INVESTMENT EVALUATION OF ICO PROJECT

Transcription

1 INVESTMENT EVALUATION OF ICO PROJECT Project info ingotcoin.io Pre-ICO: Инвестиционная оценка ICO проекта DREAMTEAM Investment attractiveness AVERAGE SCORE HIGH Quality Rate 5.3 / 7.0

2 LIMITATION OF LIABILITY 2 This information may be distributed in any way or in any form without prior consent of DigRate but with links to This evaluation expresses the views of DigRate and does not constitute a statement of fact or recommendation to buy, hold, or sell these or any other assets, or make investment decisions. DigRate assumes no responsibility for any consequences, interpretations, conclusions, recommendations or other actions directly or indirectly related to the evaluation performed by DigRate, or the observations and conclusions contained in the ratings report and press releases, or the absence of any of the above. Current valuations and recommendations can only be found on the official website The evaluation is only a reflection of DigRate s review of the documents and other resources available as of the time of the publishing of this report. Any updates and/or changes to the documents following the date of the publication of this document are not considered in the evaluation. The DigRate team expresses its respect to all enthusiasts of the cryptocurrency world. The legal opinion was prepared by NewLawyers.

3 CONTENTS 3 OFFICIAL INFORMATION 4 INVESTMENT EVALUATION 5 RECOMMENDATIONS 10 Project Concept 12 Business Model 21 The Tech 24 Tokens 28 Legal Documentation 32 Legal Opinion 35 Media Environment 44 Team 49 Project Support 53

4 OFFICIAL INFORMATION 4 IINGOT seeks to be a pioneer in the financial industry providing innovative techniques and solutions to link global markets with global market participants. The INGOT team is working to create an integrated solution for combining cryptocurrency and traditional financial markets. The Ingot ecosystem will consist of a crypto exchange (the key product of the system, which will enable to trade fiat currencies as well as cryptocurrencies and traditional financial instruments), a cold wallet, a broker-service, a digital bank, a liquidity aggregator (integrated with top world exchanges), and an educational portal. As technology progressed, the global markets and their efficiency progressed along, providing investors with more opportunities. INGOT continuously works on providing all stakeholders an ever-growing broad range of innovative products and services globally, thus allowing it to gain sufficient expertise to link this knowledge to the new blockchain environment and create an all-inclusive and self-serving Ecosystem. INGOT Group provides through its entity INGOT Brokers, a wide variety of products and services which includes ETFs, international shares and indices, commodities, metals, energies, as well as currencies. INGOT Group additionally serves as a member of Global Alliance Partners (GAP), which is an international network of regulated financial services companies that focuses on the mid capital market. GAP s international reach gives its member firms greater clout and a wider platform to conduct investment banking, wealth and fund management, broking, and other financial services across international markets.

5 INVESTMENT EVALUATION Conclusion 5 The Ingot project team plans to create an integrated investment platform that will unite financial instruments and will be able to bridge the gap between traditional financial, stock and cryptocurrency markets. The concept and tools proposed by the developers are Medium-to-high probability of long-term investment return, the level of project development potential is above average. necessary for the further development of the entire cryptocurrency market, according to them, and in the case of a full-fledged implementation of the business model, they could make the cryptocurrency market more convenient and easily accessible. The project team presented a detailed roadmap, outlined the profitability targets for the next 3 years, as well as implementation costs (justifying the collection of investments). A detailed business model and commissions, which will be charged for the Ingot services are also provided. In addition, the project itself was created by the founders and managers of the Ingot Group and Sigma Investment LTD, these companies have already proved themselves in the global financial market. All of the above facts leave no doubt about developers serious intentions and their possibilities of implementing all plans.

6 INVESTMENT EVALUATION Conclusion 6 To unite the classic stock, fiat and cryptocurrency market, the project team offers the following system of interaction. All cryptocurrencies will be assessed against the IC token, and IC, in turn, will be the only asset that will get permission to trade against fiat currencies. Medium-to-high probability of long-term investment return, the level of project development potential is above average. Thus, technically, for the trade of any cryptocurrency asset against the currency, for example BTC / USD, the transaction will be divided into two transactions - BTC / IC and IC / USD. The same principle will be applied to trade with traditional assets. Let's say that BTC will trade against Apple shares. The transaction will be divided into 3 transactions - BTC / IC, IC / USD, USD / AAPL. This solution is really innovative for the cryptocurrency market and will allow the company to achieve its goals without violating the modern legislative framework. Despite the high competence of the team, some aspects still raise questions.

