{"id":"court_sdny_654_7","court":"SDNY","case_no":"23-cr-00118","doc_number":654,"sub_number":7,"doc_type":"EXHIBIT","filed_date":"2025-04-07","title":"EXHIBIT G ![](_page_2_Picture_1.jpeg)","summary_zh":null,"summary_en":null,"body_en":"# **EXHIBIT G**\n\n![](_page_2_Picture_1.jpeg)\n\n### **Overview.**\n\n**Hamilton Investment Management Limited** (\"Hamilton\") is a technology-focused, value-driven investment management firm serving world-renowned institutional investors who invest in a broad spectrum of asset classes. Hamilton adopts a sophisticated, multi-strategy approach to investing to generate an optimal risk-return profile. This ensures that the most compelling investment opportunities are captured across diverse investment products and geographical markets.\n\n**The Hamilton** Opportunity Fund SPC is designed to connect traditional finance with the digital assets market, while maintaining market leading standards present in the crypto industry.\n\n![](_page_3_Picture_1.jpeg)\n\n**The Hamilton Opportunity Fund SPC** is created with institutional clients in mind. We provide institutional quality exposure to cryptocurrency assets for corporate investors. Built on a foundation of valuable resources and global relationships, we leverage unrivalled capabilities to manage capital for the most prestigious global institutional investors.\n\nOur dedicated team is made up of senior professionals with diverse skill sets who work together to ensure the seamless execution of every single transaction and investment, bridging the gap between traditional finance and the emerging crypto landscape. Our combined expertise across a multitude of asset classes, industry segments and markets, positions us to analyse, value and support our investments in the face of a complex set of industry dynamics.\n\n![](_page_4_Picture_1.jpeg)\n\n**Our objective** is to provide institutional investors access to a range of digital assets, which affords them peace of mind in terms of safety, security, custody, diversification and optimal risk-return profiles of investment products.\n\n**The team** is comprised of ambitious individuals who have previously worked at some of the world's most respected institutions including global investment banks (Macquarie, Goldman Sachs, Bank of America, Mizuho), and asset managers (Vanguard and Rothesay). Years of invaluable experience reassure our investors with the confidence they need to partner with us.\n\nOur crypto investment products are paired with capital preservation and operational expertise, designed for the investor who is seeking new opportunities to enhance their portfolio.\n\n![](_page_5_Picture_0.jpeg)\n\n**Hamilton Team**'s DNA combines decades of industry acumen and investment experience at the top Wall Street banks and global hedge funds.\n\n![](_page_5_Picture_3.jpeg)\n\n![](_page_6_Picture_0.jpeg)\n\n# **\"Crypto** Assets Act As A Hedge Against Macroeconomic Uncertainty\".\n\n![](_page_7_Picture_0.jpeg)\n\nIn a global economic climate characterised by heightened volatility and macroeconomic uncertainty, **change** is the only constant. Crypto assets act as a hedge against macro-economic unpredictability, while also offering diversification against traditional asset classes.\n\nThis asset class goes **beyond a store of value**, to serve as a means of payment, and an appreciating (but volatile) asset over time.\n\nThey hold the ability to disrupt the current traditional slower moving legacy financial system.\n\nOver time money has evolved from barter systems to structures backed by commodities (Eg. Gold), to the current free-floating system of exchange rates. We recognise **blockchain technology and cryptocurrencies to be the next significant phase in the evolution of money.**\n\nWith the total market capitalization of **bitcoin now exceeding the USD \\$1 trillion dollar mark**, this milestone makes digital assets a lucrative investment for the world's largest asset managers.\n\nThey offer **Asymmetrical Payoffs**. The fixed supply of bitcoin (21m coins), coupled with increasing institutional demand and broader acceptance of cryptocurrencies has cultivated an exciting and unique landscape for digital assets.\n\n![](_page_8_Picture_0.jpeg)\n\n### **The Institutionalization Of The Crypto Landscape.**\n\nSome of the world's largest and most respected institutions are finally realising the prominence of cryptocurrencies within the wider financial sphere and have started to invest.\n\n![](_page_8_Picture_4.jpeg)\n\nAmassed close to **~100K BTC**  (worth **over USD \\$5b** at current market rates).\n\nOffering institutional client's **direct access to Bitcoin funds**.