiding Principles, including to:
acknowledge that ICOs are a "sensitive activity" falling within the JFSC's Sound Business Practice Policy. Accordingly, the issuer must maintain and adopt systems, controls, policies and procedures for the customer take-on, profiling and transaction monitoring at enhanced levels ensuring reporting of suspicions of money-laundering and financing of terrorism activity;
apply relevant AML/CFT requirements to persons that either purchase tokens from, or sell tokens back to, the issuer of those tokens;
- appoint and maintain a Trust Company Service Provider ("TCSP");
- appoint and maintain a Jersey resident director on the board of the issuer; where the Jersey resident director is a natural person and also a principal person of TCSP appointed by the issuer;
- obtain the JFSC's prior approval to any change to the TCSP appointed by the issuer , the Jersey resident director of the issuer or additional specified counterparties of the issuer as set out in the COBO consent;
- prepare and file annual audited accounts with the Jersey Companies Registry;
- have procedures and processes in place to (i) mitigate and manage the risk of retail investors investing inappropriately in the ICO, and (ii) to ensure retail investors understand the risks involved;
- prepare and submit to the JFSC an Information Memorandum (which may be in the form of a White Paper) which complies with certain content requirements required of a prospectus issued by a company under the Companies (Jersey) Law 1991; and
- ensure that any marketing material (including the information memorandum relating to the ICO) is clear, fair and not misleading.