7 INVESTMENT EVALUATION Conclusion 7 For example, the legal nature of the IC token, which has features of a security, is not defined. Only cryptocurrency exchanges are examined in detail within the analysis of the competitive environment, other services are paid little attention, although hundreds of Medium-to-high probability of long-term investment return, the level of project development potential is above average. exchanges, dozens of digital banks, wallets, broker-services and training centers accumulating most of the trades have already been established on the market and offer similar to Ingot s tools. These are crypto exchanges with fiat currencies - Kraken, Bitfinex, the stock exchange aggregating liquidity - B2BX, digital bank - Datrius, integrated solutions - United Traders, BeEsy. There are also many broker-services on the market - Exante, Coinbase, FXTM, Forex4you, etc. Competitors are likely to be able to increase volumes and modify their products / services in accordance with market needs, by the time the project succeeds in releasing a full ecosystem in 2021.

8 INVESTMENT EVALUATION Conclusion Medium-to-high probability of long-term investment return, the level of project development potential is above average. 8 Nevertheless, there are no integrated systems on the market that could offer users the fullest range of financial services with cryptocurrencies, fiat currency and traditional assets. Ingot s solution is still unique. In addition, the Ingot project is supported by an international holding company with a 20-year history. However, given that the prototypes of the platform products have not been developed yet, and the legislation on regulation of activities on the aggregate cryptocurrency and traditional financial market is not available, a stable and rapid development of the Ingot project can be jeopardized.

9 9 QUALITY RATE How do we evaluate the Quality Rate? ADVANTAGES HIGH Quality Rate The team understands real market problems and offers their solutions. The project team members have extensive experience in the in the financial field. The founders of the project are known in professional circles. There is a clear roadmap. The team cooperates with major well-known companies. The project participants have a clear motivation for owning the tokens The project succeeded in attracting experienced advisers. DISADVANTAGES There is no product prototype. Smart contract code for token sale, a protocol and smart contract for the platform are not published on GitHub. The legal nature of the IC token is the basis for classifying the project's token as a non-documentary security. The measures to stabilize the exchange rate of the IC token are not sufficiently thought out. The potential legal risks that the project may face are not well thought out.

10 10 RECOMMENDATIONS What can be improved? Publish a detailed analysis of the competitive environment. Work out a strategy and mechanism for maintaining the IC token's exchange rate at a stable level. Denote a set of financial tools that will be offered to users. Publish a smart contract for ICO and conduct security audits. Work out possible factors of regulatory and legal risks of the project. Conduct and publish the results of Howey Test. Think about how the project will attract the audience and compete with similar products that are already in the market. Create and submit a prototype of the first ecosystem product (IC Wallet), then expand the platform functionality according to the roadmap.

11 11 INVESTMENT EVALUATION Conclusion Criteria Does the team understand real market problems and offer their solutions? Is the company s product unique? Does the team understand its competition? Has the project laid out its operating business model? Is there a clear roadmap and financial plan? Is there already a working product? Is blockchain technology necessary for the project? Did the project team present the results of the safety audit of the smart contract and additional system security measures? Do the project participants have a clear motivation for owning the tokens? Is the issuance of tokens limited? Is there a mechanism that would protect current holders from token devaluation? Is the company s legal structure transparent? Has the company taken preventive measures to avoid problems with ICO market regulators? Is the project popular on social networks and in thematic communities? Is the project widely discussed in blockchain news resources? Does the project team have extensive experience and a strong track record? Does the project have a strong advisory board? Are the project s partners large and well-known? Is the project attracting large VC investors? Score AVERAGE SCORE 5.3

12 Project Concept digrate.com

13 13 INVESTMENT EVALUATION Concept Does the team understand real market problems and offer their solutions? Neutral 3 DIsagree 2 1 The project developers note several main problems inherent in centralized financial ecosystems (in particular, crypto exchanges) that need to be solved: Firstly, despite the large number of e-wallets and various services with the help of which you can convert cash to the cryptocurrency, transactions are subject to a rather high commission (in the majority of 3-7%). Currency transfer between cryptocurrency and fiat exchanges is also difficult due to high commissions. Secondly, not all cryptocurrency broker-services are ready to offer the maximum functionality for working with digital currency: the possibility of trading on the weekend, when traditional exchanges are closed, realization of wider spreads during a strong market volatility, the provision of suitable commissions and fees for servicing the digital currency trade.