\n\n**Launching a crypto basket** offering clients crypto exposure.\n\nVISA\n\nTo enable **Bitcoin purchases** and integrate Bitcoin within their network.\n\nAt Hamilton we believe **this is just the tip of the iceberg** and as more institutions will follow, we give investors the capability to invest and gain exposure to crypto with our fund offerings.\n\n![](_page_9_Picture_1.jpeg)\n\n## **Cryptocurrency Market Cap (USD \\$).**\n\nThe global crypto market cap is \\$1.8Trillion. This chart shows the historical data of global market capitalisation. The total market cap parameter is calculated by collectively summarising the market capitalisations of all cryptocurrencies in USD.\n\n![](_page_9_Figure_4.jpeg)\n\n# **Total Market Capitalisation Dominance (%).**\n\nThis chart displays historical data on percentages of the total market capitalisation of the most popular cryptocurrencies. Here the market dominance of cryptocurrencies such as Bitcoin (BTC), Ethereum (ETH), XRP, Bitcoin Cash (BCH), Litecoin (LTC), EOS and others are presented.\n\n![](_page_10_Figure_4.jpeg)\n\n**Crypto does not correlate with other asset classes**.\n\nThe unique characteristics demonstrated by crypto assets means investors can capture potential growth while limiting overall portfolio risk..\n\n|                                                                      | Bitcoin | Ethereum | EOS | TRON |\n|----------------------------------------------------------------------|---------|----------|-----|------|\n| S&P 500                                                              | 8%      | 10%      | 4%  | 11%  |\n| Gold                                                                 | 4%      | 8%       | 5%  | 0%   |\n| Silver                                                               | 0%      | 8%       | 8%  | -2%  |\n| Image: [Three upward triangles] BLOK Image: [Three upward triangles] | 26%     | 28%      | 21% | 20%  |\n| Russell 2000                                                         | 9%      | 10%      | 5%  | 13%  |\n| Real Estate                                                          | -1%     | -2%      | -1% | 0%   |\n| Bond Market                                                          | -6%     | -7%      | -3% | -10% |\n\n-\n-\n-\n\n-\n-\n\n![](_page_11_Figure_12.jpeg)\n\n![](_page_12_Picture_0.jpeg)\n\n### **Efficient Frontier, Optimised.**\n\nModern Portfolio Theory considers returns, volatilities, and correlations of assets, and attempts to allocate different **combinations** of each type to **mitigate** overall portfolio risk.\n\nAn '**efficient frontier**' of portfolios can be built, where returns are optimised per unit of risk.\n\nAs we've seen the crypto asset class is **uncorrelated** to other asset classes, and thus can provide a diversification benefit.\n\nAs a result, we believe that the efficient frontier will lead to **expansion**, once crypto assets are included in the portfolio of investments.\n\n![](_page_12_Figure_7.jpeg)\n\n![](_page_13_Picture_0.jpeg)\n\n### **Crypto Trading Challenges.**\n\n![](_page_13_Figure_3.jpeg)\n\n# **Hamilton Opportunity Fund SPC provides a solution.**\n\nHamilton offers a holistic asset management solution that covers the lifecycle of your crypto investment.\n\nIt includes a fully developed:\n\n- Order Execution Management System **(OEMS)**\n- Portfolio Management System **(PMS)**\n- Risk Management System **(RMS)**\n- Advanced Suite of Sophisticated Trading Algorithms **(ALGO)**\n- Real-Time and Historical P&L and Exposure Tracking System **(Reporting/Compliance)**\n\nHamilton provides an integrated network into all major crypto exchanges.\n\n![](_page_14_Figure_10.jpeg)\n\n![](_page_15_Picture_0.jpeg)\n\n### **Our Solution.**\n\n![](_page_15_Figure_3.jpeg)\n\n![](_page_16_Picture_0.jpeg)\n\n## **Algorithmic Trading and Technology – Paradigm Overview.**\n\nCutting-edge technology is central to our ideology. We define ourselves as a data-driven firm that utilises technology to optimise investment management systems. We strongly believe in the automation of ideas, scientific research and embracing technology to help us achieve our trading objectives. However, we retain the human element and consistently investigate and question our approach to investing. We apply data analysis and sound judgement to tackle some of the world's most complex investment management challenges.\n\nWe are a team of traders, engineers, scientists / researchers and technologists that work collectively towards a common goal – putting capital to work in the most **efficient and optimal means possible**. By taking calculated risks, we aim to consistently generate alpha for our clients in the crypto space across all market conditions in a very **disciplined, scientific and research-oriented approach**.