BRIDGE OPERATING RULES
BRIDGE OPERATING RULES
Effective from 07 Sep 2026
These Operating Rules govern access to and use of the Liminal Prime Bridge platform (the “Platform” or “Liminal Prime Bridge”), which is operated by First Answer (BVI) Limited (“Liminal”, “we”, “us” or “our”). They explain how the Platform functions, how Users interact through it, and how responsibilities are allocated between Users and Liminal. These Operating Rules form part of, and are incorporated into, the Liminal Prime Terms & Conditions (the “T&C”). Words defined in the T&C have the same meaning here unless stated otherwise. Where these Operating Rules conflict with the T&C on the operation or functionality of the Platform, these Operating Rules prevail; in all other respects the T&C prevail.
1. DEFINITIONS
1.1 “Confirmation” means the post-trade report generated by the Platform on a daily basis, setting out, for each User, its identifying details, the terms of its Transactions in sufficient detail to identify them, its applicable trading limits, and its open positions awaiting settlement.
1.2 “Digital Asset” or “Virtual Asset” means any cryptographically-secured digital representation of value that operates on a distributed ledger or similar decentralised network, including cryptocurrencies, tokens and coins.
1.3 “Exchange” means any securities or derivatives exchange, clearing house, self-regulatory organisation, multilateral trading facility, alternative trading system or comparable venue on which Digital Assets may be traded.
1.4 “Firm Quote Model” means the firm order-book trading mode described in Section 8, in which Makers post resting orders and Takers send aggressive orders that are matched against the order book maintained on the Platform resulting in a Trade Contract.
1.5 “RFQ Model” means the request-for-quote trading mode described in Section 8, in which a Taker requests quotes, Makers respond, the Taker selects a Maker, and the execution of the Trade Contract takes place on that Maker’s own venue.
1.6 “Maker” means a User that provides liquidity, whether by posting resting orders in the Firm Quote Model or by responding with quotes in the RFQ Model.
1.7 “Taker” means a User that consumes liquidity, whether by sending aggressive orders in the Firm Quote Model or by requesting and accepting quotes in the RFQ Model.
1.8 “Master” means a User that may create and administer Sub-accounts and configure their permissions, limits, markups and settlement records.
1.9 “Sub-account” means a User that trades only under a Master, as either a Sub-maker or a Sub-taker, within the parameters set by that Master.
1.10 “Inter-dealer Trade” means a Transaction between Users each acting in a liquidity-providing capacity, as permitted by the Platform’s configuration.
1.11 “Markup” means an adjustment applied to a quoted price that widens or narrows the spread shown to a liquidity-consuming User.
1.12 “Net Open Position” or “NOP” means, per Digital Asset and per counterparty, the net long or short position of a User, calculated from all its Transactions and Settlement Transactions in that Digital Asset.
1.13 “Overnight Rate” means a charge or credit applied by a Maker or Master for an unsettled Net Open Position carried beyond a trading day.
1.14 “Settlement Transaction” means an informational message exchanged between counterparties recording a request for, or the status of, settlement of a position, such settlement occurring outside the Platform.
1.15 “Trade Contract” means a binding bilateral trading contract between the Taker and the Maker specifying the type of Digital Asset, the quantity, and the price, pursuant to which the settlement of a Transaction may take place.
1.16 “Transaction” means a bilateral dealing between two Users entered into through the Platform in accordance with the Trade Contract, T&C and these Operating Rules, which is settled and completed outside the Platform by delivery of the relevant assets between those two Users.
1.17 “User” means a legal entity that has accepted the T&C in order to access and use the Platform.
2. THE PLATFORM AND LIMINAL’S ROLE
2.1 Liminal Prime Bridge is a peer-to-peer electronic communication platform that enables Users to discover prices, communicate, and negotiate and enter into Transactions in Digital Assets, in the trading modes described in Section 8.
2.2 Liminal acts solely as a technology provider. It is not a party to any Transaction, and does not act as an exchange, broker, dealer, market maker, market operator, custodian or clearing entity.
2.3 Before transacting, Users must have in place their own bilateral agreement(s) governing their trading relationship. Those agreements govern the legal relationship between the Users and, as between them, prevail over these Operating Rules. Liminal is not a party to, does not verify, and is not responsible for the absence or content of such agreements.
2.4 Users are responsible for effecting delivery and settlement of their Transactions. The Platform is not involved in settlement; all asset and cash movements, netting and settlement occur outside the Platform under the Users’ own arrangements.
2.5 Liminal does not provide clearing or settlement services. A User that provides clearing or settlement services to others does so on its own responsibility and must inform its counterparties of its processes. Where such external processes differ from the Platform’s records, the external process prevails.
2.6 Masters are solely responsible for the onboarding, due diligence and AML/KYC of their Sub-accounts and for their conduct. Liminal may apply KYC/KYB/AML procedures to Sub-accounts that pay fees to Liminal directly. Liminal remains responsible for resolving trade disputes caused by technical faults in the Platform.
