Created to promote integrity, fairness, and efficiency in digital asset markets, the ADAM Code of Conduct is intended to inform market participants on best practices and to complement, not replace, existing regulation, part of a long-term effort to define and promote ethical conduct by all digital asset market participants.

The Adam


Charles Cascarilla, Paxos
Richard Gorelick, Cumberland
Tim Kelly, BitOoda
James Morgan, Genesis
Richard Rosenblum, GSR
Andrew Siegel, Galaxy Digital
Mark Smith, Symbiont
Brad Vopni, HRT
Oliver Wiener, BTIG
Brice Wilson, XBTO


The Association for Digital Asset Markets (“ADAM”) is a private, non-profit, membership-based association of firms operating in the digital asset markets. ADAM considers itself a “self-governing association.”

ADAM exists to foster fair and orderly digital asset markets where participants can transact with confidence. The development of digital assets, including cryptocurrencies, digital commodities, and digital securities, has the potential to revolutionize financial markets. ADAM works with leading financial firms, entrepreneurs, and regulators to develop industry best practices that facilitate safe, secure, and efficient digital asset markets.


  • To protect market participants from fraud and manipulation.
  • To provide clear standards for efficient trading, custody, and the clearing and settlement of digital assets.
  • To encourage professionalism and ethical conduct by market participants.
  • To increase transparency and provide information to the public and governments about digital asset markets.

ADAM was not created to replace or circumvent regulation. Rather, ADAM exists to enable industry to pave the way toward fair and orderly digital asset markets by complementing existing laws and regulation.

ADAM has released a principles-based Code of Conduct (the “Code”). All members plan to sign the Code in early 2020 and adhere to its principles. The Code sets standards of professional conduct and covers the following areas:

  • Compliance and Risk Management
  • Market Ethics
  • Conflicts of Interest
  • Transparency and Fairness
  • Market Integrity
  • Custody
  • Information Security and Business Continuity
  • Anti-Money Laundering and Countering the Finance of Terrorism

ADAM intends to update and improve the Code periodically, and will continuously consult with industry participants, current and former regulators and lawmakers, legal and compliance experts, and academics.

ADAM serves as an information exchange for industry participants, regulators, lawmakers, technologists, and others. ADAM can effectively and efficiently inform its membership of topical issues and its members also can serve as a valuable resource to industry participants or others seeking information about digital asset markets. To that end, ADAM intends to build and maintain strong relationships with a wide range of stakeholders both inside and outside the US in order to learn, share ideas, and coordinate on research, awareness initiatives, or other efforts.

ADAM is not an advocacy organization, has not registered as a lobbying organization, and does not intend to influence policy-making.

In mid-2018, a group of firms socialized the idea of forming an industry group to promote more ethical conduct and professionalism with respect to their engagement in the digital assets industry. Those firms, most of which had participated in “traditional” equities and commodities markets in the US, believed that by organizing together and leading by example, they could create a roadmap on how best to apply existing laws and regulations to activities in digital assets and, importantly, how to adopt additional standards of conduct and best practices in areas of regulatory uncertainty in order to boost digital asset market integrity.

ADAM’s ten founding members began work on our mission and goals, and formed Association for Digital Asset Markets, Inc. on October 24, 2018 as a non-profit under IRC Section 501(C)(6). ADAM formally announced its launch in November 2018 with its ten founding members:

  • BitOoda
  • BTIG
  • Cumberland
  • Galaxy Digital
  • Genesis
  • GSR
  • Hudson River Trading
  • Paxos
  • Symbiont
  • XBTO

On November 12, 2019, ADAM publicly released its Code of Conduct and announced that members plan to sign the Code in early 2020.

*This information is current as of Q4 2020