\n\n![](_page_17_Picture_0.jpeg)\n\n### **Algorithmic Trading Techniques.**\n\nTechniques we aim to apply over time include, but not limited to:\n\n![](_page_17_Figure_4.jpeg)\n\n#### **Algorithmic Trading Techniques.**\n\nOur trading team has been forefront of trading traditional asset classes with diverse backgrounds spanning **Equites**, **Fixed Income**, **FX** and **Commodities**. We have ported over this wealth of knowledge into the crypto space with the objective to provide a range of investment products to institutional investors.\n\n![](_page_17_Figure_7.jpeg)\n\n![](_page_18_Picture_0.jpeg)\n\n### **Machine Learning (ML) And Artificial Intelligence (AI).**\n\nThe team is dedicated to keeping abreast and embracing the latest advancements to utilize some of the most sophisticated research techniques in academia.\n\nWe don't blindly adopt these approaches – on the contrary, we apply rigorous scientific research to enhance the knowledge and experience we have gained to aid our investment approach and test our hypotheses.\n\nWe don't segregate the human and machine element but recognise the power in blending the two worlds. At our foundation we make sure that we understand our models and discern the logic behind the research.\n\n### ML And AI Techniques\n\n![](_page_18_Figure_7.jpeg)\n\n![](_page_19_Picture_0.jpeg)\n\n**3**\n\n# **Machine Learning (ML) & Artificial Intelligence (AI).**\n\n#### **Example Hamilton Fund AI Use Case:**\n\n![](_page_19_Picture_4.jpeg)\n\nHamilton has developed our own Machine Learning Natural Language Processing Algorithm, which includes a document parser to produce structured data in the form of machine-readable language. Algorithms and historical baselines have been built to generate Alpha and actionable Market Intelligence.\n\n**2**\n\nThe algorithm uses a multi-pass approach combining techniques like stemming and lemmatisation to achieve unparalled results. The learning environment is both supervised and unsupervised and uses programmatic regression analysis.\n\n**4**\n\nIt is not just what is being said in Traditional and Social Media, it is who is saying it. Hamilton has engineered a twelve-factor algorithm to score each source before inclusions in sentiment and volume metrics. The ability to eliminate spam and bad actors produces a pure data set to enhance trading signals.\n\nAt Hamilton we employ the use of the latest AI techniques to support our advanced Quantitative Trading strategies across the Crypto Asset class, Market Making, Algorithmic Execution, Asset Management, TCA, Risk, Research and Market Intelligence.\n\n![](_page_20_Picture_0.jpeg)\n\n**The Hamilton Opportunity Fund** specialises in products catered for the digital asset class. The fund employs a multi-strategy approach that focuses on both discretionary and systematic strategies. Alpha-oriented signals are researched, and trading strategies are built around these signals in a variety of cryptocurrencies.\n\nThe objective of the fund is to offer investment products that **optimise risk**  and **return utilising modern portfolio theory** and **active risk management**. We aim to run discretionary and quantitative algorithmic trading strategies to cater for different investor paradigms.\n\n![](_page_20_Figure_4.jpeg)\n\n![](_page_21_Picture_0.jpeg)\n\n#### **Himalaya Digital Asset Fund.** A Passive Investment Strategy.\n\nThe Himalaya Digital Asset SPC Fund is a buy and hold fund that is open to investors. Key characteristics of the fund include:\n\n![](_page_21_Picture_4.jpeg)\n\nWe have acquired powerful insights into the fundamentals and economic value of crypto assets, which enables us to accurately discern the valuations and price action of crypto assets. There is no shortage of new coins/projects entering the crypto space. As a result of the saturated scene, we are highly selective of the projects that we choose to invest in. After prudent consideration, we then leverage our broad network to continue to generate significant returns.\n\nWe have realised the potential of the **Himalaya Coin** and invested **100% of the AUM** in the Himalaya Digital Asset SPC into this project. Our size and network has led to secure allocations of the Himalaya coin at Strategic investor rounds which is not available to retail investors.\n\nThe Himalaya **HDO** and **HCN** coins are designed to form part of an ecosystem that includes an exchange trading platform and a payment platform, connecting merchants and users to a payment infrastructure. These coins are at the core of the ecosystem and enable our clients to interact within the Himalaya network.