2.7 Users remain responsible for their own compliance with the laws and regulatory obligations applicable to them in their jurisdictions of incorporation and operation.
2.8 Access to the Platform is conditional on compliance with these Operating Rules. Liminal may restrict or suspend access where a User fails to comply.
2.9 Any third-party trademarks appearing on the Platform or the Liminal Prime website are used for identification purposes only and do not imply any endorsement or affiliation.
2.10 Liminal may amend these Operating Rules in accordance with the T&C, on notice to Users. The current version is published on the Liminal Prime website.
3. TRADING LIMITS AND RISK MANAGEMENT
3.1 Trading limits and margin parameters are defined and monitored by Users. The Platform provides the tools by which Users set their limits and monitor utilisation. Liminal does not set, manage, guarantee, or provide margin or leverage, and does not act as counterparty.
3.2 Every Transaction is entered into within the trading limits pre-defined by the User. Supported limits include counterparty (bilateral) limits and, optionally, margin requirements comprising initial margin, maintenance margin and restricted-trading thresholds.
3.3 A new Transaction is permitted only where the applicable counterparty free limit is positive and any margin requirement is met; otherwise the order is rejected. Open orders and unsettled Transactions are taken into account when calculating exposure, applying a worst-case approach.
3.4 Where margin applies, the Platform compares a Taker’s equity (the sum of its NOP per counterparty) against the maintenance, restricted-trading and initial-margin thresholds set by the relevant Maker or Master, which may permit liquidation of positions or restrict further trading if breached.
3.5 Limit values are set by Users. Counterparty limits and margin requirements set on a counterparty are visible to that counterparty only where it has also set a limit on the User.
3.6 The Platform includes a mechanism preventing a User from entering into a Transaction with itself.
3.7 Makers may not trade with other Makers, which may give rise to crossed markets (a bid higher than the best offer, or an offer lower than the best bid).
3.8 A Maker may apply an Overnight Rate to an unsettled NOP. Liminal does not provide swaps or other interest-rate products and, where this functionality is used, invoices only a fraction of the Overnight Rate.
4. AVAILABILITY
4.1 The Platform is generally available 24 hours a day, 7 days a week, subject to planned and unplanned maintenance and to technical and operational constraints.
4.2 Liminal will give notice of maintenance where practicable. Liminal does not guarantee availability in the absence of a service-level agreement, and Users should maintain back-up channels for execution of the Trade Contracts.
5. ADMISSION AND ONBOARDING
5.1 Admission to the Platform is subject to due diligence. Users must provide, and keep current, the information and documentation Liminal requests; failure to do so may result in refusal, suspension or termination of access.
5.2 In addition, and as a condition of dealing through the Platform, a Maker and a Taker must first onboard with each other bilaterally, off the Platform, and enter into their own agreement governing their trading relationship. A Taker is shown only to those Makers with whom it has onboarded.
5.3 Liminal may decline or revoke access to the Platform at its discretion and without giving reasons.
6. ACCESS METHODS AND SECURITY
6.1 Users may access the Platform through a graphical user interface (GUI) or an application programming interface (API), in each case using authorised credentials issued by Liminal.
6.2 Users must keep Liminal informed of each system that accesses the Platform by API, maintain appropriate security controls, and notify Liminal promptly of any lost or compromised credentials. A sandbox environment is available for testing.
7. DATA AND RECORDS
7.1 The Platform makes available to Users market data consisting of quotes placed by other Users, via GUI and API. Data feeds may be User-specific (reflecting applicable limits and Markups); an aggregated feed is also available.
7.2 Liminal may disseminate anonymised market data and may disclose to a User certain trading statistics relating to its counterparties. Daily Confirmations are provided to each User. All timestamps are recorded in UTC.
8. TRADING MODES AND ORDER TYPES
8.1 The Platform supports two trading modes — the Firm Quote Model and the RFQ Model. A User’s access to a given mode depends on its role, its configuration, and its jurisdiction (see Annex A).
Firm Quote Model (firm order book)
8.2 In the Firm Quote Model the Platform maintains a firm order book. Makers provide liquidity by posting resting orders and Takers consume liquidity by sending aggressive orders, using the following order types:
(a) Limit — buy or sell at a specified price or better;
(b) Limit Post-only — added to the order book only if it does not match a pre-existing order;
(c) Limit Immediate-or-Cancel (IOC) — filled immediately at the specified price or better, with any unfilled size cancelled (partial fills allowed);
(d) Limit Fill-or-Kill (FOK) — filled immediately and in full at the specified price or better, failing which it is cancelled (no partial fills);
(e) Market IOC — filled immediately at available prices, with any unfilled size cancelled where there is insufficient liquidity in the order book (partial fills allowed); and
(f) Market FOK — filled immediately and in full at available prices, failing which it is cancelled.
8.3 By default, Makers may use Limit and Limit Post-only order types, and Takers may use Market and Limit IOC and FOK order types. Aggressive orders may be subject to a short latency delay (a “latency floor”) as part of the Platform’s technical configuration.
