Insider trading compliance solutions.
Purpose-built for crypto.
Manage trading plans for token holders with material non-public information, from plan implementation to OTC desk integrations and regulatory reporting.
Why do leading crypto companies choose Toku?
Toku Token Grant Administration platform makes it easy to launch a token and manage token allocations for team, investors and the ecosystem.
By integrating trading plans into token grant administration, we help token holders with material non-public information adhere to insider trading laws and project's policies while liquidating their allocations. Without structured trading plans, insiders risk violating insider trading laws, exposing themselves and the project to regulatory scrutiny.
Toku integrates directly with top-tier OTC desks, enabling compliant liquidity access while safeguarding against regulatory pitfalls.
With Toku, you get
Trading plan implementation
Custom trading plans aligned with compliance requirements
Custom plan parameters, including cooling-off periods, liquidation triggers, and plan dates
Regulatory consultation for seamless execution with our legal partners
Plan tracking & approvals
Plan tracking dashboard
Customizable workflows for plan review, sign-off and execution
Ongoing monitoring and compliance verification
OTC desk integrations
Access to top OTC trading desks
Tracking system to ensure that every transaction adheres to pre-approved trading plan parameters
Seamless end-to-end execution
Regulatory reporting & compliance
Pre-filled, audit-ready reports, fillings and disclosures
Direct integrations with payroll for tax withholding compliance
Reporting dashboard for admins to oversee plans and their adherence to internal policies
FAQs
Toku ensures that token holders with material non-public information (MNPI)—such as founders, executives, core team members, and advisors—can sell their tokens legally and without risk of insider trading violations.
We do this by setting up structured, pre-approved trading plans (similar to SEC 10b5-1 plans for equities) that remove any discretionary decision-making from the selling process. Instead of making ad hoc decisions on when to sell, token holders set up a pre-determined, automated selling schedule when they are not in possession of MNPI. Once the plan is in place, sales happen automatically according to the preset schedule, ensuring they are compliant with regulations.
A structured trading plan is essential for token holders navigating regulatory scrutiny, insider trading risks, and market stability concerns. Without a pre-approved plan, insiders risk legal exposure, market disruptions, and reputational damage when selling tokens.
By eliminating discretionary decision-making, structured plans ensure token sales follow a pre-set, rules-based schedule, mitigating insider trading risks and aligning with SEC and CFTC compliance standards. They also enhance market confidence, by preventing unstructured sales that flood liquidity, drive down token prices, and create volatility. A structured plan mitigates this risk by ensuring orderly, strategic execution, particularly through OTC desks, minimizing price impact and liquidity disruptions.
Exchanges are increasingly requiring trading plans for insiders as a prerequisite for listing to ensure compliance and protect market integrity. As regulatory clarity and enforcement continues to evolve, having a structured plan in place future-proofs your compliance posture, aligns it with institutional best practices, and strengthens your project's credibility with exchanges and regulators.
Traditional SEC Rule 10b5-1 plans apply specifically to publicly traded equities and other securities regulated under U.S. securities laws. Since tokens aren't universally classified as securities, they don’t automatically fall under the 10b5-1 framework or receive its legal protections.
However, insider trading laws still apply, meaning founders, executives, and advisors with material non-public information (MNPI) must take steps to ensure their token sales are compliant. Toku’s 10b5-1-like plans help mitigate insider trading risks by following key principles of traditional 10b5-1 plans, including pre-approved, non-discretionary trading schedules and OTC desk integrations to minimize market impact.
We recommend that token holders consult with legal counsel to ensure their trading plans align with the appropriate regulatory requirements for their jurisdiction and individual circumstances.
Toku provides direct integrations with multiple top-tier OTC trading desks, allowing token holders to access liquidity in a structured and compliant manner. Toku is not a broker and does not execute transactions. Instead, it enables token holders to engage with OTC desks while ensuring sales follow pre-approved structured trading plans that align with regulatory requirements and project's insider trading policies.
For the most up-to-date list of OTC desks we integrate with, please reach out to team@toku.com.
Whether you're a token holder looking to stay compliant while liquidating your allocation or you want to explore Toku’s infrastructure for structured trading plan on behalf of the project, we’re here to help. Contact team@toku.com to learn more.