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9Squid Private Markets is a separate legal entity from the 9Squid platform business. It facilitates secondary transfers of deal positions between pre-qualified investors on eligible deals.
Note: 9Squid Private Markets’ FINRA broker-dealer registration is currently pending. Additional documentation will be published once registration is complete.

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Overview

Secondary liquidity is optional and available only where the deal structure, offering memorandum, and transfer restrictions explicitly permit it. Not all deals support secondary transfers. When available, investors can transfer their positions to other pre-qualified investors via the 9Squid Private Markets venue.

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Eligibility Requirements

All secondary transfers are subject to:
  • Deal-specific transfer restrictions — defined in the offering memorandum and enforced in the smart contract
  • Investor eligibility — the receiving investor must meet the deal’s eligibility rules (e.g. QIB-only, US-only), verified via the Compliance Registry
  • Securities law restrictions — applicable transfer rules under 144A, Reg D 506(c), Reg S, or intra-CU network
  • KYC/AML/OFAC screening — both sides of every trade are screened
  • Transfer agent records — the transfer agent must clear the receiving investor before recording the position transfer

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How It Works

  1. Seller initiates a transfer request via the 9Squid webapp or API
  2. 9Squid Private Markets verifies eligibility of the receiving investor against deal rules and the Compliance Registry
  3. Smart contract checks the Compliance Registry — rejects if the receiving wallet is not eligible
  4. Transfer agent records the book-entry position transfer
  5. Settlement occurs on the permissioned ledger; XRPL bridge available where configured

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Compliance

9Squid Private Markets does not provide investment advice, recommendations, or solicit investment decisions. It is a venue for qualified investors to transfer positions they already hold. Changes in investor eligibility status (e.g. no longer accredited) that affect secondary trading ability must be reported immediately to compliance@9squid.com.

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Contacts