Figure Markets Exchange

Rejected venues wait the longest for re-review; a rejection has to earn another look before the scheduled date.

REJECTED. The worklist item is a centralized, KYC-gated exchange account and OTC marketplace, not an on-chain asset or passive protocol position. Figure Payments controls eligibility, custody workflow, order acceptance, account access, and withdrawal processing under amendable terms; New York residents are expressly ineligible. Figure’s regulated US posture is a positive relative to offshore exchanges, but an advisor should evaluate it as a named access/custody provider, not treat its reported $1.71B marketplace balance as investable protocol TVL.

Kill criteria: the events that revoke this verdict
• Ketju publishes a named Figure custody/access-provider profile covering segregation, insolvency, insurance, subcustody, and exit tests
• The exact client state and product are eligible under current Figure terms and licenses
• A proposed-size cash and crypto withdrawal completes within the provider profile’s stated service level

The research file

Mechanism and client claim

Figure Markets Exchange offers spot digital-asset trading through an account opened after identity verification. Current materials list BTC, ETH, HASH, USD and USDC trading, while securities are separately offered through Figure Securities’ SEC-registered alternative trading system. Orders rest on or take liquidity from an exchange book and balances appear in the customer account; this is neither smart-contract lending nor a pool that generates a client yield. DefiLlama’s OTC Marketplace category measures assets associated with the venue, but the economically relevant claim is against the account, custody, banking, and execution arrangements in the governing agreements.

Control, governance, and legal perimeter

Figure Markets Holdings and Figure Payments Corporation identify the operating entities; Figure Payments states it is a licensed money transmitter and virtual-currency business. The terms reserve discretion to verify identity, restrict geography, decline eligibility, suspend access, change services, and amend terms. New York residents cannot use the exchange services, and separate international products apply outside the US. MPC key technology can reduce a single-key compromise but does not remove the operator’s account, compliance, custody, or insolvency role. Securities trading belongs to Figure Securities, not the crypto exchange entity, so those regulatory statuses cannot be blended.

Incident and operating record

The reviewed disclosure set contains licensing, business-continuity, trading-risk, fee, and customer-agreement materials rather than an on-chain incident ledger. No customer-fund exploit was identified in those sources as of the cutoff, but a clean record does not transform a centralized account into self-custody. The material control evidence is affirmative: KYC is required, the platform may reject orders and users, and service availability depends on Figure and its banking, payment, custody, and technology providers. Those are ordinary exchange facts, not allegations of misconduct.

Exit, liquidity, and failure path

A user exits by selling or withdrawing through Figure’s account workflows, subject to asset support, identity status, geographic eligibility, processing controls, network conditions, and any linked USD rail. Quoted order-book prices are not guaranteed and may be delayed; Figure disclaims suitability and may impose additional funding requirements. The worklist TVL therefore cannot establish proposed-size withdrawal capacity for a specific client or prove bankruptcy treatment. Before advisor use, Ketju would need a custodian/provider file covering segregation, title, insurance, insolvency, subcustodians, service continuity, and tested transfer-out timing.

Comparison and decision

For on-chain holdings, direct self-custody avoids the exchange account and provider balance-sheet dependency. For clients who need a regulated fiat access point, Figure can be compared with Coinbase, Kraken, Gemini and qualified custodians only after the named-provider Phase 2/3 research is complete. The correct result here is rejection as a protocol allocation, not a claim that Figure is an illegitimate venue. Reopen as a provider profile when legal custody, account protection, execution quality, state eligibility, and proposed-size exits are assessed on like-for-like terms.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• Figure Markets — General and Exchange Terms · primary · accessed 2026-08-19
  Supports: operating entities, eligibility, New York exclusion, operator discretion
• Figure Markets — Disclosures index · primary · accessed 2026-08-19
  Supports: SEC and FINRA status of securities affiliate, product-specific disclosures
• Figure Markets Exchange — Frequently Asked Questions · primary · accessed 2026-08-19
  Supports: KYC, supported assets, spot-only description, MPC custody claim
• Figure Markets — Exchange and ATS trading fees · primary · accessed 2026-08-19
  Supports: order-book model, crypto fees, ATS separation
• DefiLlama — Figure Markets Exchange protocol data · secondary · accessed 2026-08-19
  Supports: protocol category, chain perimeter, current TVL

Inherited controls

The verdict above grades the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The least safe layer sets the position’s grade, and the position table names which one that is.