\n\n![](_page_22_Picture_0.jpeg)\n\n### **HDO Himalaya Dollar**\n\nThe Himalaya Dollar (HDO) has been designed to act as the new kind of digital infrastructure, built on a foundation solid enough to eliminate the inadequacies built into existing offering, with the goal of facilitating mass adoption. The Himalaya Dollar is a stable coin, pegged to the United States dollar, and supported 1-to-1 by a reserve of U.S. dollars [and U.S. Dollar denominated high quality liquid assets] deposited with regulated financial institutions (the \"Reserve\").\n\nThe definitive product is an evolved cryptocurrency designed to provide stability, liquidity, convenience and confidence to consumers and investors through a framework of transparency, regulatory compliance and network integrity, that is aligned with those of leading financial institutions.\n\nThe Himalaya Dollar will be issued through the Himalaya Exchange, transactions will be facilitated using hybrid blockchain technology, which combines the Ethereum and Quorum Blockchains.\n\n### **HCN Himalaya Coin**\n\nThe Himalaya Coin (HCN) is an ERC20 token created to be used on the Himalaya Pay ecosystem. HCN tokens holders will be provided with access to limited edition items, exclusive offerings, as well as premium merchant products and services which can be accessed through the Himalaya Pay App.\n\nHimalaya Coin is set to change the way we spend in store and online. Real world vendors will accept HCN positioning it as digital money for everyday use. Their instant transaction time and low fees makes Himalaya Coin a preferred method of payment.\n\nThe HCN will also support charities, actions, development, and new projects for the Himalaya Ecosystem.\n\n![](_page_23_Picture_0.jpeg)\n\n### **Himalaya Coin Solution.**\n\nHimalaya Coin is on a mission to revolutionise the blockchain payment industry. The concept driving the HCN is to help alleviate the current issues existing within the private capital industry. By establishing a liquid marketplace, the Himalaya Coin will:\n\n- reduce lock up of capital and mobilise capital by improving its velocity;\n- open different asset classes to a broader global investor base represented by both institutions and individuals;\n- enhance transparency and competitiveness in the private capital industry; and\n- as a result, improve the availability of capital for entrepreneurs.\n\n![](_page_23_Figure_8.jpeg)\n\nWith secondary market liquidity, the Himalaya Coin is introducing a new \"**Digital Asset Class**\". This advanced category has a better risk and yield profile compared to direct investments in start-ups or Venture Capital funds, as in a traditional limited partner model.\n\n![](_page_24_Picture_0.jpeg)\n\n### **Himalaya Coin.**\n\n#### PRINCIPAL **FUNCTIONALITIES**\n\n#### TRADING ON **THE HIMALAYA EXCHANGE**\n\nOn the Himalaya Exchange HCN Credits will be issued on, and fully transferable, through the Himalaya Exchange, enabling members to freely trade HCN Credits for other cryptocurrency Credits available on the Himalaya Exchange.\n\n#### HIMALAYA PAY **APP**\n\nMembers can use the Himalaya Pay App, a dedicated mobile payment application, to make fast and secure purchases using HCN Credits from merchants in the Himalaya Ecosystem, including new and established brands, who it is anticipated will provide access to products and services to HCN Credit holders.\n\n#### HIMALAYA EXCHANG **AWEBSITE & APP**\n\n![](_page_24_Picture_10.jpeg)\n\nThrough the Himalaya Exchange App users will be able to access the Himalaya Exchange trading platform to purchase, exchange and trade HCN Credits.\n\n| TOKEN NAME           | HIMALAYA COIN                 |\n|----------------------|-------------------------------|\n| TOKEN TICKER         | HCN                           |\n| ISSUER JURISDICTION  | BRITISH VIRGIN                |\n| INITIAL ISSUE DATE   | 22 APRIL 2021                 |\n| INITIAL ISSUE PRICE  | 0.10 HIMALAYA<br>U.S. DOLLARS |\n| ACCEPTED PAYMENT     | U.S. DOLLARS<br>DOLLAR CREDIT |\n| HCN INITIAL ISSUANCE | 1,000,000,000                 |\n\n#### PRINCIPAL **BENEFITS**\n\n![](_page_24_Figure_14.jpeg)\n\n![](_page_24_Picture_15.jpeg)\n\n#### TRANSPARENCY & **SECURITY**\n\nA transparent asset benefitting from a robust and secure platform.\n\n![](_page_24_Picture_18.jpeg)\n\n**LIQUIDITY** Access to a liquid market with Credits\n\ncorresponding to a range of digital assets.\n\n![](_page_25_Picture_0.jpeg)\n\n#### **Himalaya Digital Asset SPC Fund.** A Passive Investment Strategy.\n\nOver the coming months, we will be launching several more cryptocurrency strategies, that will be available as separate investable sub funds.