TIB Integrity Standards
The published criteria — six pillars, thirty binding items — applied in every TIB verification engagement.
Status and authority
This document (the Standards) sets out the substantive criteria applied by Trading Integrity Bureau (TIB, operated by Stratinova LTD, Cyprus, HE475207) when conducting verification engagements. The Standards are applied in accordance with the procedure published in the Methodology.
Binding effect
The Standards are binding on TIB in the conduct of every verification engagement and are incorporated by reference into every Engagement Agreement. They do not, of themselves, create rights enforceable by any third party and do not constitute legal or regulatory requirements imposed on any Firm.
Universality
The Standards apply identically to every Firm under the same engagement type. A Firm cannot negotiate the criteria against which it is assessed.
Interpretation
Words of obligation
References to must, shall, or required in the Standards are binding within the scope of a TIB verification engagement. They do not impose legal obligations on Firms outside that scope.
Proportionality
The Standards are applied with regard to the size, complexity, and risk profile of the Firm. Smaller, simpler operations may discharge a criterion through commensurately simpler controls; larger or more complex operations may require more elaborate evidence to satisfy the same criterion.
Functional equivalents
Where a control specified in the Standards is not implemented in the precise form described, but the Firm operates a functional equivalent that achieves the same outcome and the equivalent is documented and evidenced, the criterion may be satisfied.
Definitions
Capitalised terms not defined here have the meaning given in the Terms of Service, § 2 and the Methodology, § 2.
Determination of compliance
Each criterion is evaluated as Pass, Conditional, or Fail in accordance with the determination scale in the Methodology, § 7. A pillar Determination is the conjunction of its constituent criteria. The overall Determination is published in the Registry per the Methodology, § 10.
Pillar — GovernanceTIB-IS.1
Structures and records that demonstrate independent oversight of operational decisions and accountability for Material Findings.
Ownership disclosure
Ultimate beneficial owners holding ≥ 25 % are identified and screened against sanctions and adverse-media sources at onboarding and at least annually thereafter.
Evidence: ownership register, screening logs, declarations.
Board composition and oversight
A documented oversight body meets at least quarterly with recorded minutes. At least one member or function provides oversight independent of day-to-day commercial leadership.
Evidence: board terms of reference, minutes for the preceding 12 months, organisation chart.
Conflict-of-interest policy
A written conflict-of-interest policy is in force; a register of declared conflicts is maintained; and annual attestations are obtained from material decision-makers.
Evidence: policy, register, attestations.
Decision records
Material operational decisions — including rule changes, limit changes, counterparty changes, and product launches — are recorded with rationale, decision-maker, and date.
Evidence: decision log for the preceding 12 months.
Control-function independence
Risk and compliance functions report on a basis that does not depend solely on commercial leadership for performance assessment, remuneration, or termination.
Evidence: reporting lines, terms of reference, remuneration governance.
Pillar — Capital & safeguardingTIB-IS.2
Adequacy of capital relative to obligations and protection of funds held on behalf of third parties.
Capital adequacy methodology
A documented methodology sizes capital against the largest plausible drawdown plus 90 days of operating cost. The methodology is reviewed at least annually.
Evidence: methodology document, latest calculation, board approval.
Segregation of participant funds
Where applicable, participant or client funds are held separately from operating funds at regulated institutions and are not used for operating purposes.
Evidence: account statements, segregation policy, custodian confirmations.
Custodian due diligence
Documented due diligence is performed on each custodian or banking partner at onboarding and refreshed at least annually.
Evidence: diligence files, refresh dates, escalation records.
Reconciliation
Reconciliation of internal records to external statements is performed at a frequency appropriate to volume (daily for high volume) and breaks are investigated within a defined SLA.
Evidence: reconciliation logs, break register, SLA document.
Stress testing
Capital position is stress-tested against adverse scenarios at least quarterly. Results are reported to the oversight body.
Evidence: stress scenarios, results, oversight reports.
Pillar — Order handling & executionTIB-IS.3
How orders are received, routed, filled, modified, and closed, and the controls that prevent participant detriment in execution.
Execution policy
A written, versioned execution policy is published and made accessible to participants. Material changes are pre-notified.
Evidence: current policy, version history.
Venue selection
Selection criteria for execution venues, liquidity providers, or counterparties are documented and applied consistently.
Evidence: selection methodology, current panel, change log.
Slippage profile
Slippage is measured, recorded, and disclosable on request. Material divergence between disclosed and observed slippage is investigated.
Evidence: slippage telemetry sample, disclosure document.
Stop-out and forced-close handling
Where automated stop-out, margin call, or forced close logic operates, the methodology is documented, applied consistently, and audit-logged.
Evidence: methodology, sample of triggered events with logs.
Dealing-desk independence
Where the Firm operates a dealing desk against participants, dealing-desk decisions are organisationally separated from risk determinations affecting participant accounts (e.g. account closures, profit invalidation).
