An insider refers to any individual who belongs to a specific group that develops crypto assets (virtual currency) or is in an environment where they are privy to information which could exert a considerable influence on one’s judgement on crypto assets (virtual currency) trading. To be specific, anyone who meets any of the following eight criteria would be deemed an insider.
bitFlyer’s definition of an insider:
1) Issuer or manager of a crypto assets (virtual currency) handled by bitFlyer *1
2) Company related to someone detailed in 1) *2
3) Major shareholder of 1) or 2) *3
4) Executive of 1) or 2) *4
5) Formerly qualified for 4) within 1 year
6) Married to or cohabitate with someone detailed in 4)
7) Employee of 1) or 2)
8) Main shareholder, executive, or employee of any business involved in crypto assets (virtual currency) *5
Notes:
*1. A list of virtual currencies handled by bitFlyer can be found here.
*2. The term "associated company" means the parent company, subsidiary company, or affiliated company of the company submitting financial statements and, when the company submitting financial statements is the affiliated company of another company, etc., the relevant other company, etc. (referred to as "other associated company."
The term "affiliated company" means when a company, etc. or its subsidiary company is able to exert a material impact on the financial and operational or business policy decisions of another company, etc. that is not a subsidiary company, due to their ties in terms of investment, personnel, funds, technology, transactions, etc., the relevant other Company, etc. that is not a subsidiary company.
*3. Applies to any party holding 10% or more of the stock issued.
*4. Applies to board members, accounting advisors, auditing directors, directors, executives, legal auditor or other corresponding position.
*5. A list of virtual currency exchange operators licensed to operate in Japan can be found here (only available in Japanese).