\n\n**Initially we will introduce a BTC and ETH fund, as these two coins represent the leaders in terms of blockchain technology, liquidity and market capitalisation.**\n\nObtaining crypto exposure can be daunting even for the most experienced investors. We offer institutional grade execution, custody and security that assures our clients that they can rely on our expertise to navigate through the intricacies of crypto investments. Our products facilitate a smooth initiation into the world of crypto, for just a small fee.\n\n![](_page_25_Figure_6.jpeg)\n\n![](_page_26_Picture_0.jpeg)\n\n# \"We Remove The Barriers Of Investing In Crypto.\"\n\n![](_page_27_Picture_0.jpeg)\n\n![](_page_27_Picture_2.jpeg)\n\nEase of Investment\n\n![](_page_27_Picture_4.jpeg)\n\nCompliance & Tax\n\n![](_page_27_Picture_6.jpeg)\n\nResearch Trading\n\n![](_page_27_Picture_8.jpeg)\n\nTrading\n\n![](_page_27_Figure_10.jpeg)\n\nExperience Hedging Reporting Security\n\n![](_page_27_Picture_12.jpeg)\n\nHedging\n\n![](_page_27_Picture_14.jpeg)\n\n![](_page_27_Picture_15.jpeg)\n\n![](_page_27_Picture_16.jpeg)\n\nSecurity\n\n![](_page_28_Picture_0.jpeg)\n\n### **Secure Custody.**\n\nAt Hamilton the security of assets is of paramount importance. This is where our **award-winning custody** solution comes in.\n\n![](_page_28_Picture_4.jpeg)\n\n**Secure Custody**\n\n- ✓ MPC protected custodial architecture.\n- ✓ Cold, warm, hot & proxy layers supported.\n- ✓ No single point of failure.\n\n#### Protection against:\n\n- ✓ Employee Theft\n- ✓ Third-party Computer Crime\n- ✓ Funds Transfer Fraud\n- ✓ Cyber Losses (Crime through fraud/theft, viruses, hacking)\n- ✓ Property loss (relevant to the assets) within Hamilton premises & transit\n\n![](_page_28_Picture_15.jpeg)\n\n#### **Connected Trading**\n\n- ✓ Trade out of cold storage with ClearLoop.\n- ✓ Move assets instantly between 30+ top-tier exchanges.\n- ✓ Tight spreads directly through API enabled eOTC RFQ or streaming.\n\n![](_page_28_Picture_20.jpeg)\n\n#### **Audited, Certified & Insured**\n\n- ✓ FinCEN & FCA registered Money Services Business.\n- ✓ ISO 27001 and Cyber Essential Plus certified & registered.\n- ✓ Aon brokered Crime insurance policy.\n\n![](_page_28_Picture_25.jpeg)\n\nOur insurance is based on a Crime policy and protects against threats to/on our infrastructure. This policy doesn't cover assets on third-party/other infrastructure where the risk is not something we can control or manage. The cost of the premium is retained by Hamilton, and not passed onto Clients. If Clients would ever wish to increase the policy limit, an excess layer can ben arranged for the Client directly through AON.\n\n![](_page_29_Picture_0.jpeg)\n\n### **ASSET SECURITY OPTIONS.**\n\n![](_page_29_Picture_3.jpeg)\n\n**Hot Wallet**\n\nAccessible via an online server.\nAn agile, easy and convenient\noption for trading.\n\nVulnerable to the most frequent\ntype of threat, a network attack.\n\nNo control over the key\n\nPrivate keys are stored on a user's physical device, such as a laptop, mobile or PC.\nRisk of losing or compromising the device.\n\nMalware attacks as the device remains connected to the internet.\n\nKey shares are created simultaneously and in isolation. By using MPC crytography, these shards allow transactions to be signed online without disclosing the underlying private key.\n\nMinimizes the risk to the quality of the fundamental cryptographic protocols.\n\n**HSM (Hardware**\n**Security Module)**\n\nPrivate keys are stored on a dedicated device, architected to perform specific functions, primarily signing transactions.\n\nRequires a highly secure environment and a controlling person/entity, meaning a single point of failure.\n\n## Key Sharing\n\nPrivate keys are split into parts, encryptpted and distributed to different parties and/or locations.\n\nAn advanced method, yet remains a single point of failure during the signing process.\n\nPrivate Key Management – Mitigating Single Point of Failure. Hamilton has adopted the Gold Standard of Private key Cryptography Security. We use a Multi Person Computation (MPC) approach to private key encryption.\n\n![](_page_30_Picture_0.jpeg)\n\n#### **Logic of Private Key Sharding**\n\nPrivate keys are fragmented into shares, encrypted and divided among various parties.\n\nWith key sharding in place, for a potential hacker to capture a user's wallet, they would need to attack: several organisations, multiple platforms and multiple locations simultaneously.