Due-diligence checklist
Generate a due-diligence questionnaire by jurisdiction × asset class × your role — every item states why it matters, where to check, and what good evidence looks like. Free, no sign-in required.
Scope and limits
This checklist is a compilation of public information. It is not legal, audit or investment advice. Each item links to the official or authoritative source it comes from.
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Entity & licensing (8)
| What is the issuer's legal registered name and entity number?
Why：Name duplication or similarity is a common tactic used by impersonators of licensed entities; the entity number is the unique anchor.
Good evidence：Screenshot or export from the official registry showing name, number, status, and query date.
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| Is the entity licensed or registered with the regulator for the activities required by this project?
Why：Operating without a license is the most direct compliance risk and a definitive gatekeeper for market access.
Good evidence：Screenshot from the regulator’s public register showing license category and validity period.
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| Do the license number, category, and validity period match the claims made in marketing materials?
Why：Marketing often uses ambiguous phrasing such as 'affiliated with a licensed entity'.
Good evidence：Itemized comparison table listing license number, category, and start/end dates of validity.
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| Can the entity be found in the regulator’s publicly searchable directory?
Why：Failure to locate the entity signals high risk and necessitates verification against the primary registry.
Good evidence：URL of search result and timestamp (including exact search term).
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| Are there any regulatory penalties, warnings, or revocation records against the entity?
Why：Historical regulatory actions directly affect assessment of fiduciary responsibility.
Good evidence：Direct links and document numbers for penalty/warning notices, or auditable proof of 'no record' search.
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| Is the entity the same legal person as the actual issuer and operator (e.g., in an SPV structure)?
Why：Unclear liability allocation obstructs recovery pathways in default scenarios.
Good evidence：Structural diagram + registration certificates for each layer, clearly identifying the signatory party.
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| Does this arrangement constitute a regulated activity (Categories 1/4/9) under Hong Kong’s Securities and Futures Ordinance?
Why：Incorrect classification risks unlicensed operation.
Good evidence：SFC Register listing of regulated activity categories + legal opinion or regulatory letter.
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| Is there a legal opinion and regulatory correspondence from the applicable jurisdiction?
Why：Legal opinions are essential for issuing compliance conclusions.
Good evidence：Full legal opinion + regulatory correspondence reference numbers and dates (if any).
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Asset & structure (8)
| What are the underlying assets, and how is legal title defined?
Why：Ambiguous title definition prevents asset segregation in insolvency.
Good evidence：Relevant clauses defining assets and establishing title in offering documents or trust deeds.
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| What is the asset size, denomination currency, and valuation methodology?
Why：Inconsistent valuation methodologies render stated asset sizes misleading.
Good evidence：Valuation policy document + most recent valuation report (including methodology, frequency, and reference date).
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| Are offering documents, term sheets, or prospectuses available?
Why：Projects without formal documents cannot complete desk-based due diligence.
Good evidence：Original PDF files with version number and publication date.
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| What are the investor eligibility requirements (e.g., accredited investors / professional investors)?
Why：Mis-selling due to eligibility mismatch is a frequent cause of regulatory penalties.
Good evidence：Exact eligibility clauses from documents and their applicable legal jurisdiction.
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| What are the redemption and payout terms (e.g., settlement cycle T+n, minimum threshold, suspension conditions)?
Why：Redemption suspension clauses determine the true liquidity risk exposure.
Good evidence：Exact clause text + historical redemption execution records (including longest processing time).
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| How are fees and profit distribution structured (e.g., management fee, performance fee, taxes)?
Why：Fee opacity materially erodes net returns.
Good evidence：Original fee schedule and calculation methodology; third-party verification preferred.
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| Is the arrangement covered under HKMA’s digital bond initiative or Ensemble programme?
Why：Officially endorsed projects have additional publicly verifiable disclosures.
Good evidence：HKMA press release or official programme list with direct link.
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| How are the maturity profile, duration, and interest rate risk of government bonds disclosed?
Why：Duration mismatch is a core risk for money market products.
Good evidence：Holding schedule (maturity distribution, weighted average duration) and valuation date.
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Custody & audit (5)
| Who acts as custodian, and is custody independent or proprietary?
Why：Proprietary custody implies asset commingling risk.
Good evidence：Key pages of custody agreement (custodian name, account type, segregation clauses).
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| Is the custodian licensed or regulated, and by which authority?
Why：An unregulated custodian cannot provide independent third-party evidence.
