person who has authorized the management of the private fund using knowledge and competence as a professional. SEC Act S.134 paragraph 2 and paragraph 3 in conjunction with 133 paragraph 1 Criminal

systems related to receiving and handling complaints, channels to communicate with customers as well as the number and ability of personnel for Bitkub to operate its business efficiently. DAB Act S.30

of exchange of a company for private funds which did not analyze the ability to pay debt and did not ask for the consent of the client. SEC Act S.133 paragraph 2 Settlement Committee Meeting No. 3

the credit was not rated and found defects in consideration of important information or factors with respect to the issuer, and this affected its capability to repay the principal and pay interest