Evidence: reporting lines, role definitions, control matrix.
Pillar — Payout integrityTIB-IS.4
How claims by participants on the Firm are documented, adjudicated, and settled — and how the Firm records its performance against its own published policy.
Payout policy
A written, complete, and unambiguous payout policy is published. The policy enumerates grounds for rejection, claw-back conditions (if any), and the dispute pathway.
Evidence: policy document with version and effective date.
Historical payout record
Payout volume and time-to-pay statistics for the preceding 12 months are available. Methodology for calculating time-to-pay is disclosed.
Evidence: payout ledger sample, methodology note.
Rejection grounds
Each rejection is tied to a specific clause of the published payout policy and is supported by retained evidence.
Evidence: rejection register sample with linked policy clauses and supporting evidence.
Dispute handling
A documented dispute pathway with defined SLA exists. Disputes escalated beyond first-level review are heard by personnel not involved in the original rejection.
Evidence: dispute log, SLA document.
Claw-back conditions
If claw-back rights are reserved, they are fully disclosed in the published policy and applied consistently.
Evidence: policy clause, claw-back register (if any).
Pillar — Risk & complianceTIB-IS.5
The framework that keeps operational risk within declared appetite and the controls that meet financial-crime and data-protection expectations.
Risk framework
A documented risk framework defines taxonomy, appetite, limits, and ownership. The framework is approved by the oversight body and reviewed at least annually.
Evidence: framework document, latest approval.
Monitoring and breach escalation
Limits are monitored at a frequency appropriate to risk. Breaches trigger a defined escalation path with recorded outcomes.
Evidence: monitoring artefacts, breach register.
Incident register
Material incidents are logged with root cause, remediation, and lessons-learned. The register is reviewed by the oversight body.
Evidence: register sample, oversight reports.
AML / KYC
Onboarding and ongoing customer due diligence are performed in a manner appropriate to jurisdiction and product. Triggers for enhanced due diligence are documented.
Evidence: AML/KYC policy, sample of onboarded files.
Sanctions screening
Sanctions screening is performed at onboarding and refreshed at a frequency appropriate to risk. Hits are escalated and resolved per documented procedure.
Evidence: screening logs, escalation register.
Data protection posture
Encryption in transit, access controls, and a documented data-retention schedule are in place. A breach-notification process exists and meets jurisdictional timelines.
Evidence: security policy, retention schedule, breach-notification procedure.
Pillar — Disclosure & conductTIB-IS.6
Accuracy of what the Firm tells the public, consistency between disclosure surfaces, and quality of complaint handling.
Marketing accuracy
Public marketing claims are supported by evidence and free of misleading statements. Comparative claims, performance figures, and superlatives are substantiable.
Evidence: marketing material sample, supporting substantiation files.
Terms consistency
Terms, risk disclosures, rule books, and marketing material are mutually consistent. Where the same matter is addressed in multiple documents, the documents do not conflict.
Evidence: consistency review across primary documents.
Complaint handling
A documented complaints procedure with defined response times exists. Complaints are logged, categorised, and reviewed by an appropriate function.
Evidence: procedure, complaints log, periodic review.
Fee transparency
All material fees, charges, and economic conditions are disclosed prior to engagement with the participant and are not subject to undisclosed change.
Evidence: fee schedule, disclosure flow.
Change communication
Material changes to rules, fees, or terms are pre-notified to existing participants with a reasonable effective date and a record of communication.
Evidence: change log, communications sample.
Cross-pillar requirements
Documentation
Where the Standards refer to a "documented" item, the document must be: written, dated, version-controlled, attributable to a named owner, and current at the Effective Date of the verification.
Retention
Evidence of compliance must be retained for the duration of the Firm's Registry listing plus seven (7) years.
Significant changes between reviews
Where a Material change occurs between scheduled re-assessments, the Firm must notify TIB within twenty (20) business days. Failure to notify may itself constitute a Material Finding under TIB-IS.6.E.
Standards updates and changelog
The Standards are reviewed at least annually. Each version is identified by a document code (TIB-IS-x.y) and an Effective Date. Material updates are announced in advance and Engagements in flight at the time of an update continue under the version stated in their Engagement Agreement.
| Version | Effective | Notes |
|---|---|---|
| TIB-IS-1.0 | 16 April 2026 | Initial publication. Six pillars, thirty binding criteria. |
Limitations
The Standards are TIB's own criteria. They are not a regulatory standard, an industry code adopted by any third party, or a substitute for compliance with Applicable Law in any jurisdiction. Conformance with the Standards does not warrant a Firm's overall conduct, future performance, or solvency. Reliance on a Determination is subject to the limitations published in the Legal & Disclosures.
Operating entity
Stratinova LTD
Registration number: HE475207
Jurisdiction: Republic of Cyprus
Archiepiskopou Makariou III 228, Agios Pavlos Building, 3030 Limassol, Cyprus