Good evidence：Custodian license/registration details and name of supervisory authority.
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| Who is the auditor, and what was the opinion type and audit reference date of the most recent audit?
Why：A qualified opinion or prolonged absence of audit is one of the strongest red flags.
Good evidence：Audit report cover page and opinion paragraph (including firm name, signing date, opinion type).
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| Are periodic reserve or asset existence verification reports issued?
Why：Without periodic verification, reported asset size cannot be independently validated.
Good evidence：Link to most recent report, stated frequency (monthly/quarterly), and issuing party.
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| How is bankruptcy remoteness structured (e.g., SPV, trust, or account segregation)?
Why：Failure of segregation may result in commingling of investor rights with originator assets.
Good evidence：Relevant clauses from legal opinion or transaction structure document.
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On-chain & liquidity (5)
| What is the smart contract address and underlying blockchain, and who deployed it?
Why：An incorrect contract address invalidates all subsequent on-chain analysis.
Where：Etherscan ↗
Good evidence：Blockchain explorer page showing chain identifier and deployment transaction hash.
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| Is the contract upgradeable, and are administrative privileges centralized?
Why：Centralized upgradeability creates single-point-of-failure and malicious control risk.
Where：Etherscan ↗
Good evidence：Contract permission list (e.g., owner/minter/pauser addresses and multi-sig status).
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| What are the on-chain market cap, number of holders, and top-10 holders’ combined share?
Why：Excessive concentration increases susceptibility to secondary-market price manipulation.
Where：Etherscan ↗ · Market library →
Good evidence：Blockchain explorer token-holding distribution screenshot + block height and timestamp of data capture.
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| Is the token listed on exchanges? What are the trading pairs and liquidity levels?
Why：Unlisted tokens or those with negligible liquidity impede investor exit.
Where：CoinGecko ↗ · Market library →
Good evidence：Exchange market data page link + 30-day trading volume and depth metrics.
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| Are there transfer restrictions, whitelisting, or freezing mechanisms?
Why：Freezing mechanisms directly impair asset transferability.
Where：Etherscan ↗
Good evidence：Relevant functions in contract source code or corresponding clauses in issuance documents.
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Risk & disputes (5)
| Are there media criticisms, disputes, or litigation involving the project?
Why：Negative information often emerges before official disclosures.
Good evidence：At least two independent sources (original URLs + publication timestamps), plus verification of party responses.
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| Do related parties or entities under common control pose material risks?
Why：Related-party risk is a mandatory element of gatekeeping review.
Good evidence：List of related parties (per statutory register) + documented risk status for each.
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| Has there been a de-pegging event, delayed redemption, or suspension of redemptions?
Why：Historical payment failures are the strongest leading indicators of default.
Where：CoinGecko ↗
Good evidence：Price/redemption timeline + official announcement links.
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| Is there key-person dependency (e.g., core team, technology provider)?
Why：Departure of key personnel or termination of technology support may disrupt operations.
Good evidence：Team and vendor list + publicly available resumes of key personnel.
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| Is there a legal opinion letter, and how are its conclusions and scope of applicability stated?
Why：The assumptions and limitations in the opinion determine its usable scope.
Good evidence：Full opinion letter (focus on assumptions, limitations, governing law, and date).
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Ongoing monitoring (5)
| Is license status monitored for changes (e.g., active → suspended/revoked)?
Why：License changes constitute a critical red-flag requiring immediate response.
Good evidence：Monitoring configuration screenshot + timestamp of most recent check.
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| Are regulatory updates and enforcement actions monitored in relevant jurisdictions?
Why：Regulatory changes may invalidate prior assessments.
Good evidence：Monitoring rule description + sample trigger record.
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| Is on-chain scale monitored for abnormal fluctuations (e.g., ±30% over 7 days)?
Why：Sudden scale changes often precede official announcements.
Where：DefiLlama ↗ · Market library →
Good evidence：Defined monitoring thresholds + at least one triggered alert record.
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| Are reserve reports issued at the promised frequency, and is there an overdue alert mechanism?
Why：Report delays are a frequent risk signal for reserve-backed projects.
Good evidence：Publication schedule + rule for calculating overdue days.
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| Are listing and delisting statuses monitored across exchanges?
Why：Delisting directly impacts liquidity and valuation.
Where：CoinGecko ↗ · Market library →
Good evidence：Cross-check record of exchange tickers (including check date).
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