\n\n![](_page_30_Figure_5.jpeg)\n\n![](_page_31_Picture_0.jpeg)\n\n▷ (t, n) Secret Sharing\n\n-\n-\n\n✓Using  $t-1$  degree random polynomial with random coefficient\n\n(Step 1. Polynomial construction ) A dealer selects a secret,  $K$  (<  $p$  : prime) as a constant term and  $t-1$  degree random polynomial with arbitrary coefficients as :\n\n$$F(x) = K + a\\_1x + a\\_2x^2 + \\dots + a\\_{k-1}x^{t-1} \\bmod p$$\n\n$$K = \\sum\\_{j \\in \\Lambda} K\\_j \\lambda\\_{j,\\Lambda} \\bmod p, \\quad \\text{where} \\quad \\lambda\\_{j,\\Lambda} = \\prod\\_{l \\in \\Lambda \\setminus \\{j\\}} \\frac{l}{l-j}$$\n\n![](_page_31_Figure_12.jpeg)\n\nAny 2 of 3 points combined deterministically define the underlying functions.\n\n#### Maths Algorithm of **Private Key Sharding**:\n\n- Shamir's Secret Sharing scheme is an algorithm that was first proposed in 1979 by the renowned Israeli cryptographer Adi Shamir.\n- It allows for information to be broken into many shares, while only requiring a fraction of those shares to reconstruct the original secret.\n- This means that, instead of requiring all shares to reconstruct the original secret, Shamir's scheme requires a minimum number of shares — this minimum is referred to as the threshold.\n\n![](_page_32_Picture_0.jpeg)\n\n## **Secure Multi Party Computation (MPC).**\n\n- Each party controls a share of the key rather than the full key\n- Parties complete their part of the signature algorithm in a sequence\n- Key shares are never revealed between participating parties\n- To reach the highest degree of security, the full private key is never assembled on any server.\n\n![](_page_32_Figure_7.jpeg)\n\nIndependent Fund\nAdministrator\n\n![](_page_33_Picture_1.jpeg)\n\n# **To access the entire market safely, build a Walled Garden.**\n\n- Identity of participating exchanges is transparent.\n- All authorised addresses are whitelisted by the participating exchanges.\n- Any attempt to send funds outside the Walled Garden triggers a multi signature approval procedure.\n\n![](_page_33_Figure_6.jpeg)\n\n![](_page_34_Picture_0.jpeg)\n\n# **Off Exchange Settlement.**\n\n- The fund's assets are held by the independent custodian in an MPC vault.\n- An exchange of capital is assigned to this venue, advised by the custodian.\n- P&L can be settled continually on a realtime basis.\n- In the case of exchange failure, there is zero counterparty risk.\n- Crypto Assets are stored offline in a vault and virtual balances are held on various exchanges. Trades are then settled daily with the custodian.\n\n![](_page_34_Figure_8.jpeg)\n\n![](_page_35_Picture_0.jpeg)\n\n![](_page_35_Figure_2.jpeg)\n\n**The Fund always controls the fiat or crypto currency accounts.**\n\nAll exchange and bank accounts are held in the name of Hamilton fund. Hamilton holds the security credentials of the exchanges, and the administrator holds the exchange 2FA token.\n\nThe investment manager requests the transfer, but it is only executed by Hamilton Custodian Account or the fund administrator. The investment manager does not have direct access to any fiat or crypto funds.\n\n![](_page_36_Picture_0.jpeg)\n\n# **Inter-exchange safeguarding.**\n\nWalled Garden.\n\nBy using a Fund's exchange APIs and the Hamilton Platform for portfolio management, Hamilton can construct a Walled Garden where it offers custody, and connection to various exchanges to facilitate trading and liquidity.\n\nAs an additional layer of security, Fund Administrators retain Read-Only access to prepare and preserve visibility of balances.\n\nTo ensure Digital Assets never leave the Walled Garden, a 3rd party is entrusted with Multi-signature authorisation.\n\n![](_page_36_Figure_7.jpeg)\n\nWe recognised the lack of infrastructure serving institutional investors who need highly secure access to digital assets. Hamilton Fund was established to address this shortcoming.\n\n#### **HAMILTON**\n\n#### **DIGITAL ASSET CUSTODY.**\n\nHamilton has access to a pioneering blockchain agnostic system that employs distributed keys to allow access and grant permission to transactions generated from a Hamilton Platform wallet. The application functions entirely offline, in a key-less and server-less environment, assuring maximum security for digital assets.\n\n#### **HAMILTON PLATFORM DIGITAL ASSET ACQUISITION.**\n\nTo support institutional investors, a portfolio management and trading platform has been set up by integrating multiple-user logins and multiple trading account creation for teams. To facilitate even greater liquidity, Trading APIs with multiple exchanges are in place with the added protection of Hamilton secure custody vaults.\n\n#### **HAMILTON WALLED GARDEN**\n\n#### **DIGITAL ASSET PRIME BROKERAGE.