accordance with the notification of the SEC. In this regard, Zipmex did not deposit customers' digital assets with digital asset depository service providers and keep them in its cold wallets, digital

connected to the internet when conducting transactions only (cold wallet) less than 90 percent of the customer's total digital asset value and did not deposit customers' digital assets with digital

Orbix failed to keep customers' digital assets in accordance with the notification of the SEC for 121 days. In this regard, Orbix did not deposit customers' digital assets with digital asset

for the operation of Merkle relating to customers' assets. Her failure to perform the required duty of her position resulted in the offence committed by Merkle concerning the case that, from March