14 INVESTMENT EVALUATION Concept 14 The Ingot team proposes to solve these problems by creating an integrated financial platform. The solution of the problem of high commissions will be achieved by combining the financial, stock and cryptocurrency market and giving users the opportunity to exchange different assets using one service (IC Exchange or IC Brokerage). In this case, users will not pay extra costs for withdrawing funds from one exchange (for example, crypto exchange) and transferring them to another one (for example, a fiat one). To solve the problem of the limited functionality of broker services, the project team develops its own IC Brokerage service, which will be available 24/7, will have the same conditions for both large and small investors, a low entry threshold and will conduct all transactions using smart contracts.

15 15 INVESTMENT EVALUATION Concept Is the company s product unique? Neutral 3 DIsagree 2 1 A complex of services is supposed to lay in the basis of the new Ingot ecosystem. The group of Ingot companies (Ingot Group) already has a functioning broker service for trading shares and traditional assets, this service will be integrated with the crypto exchange and other products of Ingot, that are currently being developed. IC Exchange is a key component of the platform that will provide users with a convenient graphical interface and will be able to offer a wide range of trading tools (precious metals, US and UK shares, European shares, Asian shares, African shares, and indexes for the latter, such as the S & P 500 and DowJones, ETF, bonds, options, etc.).

16 INVESTMENT EVALUATION Concept 16 IC Wallet is a cold wallet for storing crypto assets, fieat currency and traditional assets, integrated with other Ingot products for more effective interaction. IC Brokerage Service provides investors with the ability to trade different financial assets and provides users with a high liquidity pool due to communication with the best exchanges (agreements with exchanges have not yet been signed). IC Digital Bank is a digital bank, available 24/7, capable of managing customer funds. To increase reliability, IC Digital Bank will receive a financial banking license from an authoritative strict regulator (the company is studying regulators in Germany, Latvia, Belarus, the UAE and Bahrain, but no final decision has been made) that will ensure safe and smooth transactions. The bank will offer such services as opening an account, issuing a debit card for account holders, electronic transfers and payments. IC Liquidity Pool will be integrated with the best exchanges in the world (the list of exchanges is not disclosed) in order to exclude price manipulation and ensure deals at the best price in the market along with the highest liquidity. IC Crypto Certifier will provide market participants with the opportunity to participate in webinars, that will have a direct impact on increasing the awareness and knowledge of the global crypto community. Users will be provided with free courses in finance, history of cryptocurrencies and much more, as well as professional accreditations.

17 INVESTMENT EVALUATION Concept 17 The unification and functioning of the cryptocurrency, stock and currency markets within a single ecosystem is a unique offer on the market and will be in demand by investors both from the traditional financial market and crypto market. As for the additional services of the platform (training service, digital bank, e-wallet, exchange of cryptocurrency for fiat), these products will be presented in a highly competitive market and their competitive advantages for users are not obvious.

18 18 INVESTMENT EVALUATION Concept Did the team show the understanding of the competitive market environment? Neutral 3 DIsagree 2 1 A research of the cryptocurrency market and exchanges that would compete with Ingot was conducted in a business plan provided to DigRate analysts in private. The generalized statistics on services offered by digital banks, on the functionality of cryptocurrency wallets and on average prices for learning the basics of the blockchain development are presented. However, in addition to the list of major exchanges, the project team does not give other names of projects which Ingot will face in the market. There are more than 200 crypto exchanges, more than 20 cold wallets, more than 50 digital banks and more than 40 cryptocurrency broker services in today's cryptocurrency market with a capitalization of $ 417 billion (as of April 25, 2018), so it can be stated that the project will operate in a highly competitive environment.

19 INVESTMENT EVALUATION Concept 19 One of the Ingot s competitors is B2BX exchange that has already aggregated the liquidity of the 5 largest crypto exchanges. Current B2BX customers are 35 medium-sized brokerage companies and 5 famous giants of the crypto industry. Bitfinex and Kraken exchanges can also offer users cryptocurrency and fiat trade and they are in the top 10 exchanges in terms of daily trading volume on CoinMarketCap. United Traders (A2 investment attractiveness score), Beesy (A2 investment attractiveness score), that are working to create an integrated cryptocurrency ecosystems and have already presented their products to the market, as well as the Datarius digital bank, can be mentioned as competitors. In addition, there are many cryptocurrency broker-services (Coinbase, FXTM, Forex4you, etc.) and classic broker-services, that initially operated in the traditional financial market and then integrated with cryptocurrency services, for example, Exante. However, none of them, unlike Ingot, does not offer a solution that would allow direct exchange of traditional financial instruments for cryptocurrency and vice versa. The main competitive advantages of Ingot are the presence of a cold wallet (IC Wallet), integrated with the exchange, which will increase the security of funds storage and aggregation of liquidity from other exchanges in IC Exchange and IC Brokerage, that excludes failures in the periods of high market volatility. The developers of the project also claim that they will be able to offer an unlimited number of trading tools in IC Brokerage and IC Exchange, will list on their exchange all new cryptocurrencies, will list a lot of already issued tokens, and will also be able to offer shares and fiat currencies trade. However, as is known, crypto exchanges with fiat currencies have strict regulation by financial state regulators, and the list of possible cryptocurrencies is very limited.