**\n\nDeploying the Fund's exchange APIs and the Hamilton Platform for portfolio management, Hamilton can establish a Walled Garden that provides custody and facilitates trading and liquidity between multiple exchanges. Fund Administrators retain Read-Only access to prepare and maintain visibility of balances. A Trusted 3rd party guarantees Digital Assets require multi-signature authorisation from Hamilton Platform- digital asset acquisition, to leave the Walled Garden.\n\nHamilton's DNA is a blend of industry acumen and investment experience at some of the world's top firms, including:\n\n- Goldman Sachs\n- Macquarie\n- Dresdner Kleinwort\n- NatWest\n- Mizuho\n- GSR Capital Management\n- TradeLink\n- Bank of America\n- Credit Agricole Group\n- Vanguard\n- Rothesay Life\n- Barclays\n\nHamilton is based in London, with a team that operates under strict KYC/AML processes. In its nascent phase, digital assets remains unregulated by the FCA, however Hamilton complies to the same standards applied to supervised financial institutions.\n\n![](_page_38_Picture_0.jpeg)\n\n### **Fund Administration / Reporting.**\n\nWe have partnered with one of the world's leading Fund Administrators, ranked by HFM as a top-tier service provider in the Hedge Fund Space.\n\n*\"Hamilton's Fund Administrator for the Group is NAV a privately-owned fund administrator. NAV has achieved 30 years of year-over-year growth solely via commercial success, innovation, service delivery, business diversity and maintaining a remarkable 99% client retention rate. They are among the top 10 global hedge fund administrators by number of funds, servicing more than \\$110 billion AUM.\"*\n\n#### **HAMILTON**'S CLIENT WEB PORTAL\n\nEmpowers investors to access a broad range of accounting reports, risk analytics and portfolio data.\n\nFiled 04/07/23 Page 39 of 46\n\n**Interactive Data Mining Tools**\n\n**Full Library of Historical Fund Performance**\n\n**Risk Analytics\\***\n\n**Advanced P&L, Portfolio Reporting**\n\n**Accounting and Investor Records**\n\nHFM EUROPEAN QUANT AWARDS 2022\nWinner\nBest fund administrator\n\nUS QUANT AWARDS 2021\nWinner\n\nOPERATIONS & SERVICES AWARDS 2021\nWinner\nNAV Fund Administration Group\n\nhedgeweek\nWinner\nBest Fund Administrator\n\nHFM TOP-RATED GLOBAL FUND ADMINISTRATOR\n\nEUROPEAN QUANT AWARDS 2020\nWinner\nBest Administrator\n\nAltCredit FUND INTELLIGENCE US SERVICES AWARDS 2020\nWinner\nBest Fund Admin private credit\n\nHFM US SERVICES AWARDS 2020\nWinner\nBest Administrator Middle-Office Services\n\nCTA INTELLIGENCE US Awards 2019\nWinner\nBEST CTA ADMINISTRATOR\n\nHFMWeek US Fund Services Awards 2018\nWinner\nBest Administrator under \\$30bn single manager\n\nHFMWeek US Fund Services Awards 2018\nWinner\nBest Administrator small managers\n\n@preqin\n2017 Leading Fund Administrator Servicing CTAS\n\nAI 2016 HEDGE FUND AWARDS\nWinner\nMost Trusted Hedge Fund Administrator\n\nAI 2016 HEDGE FUND AWARDS\nWinner\nLeader in Multi-Advisor Platforms & Complexes\n\nHFM AWARDS 2016 US TECHNOLOGY\nWinner\nBEST MANAGED ACCOUNT PLATFORM TECHNOLOGY\n\nCTA INTELLIGENCE US SERVICES AWARDS 2016\nWINNER\nMOST INNOVATIVE FUND ADMINISTRATOR\n\nHFM AWARDS 2016\nHIGHLY COMMENDED\nHEDGE FUND ADMINISTRATOR REPORTING\n\nCTA INTELLIGENCE US CTA SERVICES AWARDS 2016\nWINNER\n\nHFM AWARDS 2015\nHIGHLY COMMENDED\nMOST INNOVATIVE FUND ADMIN OVER \\$30BN\n\n2014 INTERNATIONAL HEDGE FUND AWARDS\nUS Fund Administrator Service Provider of the Year\nNAV Consulting Inc.\n\n![](_page_39_Picture_0.jpeg)\n\n### **INVESTOR PORTAL.**\n\n![](_page_39_Figure_3.jpeg)\n\n![](_page_39_Figure_4.jpeg)\n\n![](_page_39_Picture_5.jpeg)\n\n![](_page_39_Picture_6.jpeg)\n\n### **The Team.**\n\nThe team at Hamilton Investment Management Ltd bring together a unique combination of funds management, venture capital, and crypto experience to offer a comprehensive service and product offering.\n\n![](_page_41_Picture_0.jpeg)\n\n### **Fund Manager Bio: Kin Je.**\n\nKin Je has almost 30 years of experience as a fund manager and investment banker, currently managing a global investment fund with an Asset Under Management of USD12 billion. Prior to that, Mr. Je was the Chairman of Equity Capital Markets, Greater China at the Macquarie Banking Group for 10 years, managing its Greater China capital markets and principal investment activities. Before his position at Macquarie, Mr. Je served as the senior management for several investment banks including as the Managing Director and joint venture partner of China Merchant Securities (Hong Kong) Limited, Executive Director and Head of China of Credit Agricole Indosuez (and Board member of its securities arm, Indosuez W.I. Carr Securities), Director of Dresdner Kleinwort Wasserstein and Vice President of NatWest Markets.