ABC VASP is launching a referral programme to acquire new customers in the Emirate, after receiving a VARA Licence for providing Exchange Services. The programme allows existing users to share referral codes with any person, with no maximum number of referrals. Once a person signs up with ABC VASP the referrer gets a fixed percentage of trading fees generated by users that sign up using their referral code.
 

ABC VASP is also launching its own NFT marketplace. To attract users, it has announced that users who sign up in the next month will be gifted a free, non-tradeable NFT as a digital collectible commemorating the launch of the marketplace.
 

In its Marketing campaign for the NFT marketplace, ABC VASP has focused on promoting its low fees and policy on royalties (i.e. features of the platform).
 

An example of ABC VASP’s Marketing of the new NFT marketplace is shown below.
 

Figure (15): Social media post by ABC VASP
 

COMPLIANT: Free, non-tradeable NFTs are unlikely to divert investors’ focus from considering the risks associated with using the NFT marketplace.
 

The free non-tradeable NFT for early users qualifies as a non-monetary incentive used in the Marketing of ABC VASP. Monetary and non-monetary incentives are subject to requirements in Marketing Regulation I.C.2.l.
 

As the NFT in this specific instance is minted for commemorative purposes only and has a negligible economic value as it cannot be traded, this giveaway is unlikely to divert potential users’ focus from the proper consideration of the risks associated with using the NFT marketplace or trading NFTs as a whole. The NFT giveaway is therefore a compliant form of non-monetary incentive used in Marketing.