8.4 Execution in the Firm Quote Model. In the Firm Quote Model, orders are matched against the order book maintained on the Platform, and the resulting Trade Contract is formed at the point of match on the Platform. The Settlement occurs outside the Platform, bilaterally between the Users.
RFQ Model (request for quote)
8.5 In the RFQ Model:
(a) a Taker submits a request for a quote, specifying the side (buy or sell) and the size;
(b) the Makers with whom the Taker has onboarded respond with price quotes;
(c) the Taker may submit an order request to a selected Maker based on those quotes; and
(d) the selected Maker may exercise a final confirmation right (a “last look”) to confirm or decline the order request.
8.6 Execution in the RFQ Model. In the RFQ Model, execution of the Trade Contract takes place on the external trading platform of the selected Maker. Transaction completion and settlement is managed entirely by the selected Maker and/or external platforms, and not by Liminal Prime Bridge. Liminal is not responsible for order rejections under the last-look process, for issues arising from third-party integration, or for any matters beyond its control. The Platform is used only to request and receive quotes and to communicate; it does not match, execute or settle RFQ orders.
Execution venue — summary
8.7 For the avoidance of doubt: in the Firm Quote Model, matching and execution of the Trade Contract occurs on the Platform’s order book; in the RFQ Model, execution of the Trade Contract occurs on the selected Maker’s own venue, off the Platform. In both models, settlement occurs bilaterally between the Users, outside the Platform, and Liminal takes no custody of any User’s assets.
9. FAIR USE OF THE PLATFORM
9.1 Users must use the Platform in a fair, orderly and responsible manner. Abusive trading practices are prohibited, including painting the tape, wash trades, advancing the bid, pump-and-dump activity and spoofing.
9.2 The Platform provides limited built-in protective controls and does not substitute for Users’ own systems and controls. Users are responsible for maintaining adequate systems and controls to ensure their compliance with these Operating Rules and to manage their trading activity.
9.3 On a material disruption — including a Platform malfunction, attempted market abuse, third-party failure, emergency, extraordinary market conditions or force majeure — Liminal may take such action as it reasonably considers necessary to restore orderly operation. On a system failure, open orders may be cancelled regardless of their time-in-force; orders filled but not yet confirmed may be treated as filled for reconciliation purposes.
10. COMPLIANCE — SANCTIONS AND EXPORT CONTROLS
10.1 Users must comply at all times with applicable export-control and sanctions laws and regulations.
10.2 Access to the Platform is not permitted where a User, or any of its owners, directors or senior managers, is subject to sanctions administered by the U.S. Office of Foreign Assets Control (OFAC), the U.K. HM Treasury, the European Union or any other applicable authority; where a User is controlled by or acting for a sanctioned government or person; or where funds used derive from any sanctioned person.
11. ERRONEOUS TRANSACTIONS
11.1 A Transaction may be treated as erroneous where the counterparty is not an authorised User, an applicable counterparty limit is exceeded as a result of the Transaction, or the asset is not a permitted asset.
11.2 A review may be initiated by a User or by Liminal. Liminal is not obliged to review any Transaction and will not review a Transaction that has already settled. Liminal will use good-faith efforts to assist the parties, including by providing relevant records, but the resolution rests with the parties.
12. GENERAL
12.1 These Operating Rules are incorporated into, and form part of, the T&C. They are governed by, and construed in accordance with, the governing law and the dispute-resolution provisions set out in the T&C (Singapore law).
12.2 Liminal may amend these Operating Rules in accordance with the T&C, on notice to Users. Records maintained by the Platform are retained in accordance with the T&C and applicable law.
ANNEX A — JURISDICTION-SPECIFIC RIDER: UNITED ARAB EMIRATES (UAE USERS)
A.1 This Annex applies to Users that are located in, resident in, or accessing the Platform from the United Arab Emirates (“UAE Users”). To the extent of any inconsistency, this Annex prevails over the body of these Operating Rules in respect of UAE Users.
A.2 Only the RFQ Model is available. For UAE Users, only the RFQ Model is made available on the Platform. The Firm Quote Model (firm order book) is not offered or enabled for UAE Users, and no order book is maintained for them.
A.3 Execution off the Platform. Consistent with the RFQ Model, for UAE Users the execution of orders takes place on the external venue of the selected Maker. Liminal Prime Bridge acts only as a technology and communication layer and does not match, execute or settle any trade.
A.4 Bilateral onboarding. UAE Users deal only with Makers with whom they have separately onboarded and entered into their own bilateral agreements off the Platform. A UAE User is shown only those Makers with whom it has onboarded.
A.5 No custody or settlement. Liminal takes no custody of any UAE User’s assets and provides no clearing or settlement. Settlement occurs bilaterally between the Users, outside the Platform.
A.6 This Annex reflects the basis on which the Platform is made available in the UAE and is subject to any conditions required by applicable UAE law and by the relevant UAE regulators.