20 INVESTMENT EVALUATION Concept 20 The team suggests the following to solve this problem: all cryptocurrencies will be evaluated against the IC token, and IC in turn will be the only token on the exchange that will get permission for trading against fiat currencies. Thus, for the trade of any cryptocurrency asset against the fiat currency, for example BTC / USD, the transaction will be divided into two transactions - BTC / IC and IC / USD. The same principle will be applied to traditional assets trade. Let's say that BTC will trade against Apple shares. The transaction will be divided into 3 transactions - BTC / IC, IC / USD, USD / AAPL. Transaction costs will be low due to calculations through the IC token. This solution is really innovative for the cryptocurrency market, but the question is whether this solution is necessary for the market. If the exchange of traditional assets for cryptocurrency is in demand, it is likely that other existing exchanges and financial ecosystems will implement this service. Since the exchange of traditional assets for cryptocurrency within the Ingot ecosystem will be available only by 2021, according to the roadmap, new competitors with a similar solution may appear on the market.

21 Business Model digrate.com

22 22 INVESTMENT EVALUATION Business Model Has the project laid out its operating business model, which is planned to be implemented under project? Neutral 3 DIsagree 2 1 Ecosystem revenues will be generated through from the IC Digital Bank services commissions (commissions for transfers and transactions inside the system), IC Exchange (exchange commissions), IC Brokerage (fees for brokerage services), IC Crypto Certifier (fee for user certification). Users will be able to purchase IC tokens during ICO and store them on IC Wallet. Tokens stored on IC Wallet can be easily used to pay for other platform services. At the same time, users will receive discounts of up to 50% paying for services with IC tokens. The cost of IC Certifier services is denoted as the average for the market and will be $ $ 2000 depending on the exchange rate. 50% of the cost of the training course will be transferred to teachers and the remaining 50% is Ingot s profit. The IC Exchange and IC Brokerage transaction commissions will range from 0.05% for Fiat vs Fiat transactions to 1.10% for the Crypto vs Traditional and, after deduction of costs, will also form the Ingot s profit. IC Digital Bank services will be subject to a depositary commission of 0.05%, a 1% management commision and fund management performance fee of 10%. The commissions indicated by the Ingot team are average or below the average for the market.

23 23 INVESTMENT EVALUATION Business Model Is there a clear roadmap and financial plan? Neutral 3 DIsagree 2 1 A detailed roadmap is available on official project resources. The project announced ICO rather recently, therefore it is at the very beginning of implementation and it is not possible to assess the compliance with the terms of the project development. The project's income will reach about $ 200 million by 2020, $ 800 million by 2021, according to the project team s calculations. The exchange rate of the IC token will grow to $ 5 by 2020 and to $ 40 in This forecast is too optimistic taking into account the presence of strong competitors with the finished products, according to DigRate experts, however, in order not to overstate the indicators, the project team took indicators below the average in the market for all calculations.

24 The Tech digrate.com

25 25 INVESTMENT EVALUATION The Tech Does the company has already a working product? Neutral 3 DIsagree 2 1 There is no reference to the product prototype on official resources of the company. Release of the first product (IC Wallet) is scheduled for the second quarter of 2018 (before the start of the crowdsale), according to the roadmap. IC Wallet will be equipped with all the declared functionality and fully launched by the end of Further IC Digital Bank will be released in the second quarter of 2019, and all other products will be released (IC Brokerage, IC Certifier, IC Exchange) by the end of The source code of the smart contract and platform protocol are not published on GitHub. The project team promises to publish a smart contract by the end of June.