\n\nMr. Je has successfully completed more than 70 global IPO, M&A and principal investment transactions which amounted to US\\$40 billion. Mr. Je is recognised by \"International Who's Who\" as a leading investment banking professional in the world and is awarded honourable citizenship of the Washington State, U.S.A. for his contribution to Sino-US relationship. Mr. Je is a Vice Chairman of the Hong Kong International Blockchain and Financial Association, an NGO promoting blockchain technology and advocating crypto market regulation.\n\nMr. Je graduated from the Manchester Business School and the University of Wales (U.K.) with a Master of Business Administration. Mr. Je is a fellow member of the Association of Chartered Certified Accountants (U.K.) and the Hong Kong Institute of Certified Accountants. He is also a member of the Certified Financial Consultants (U.S.).\n\n![](_page_42_Picture_0.jpeg)\n\n### **Fund Manager Bio: David Fallon.**\n\nDavid is a Portfolio Manager at Hamilton Investment Management Ltd. Previously, he was a Portfolio Manager at TradeLink Holdings LLC, a diversified alternative investment and proprietary trading firm founded in 1979 by Walt Weissman. Prior to his tenure at Tradelink, David was a Portfolio Manager at Vanguard Asset Management and a Portfolio Manager at the Diversified Trading Group of Mizuho Bank London.\n\nBefore joining investment banking and Mizuho Bank in 2010, David studied applied mathematics and finance in University College Dublin. He holds an MSc in Quantitative Finance from University College Dublin, Thesis: A Genetic Programming Self Evolving Trading System and a BSc Hons in Mathematics and Computer Science from University College Dublin. Neural Networks & Natural Computing are of keen research interest to him. Natural computing (Biologically inspired algorithms for financial modelling) present a lot of opportunities for future developments of computational methods. Various bio-inspired methodologies such as neural networks, evolutionary computing (particularly genetic algorithms and grammatical evolution), particle swarm, all present endless possibilities for future developments in computational methods in finance.\n\nDavid has applied some of these techniques in developing proprietary trade finding tools throughout his trading career.\n\n![](_page_43_Picture_0.jpeg)\n\n### **Fund Manager Bio: Lee Alfay.**\n\nLee has 16 years experience in finance across Asia with a focus on electronic trading. Lee started his career with Bank of America in Singapore as a FX trader building automated proprietary trading strategies in the Spot FX space. He subsequently moved into a hedge fund where he built out a portfolio of FX strategies encapsulating marketmaking and arbitrage logic. Lee then joined a high frequency trading firm where he spent 5 years researching and trading a suite of high frequency trading strategies in the delta one space.\n\nLee then joined Goldman Sachs in HK where he spent almost four years in their FICC department initially as a Quantitative Algo Strategist then subsequently becoming an eFX trader managing the trading book in the Asian time-zone. Lee has also spent time with a Crypto trading firm in Japan focusing on trading and risk managing a portfolio of crypto assets. Lee's most recent experience was with a multi-strategy hedge fund focusing on trading delta one products.\n\nPrior to joining investment banking, Lee graduated from the Queensland University of Technology with Honours in Finance. Lee's undergraduate degree was a Bachelor of Business in Finance and an Extended Major in Economics.\n\n![](_page_44_Picture_0.jpeg)\n\n#### **Himalaya Digital Asset SPC Fund.** A Passive Investment Strategy.\n\n#### **Fund Terms**\n\n| Investors                                          | Qualified Investors |\n|----------------------------------------------------|---------------------|\n| Minimum Investment                                 | \\$100,000 USD       |\n| Fund Management Fee                                | 1.0%                |\n| Performance Fee<br>(subject to high water<br>mark) | 0%                  |\n\n| Subscriptions                             | Monthly   |\n|-------------------------------------------|-----------|\n| Redemptions                               | Quarterly |\n| Recommended<br>Minimum Investment<br>Term | 3 Years   |\n\n![](_page_44_Picture_6.jpeg)\n\n![](_page_45_Picture_0.jpeg)\n\n### **Our Partners.**\n\n![](_page_45_Figure_3.jpeg)","body_zh":null,"key_entities":["Himalaya","Je","CIPA","Himalaya Exchange","RICO"],"ecf_references":[],"word_count":4947,"status":"published","published_at":"2025-04-07 00:00:00","created_at":"2025-04-07","updated_at":"2026-07-06 20:55:59"}