26 26 INVESTMENT EVALUATION The Tech Is blockchain technology necessary for the project? Neutral 3 DIsagree 2 1 Developers state that the introduction of blockchain and crypto technologies in the Ingot Group business will allow reaching a wider audience, making transactions between ecosystem users reliable and transparent. It will also unite the traditional financial market with crypto market, will cut costs, entry thresholds and commissions. Cost savings will also be achieved due to the use of a distributed network and smart contracts in IC Brokerage and IC Exchange services to execute orders that automate most of the activity. IC Wallet will also be based on the blockchain and store all transaction data in it. The data on the issued IC Certifier certificates will be recorded in the blockchain.the project team admits that they are using a hybrid system and integrate a centralized and decentralized data storage and processing structure for building the Ingot ecosystem. The construction of such a structure is possible without blockchain technology, however, the use of such technology in the registration, storage and exchange of data is important and valuable for any financial project, including Ingot. Investment evaluation of NEX ICO

27 27 INVESTMENT EVALUATION The Tech Did the project team present the results of the safety audit of the smart contract and additional system security measures? Neutral 3 DIsagree 2 1 IC Wallet, where funds are protected by cryptographic ciphers, as well as a storage with a lot of signatures, which will protect market participants from any external access, will be the main security measure of the system. IC Wallet users will be able to transfer their assets safely between the ecosystem wallets through a set of procedures that will include KYC, AML and multi-signature procedures. The project team has not yet publicly submitted a smart contract and has not conducted its security audit. Investment evaluation of NEX ICO

28 Tokens digrate.com

29 29 INVESTMENT EVALUATION Tokens Do the project participants have clear motivation for owning the tokens? Neutral 3 DIsagree 2 1 The project team notes that the IC token will have a number of utility token features - using IC as a payment tool in the Ingot ecosystem, payments with the IC token are being subject to preferential commissions, as well as transactions within IC Exchange involving IC, although the token will not be the only means of payment within the ecosystem. Developers also note the security nature of the IC token. The founders of the project promise to pay dividends to all the holders of the tokens after the Ingot ecosystem becomes stable and profitable. The project team declares the satisfaction of the token owners and the provision of economic benefits as one of the main objectives of the project. Representatives of the team declare that the IC tokens will be quoted on the top-level crypto exchanges (that are not specified) and the project team is currently negotiating with the exchanges. Since IC has clear security features, the token must be registered with the securities market regulators in those countries where the law requires it (for example, the USA).

30 30 INVESTMENT EVALUATION Tokens Is the issuance of tokens limited? Neutral 3 DIsagree 2 1 A total of 120 million IC tokens will be issued with a base cost of 1 IC = 1 $. All unsold tokens will be destroyed. Soft cap is $ 37 million, hard cap is $ 90 million. The ratio of soft cap to hard cap is optimal. The developers do not approve that the investors' funds will be returned if the soft cap is not reached, but designate this amount as the minimum necessary to implement the first stages of the project. Since the project will also carry out activities on the traditional stock market, it will require appropriate licenses, depending on countries in which activities are supposed to be carried out. These licenses are quite expensive, so DigRate analysts believe that Hard Cap is adequate. Early investors will be offered bonuses of up to 30%.

31 31 INVESTMENT EVALUATION Tokens Is there a mechanism that would protect current holders from token devaluation? Neutral 3 DIsagree 2 1 The project team states that the use of IC tokens within the system will be encouraged by preferential commissions (up to 50%), that can potentially stimulate the turnover of tokens and the growth of the IC exchange rate. It is planned to lock the project founders tokens for 18 months, project teams for 12 months and advisers for 3 months. Additional deflation mechanisms are not ensured by the project team.

32 Legal Documentation digrate.com

33 33 INVESTMENT EVALUATION Legal Documentation Is the company s legal structure transparent? Neutral 3 DIsagree 2 1 The company that will carry out operations and acts as the issuer of the IC token is INGOT COIN OÜ (registered on in Estonia at Parda tn , center of the city district of Harju County 10151, registration number ). Information about the management of the company and its beneficiaries is not disclosed. The team has developed and published legal documents: Terms and Conditions, Privacy Policy, the SAFT for the sale of tokens. Information about the use of an escrow is absent.

34 34 INVESTMENT EVALUATION Legal Documentation Has the company taken preventive measures to avoid problems with ICO market regulators? Neutral 3 DIsagree 2 1 White Paper mentions that all investors will have to undergo AML and KYC procedures for the acquisition of IC tokens. The internal KYC system for users of Ingot services is also provided. SAFT contains recommendations for residents of all countries with strict regulatory rules for cryptocurrency. Residents of the United States are not allowed to purchase IC tokens. The project team plans to start activity in Europe (Germany, France, Estonia), then in the Middle East (Dubai, Bahrain, Lebanon, South Africa, Egypt). It is planned to expand activities to all regions where operations with cryptocurrency are not prohibited as far as obtaining permits. The project has already received an exchange license from the Estonian regulator, and is in the process of issuing a banking license from the German regulator. Tests on the non-recognition of the token as a security were not presented by the team, although there is a high probability of recognizing the token as a security by the market regulators, since the project team directly declares the payment of dividends to the token holders.

35 Legal Opinion digrate.com

36 INVESTMENT EVALUATION Legal Opinion 36 NewLawyers, partner of Digital Rating Agency. SUBJECT The IC token (hereinafter Token) issued under ICO of INGOT TOKEN project (hereinafter Project) is analyzed in the report. Analysis findings can be used with the account of the limitations defined in the end of the report. DOCUMENTS Whitepaper, which is the main marketing material for the Token sale, can be downloaded on (hereinafter Site). Despite the very large size, Whitepaper contains extremely limited information on legal aspects, but the information contained in this document is sufficient to draw separate conclusions about the Project. However, the legal value of this document is not so high, as it is directly stated because in SAFT, which is supposed to be processed with Token buyers, that Whitepaper does not have any legal value.

37 INVESTMENT EVALUATION Legal Opinion 37 The Site contains information about the Project team (hereinafter Team). Terms and Conditions, Privacy Policy, as well as SAFT, which is likely to be used for registration of investment attraction, are presented for the analysis. All documents seem to be executed in a rather weak style. The team has a lawyer, but we can assume that the level of his involvement in the Project is not so high. The last access to the Documents was made on April 24, The last SAFT analysis was carried out on May 3, TOKEN Rights granted to Tokens holders As it stated in the Whitepaper, Token can be used both as a security and as a utility token. In the first case, the owner of Token will receive income from the growth of its value in the form of dividends. In the second case, it will be used as a means of payment within the ecosystem created by the Team, as well as outside of it. There is no meaningful information about what the Token is in the SAFT. The Token is described in Terms and Conditions in the most general form (in the form of reproduction of separate Whitepaper provisions). However, the rights of Token owners are not really described even there.

38 INVESTMENT EVALUATION Legal Opinion 38 Token Issuer Judging by the Documents, it is impossible to make an unambiguous conclusion about who is the issuer of Tokens. SAFT conclusion is planned exactly from the Estonian company INGOTCOIN. Terms of Tokens sale The contractual provisions regarding the sale of Tokens are mixed in SAFT and Terms and Conditions. Analysis of these documents does not allow us to make a full conclusion about whether Tokens are being sold now, or it is only about the future sale. It is not completely clear when sale will happen. Most of the documents content is aimed at protecting the interests of the issuer, primarily from the risk of Token buyer claims. Accordingly, there is no clarity regarding the responsibility for the Token sale transaction. The possibility of returning to the buyer his funds for Tokens is not mentioned. In general, these documents appear to have been implemented at a low legal level. Moreover, the use of the SAFT design is rather a tribute to fashion. The meaning in this particular case is not obvious.

39 39 INVESTMENT EVALUATION Legal Opinion Management of risks of Token's qualifications as a security Whitepaper unambiguously indicates that Token has both utility and security features (pages 46 and 47). Moreover, the Team directly promises future dividends to the Token. At the same time, the Team also indicates that the Token is not a security (p. 62) in Whitepaper. The same contradiction can be traced in SAFT, where the Team indicates the risk of Token's qualification as a security in a fairly obvious form, but later in the same document it tries to realize the idea that Token is still not a security. Further in the same document it is said that the buyer buys Token in the hope of profit from the efforts of the company and its employees, that is a direct way to pass the Howey test. Despite the high risks of Token's qualifications as a security, restrictions of jurisdictions for which Token will be offered are not mentioned in the Documents. At the same time, the SAFT includes a set of standard notifications for citizens of different countries (USA, European Economic Area, Switzerland, Great Britain, Singapore, Canada, Hong Kong, Japan, Russia, India, China, South Korea, Iran, North Korea, Syria, Sudan, Cuba), which, depending on the country, contains a prohibition on the token purchase, the absence of tokens full registration as a security and a full-fledged issuance prospectus.

40 40 INVESTMENT EVALUATION Legal Opinion Usage of proceeds obtained from the emission of Tokens The purposes for which proceeds from the sale of Tokens will be used are specified in White Paper. This information is not duplicated in the ment. HOLDING STRUCTURE SAFT only mentions the Estonian company INGOTGOIN. Terms and Conditions also mentions the company that is listed below on the Site, but now there is no mentioned legal entity. OPERATIONAL STRUCTURE The Site provides information on the Team members. There are also hyperlinks to the profiles of the majority of Team members. It is worth paying attention to the fact that the overwhelming majority noted that they are participating in the Project from November/December Team members live mainly in Jordan, as well as in the UAE, China, Swaziland. None of them live in Estonia.

41 INVESTMENT EVALUATION Legal Opinion 41 INTELLECTUAL PROPERTY There is no information on intellectual property in Whitepaper. Trademarks that use INGOT designations were not found. PERSONAL DATA The issues of obtaining, processing, storing and transferring personal data are practically not disclosed. There is a standard Privacy Policy, that does not differ from other similar documents. COUNTERACTION OF THE LEGITIMIZATION OF THE PROCEEDS OF CRIME AND THE FINANCING OF TERRORISM Detailed KYC / AML procedures are not described in the Documents, although the need for compliance with the relevant procedures is mentioned in Whitepaper.

42 INVESTMENT EVALUATION Legal Opinion 42 RESTRICTIONS The analysis presented in this report is intended for information purposes only, it has been prepared using publicly available information only and it is not a legal opinion of NewLawyers regarding the legislation of any given state. In the analysis we used only the information which has been freely available and could have been obtained by any interested person without making any financial investments. The only purpose of our study is to form a common understanding of the degree of attention that the Team may have given to the legal aspects of the Project. The purpose of this study has never been, is not and will not be, among other things, assessing the legal correctness of the performed ICO, the correctness of any of the Team's legal positions, the quality and (or) correctness, and (or) the adequacy of the Documents used, the ability of the Team to fulfill obligations in the framework of the Project, the confirmation (or refutation) of certain facts, the implementation of legal advice and others. The conclusions drawn can in no circumstances be used or interpreted as an incentive or recommendation for any Token transaction or other investment decision related to Tokens. Our interpretation of the Documents may differ from the interpretation recognized by the Team and/or its individual members and/or any other persons.

43 INVESTMENT EVALUATION Legal Opinion 43 Despite the fact that we have taken all reasonable measures to exclude mistakes in our analysis, it cannot be completely ruled out that such errors are still admitted. We are not responsible for any mistake, misprint, inaccuracy, ambiguity, as well as any discrepancy in the interpretation of the Documents (including if our interpretation is incorrect). You need to contact your counselor for professional legal and other advice in the context of your particular situation. The first person who reads down the "Restrictions" section to the end and reports to the NewLawyers is given a 50% discount, and the next ten persons will be given 10% discount for any NewLawyers legal services related to the implementation of the blockchain project, during 2018.

44 Media Environment digrate.com

45 45 INVESTMENT EVALUATION Media Environment Is the project popular on social networks and in thematic communities? Neutral 3 DIsagree 2 1 The project team conducts an active marketing campaign, the number of subscribers in social networks and BitcoinTalk is quite high, however, there is no extensive discussion of the project. The highest activity by the number of comments is observed on Twitter. The team also published a marketing plan with further actions.

46 INVESTMENT EVALUATION Media Environment Number of subscribers of the project in social networks and on other resources (as of June 4, 2018): 1591 subscribers 2167 subscribers 17,554 subscribers 48,853 members 46

47 47 INVESTMENT EVALUATION Media Environment Is the project widely discussed in blockchain news resources? Neutral 3 DIsagree 2 1 Information about the project is found on many resource trackers and was published in more than 30 news platforms from to The project team also took part in several May conferences attended by many MENA and Asian investors. However, active discussion of the project by public and blockchain enthusiasts is not observed.

48 INVESTMENT EVALUATION Media Environment News resources that have published articles about the project: 48

49 Team digrate.com

50 50 INVESTMENT EVALUATION Team Does the project team have extensive experience and a strong track record? Neutral 3 DIsagree 2 1 All project founders occupy leading positions in Sigma Investment LTD, some of them are also managers of the Ingot Group. The CEO of the Ingot project is also the Chief Manager of the Ingot Group. It is worth noting that Ingot Group is a successful and well-known company that has been operating in the financial market for more than 20 years and has representative offices in different countries of the world (Australia, Estonia, Switzerland, Bahrain, etc.). The official resources of the project provide information on other team members, with a description of their experience and contact information. Most of the team members are also employees of Sigma Investment LTD. The project team is represented by 16 specialists from various professional fields: marketing, software development and design, financial analytics. However, despite the professional merit, it can not be said that the team has considerable experience in the implementation of blockchain projects. Absence of specialists in the blockchain field is compensated by the fact that experienced advisers are attracted to cooperation.

51 51 INVESTMENT EVALUATION Team Iman Mutlaq Ali Shibib Founder CEO MBA ACCA, CMA, FRM, CTP Ali Faqih Zeid Madbak CFO CRO CMA, CPA CFA

52 52 INVESTMENT EVALUATION Team Ahmed Khawanky Bruno Bianchini CMO CSO Other team members: Hadi Varouqa Art Director Saif El Din Murad, Rashed Alkhzaie, Haiyan Liu, Iyas Sartawi, Mohammad Basyouni, Matthew McCrow, Rajkumar Kanagasingam, Yin Lu, Hasan Al-Omari, Zaid Srour, Hossam Khawanky, Ehab Aboushi, Ashar Rawashdeh, Khaled Faza, Esra Hatemi, Jasveer singh, Surabhi Dewra, Leen Daoud, Mohamed Qasem.

53 Project Support digrate.com

54 54 INVESTMENT EVALUATION Project Support Is the project supported by a serious Advisory Board team? Neutral 3 DIsagree 2 1 As of the date of the report, the advisory board of the project consists of ten members, the first one was Naviin Kapoor a well-known ICO and a contractor adviser that will be able to provide substantial tech support to the project. Warren Whitlock is a PR and marketing adviser, also known for his "Twitter Revolution" book. Involving a well-known experts will help the project to conduct an effective campaign and become famous on the world stage. Naviin Kapoor confirmed his participation in the project, confirmation of participation of Wareen Whitlock was not received. The project states that they attracted the following blockchain advisors: Pranav Bhatia (blockchain), Victor Chow (business), Sydney Ifergan (marketing), John Van Der Voss (ICO), Bogdan Fiedur (technical development) and George Mentz (jurisprudence), Jim Preissler (ICO), Saad Mohib (ICO). LinkedIn profiles of advisors indicate cooperation with Ingot.

55 55 INVESTMENT EVALUATION Project Support Naviin Kapoor Warren Whitlock George Mentz Blockchain ICO Advisor PR & Marketing Adviser ICO Legal Adviser Pranav Bhatia Sydney Ifergan Blockchain R&D ICO Marketing Adviser

56 56 INVESTMENT EVALUATION Project Support John Van der Vos ICO Advisor Инвестиционная оценка ICO проекта Ingot Bogdan Fiedur Victor Chow ICO Tech Adviser ICO Business Adviser

57 57 INVESTMENT EVALUATION Project Support Are the project s partners large and well-known? Neutral 3 DIsagree 2 1 The partners of the project are such companies as Sigma Investment LTD, Dreamtechs, that, like the Ingot project, are part of the Ingot Group. Employees of these companies are not directly involved in the project and will advise the project on investment, financial and tech issues. Ingot Group is also a member of Global Alliance Partners (GAP) - an international network of regulated financial companies specializing in the market of medium capital. The international coverage of GAP gives its member firms more opportunities and a wider platform for investment banking, capital and fund management. The Trade.io project provides Ingot with advisory support in conducting the ICO. Ingot concluded a partnership agreement with Modern Finance Chain on matters of ensuring sufficient liquidity. There are also announced partnerships with ZICHAIN, Stella, HalalChain, Kakushin.tech and Bineuro. Details of the agreements will be disclosed later.

58 58 INVESTMENT EVALUATION Project Support Is the project attracting large VC investors? Neutral 3 DIsagree 2 1 The project team claims that a number of large VC funds such as Wamda, Dash, Oasis 500, Shamal Start, East Chain and Ahli FinTech showed interest in the project, however, no actual investments in the project is reported, and no such information was found in news resources.

59 59 RATING SCALE OF INVESTMENT ATTRACTIVENESS Very high High Satisfactory Medium-to-high probability of long-term investment return, the level of project development potential is above average. Score: Considerable risk exposure, high sensitivity to market conditions. Score: Low Very low In default Low development potential, highly speculative investment. Score: High default risk in the short term. Score: 0-2 In default, with little-to-no prospect for recovery High probability of a significant token price increase, considerable scaling and development opportunities. Score: 6.1-7

60 CONTACTS (495) (Russia) (Russia) (Switzerland) digrate.com 60