[CRO] MIP6 Collateral Onboarding Application - Crypto.com

Greetings to the MakerDAO community! We are from Crypto.com and would like to propose onboarding CRO as a collateral asset. Below is our application following the MIP6 template, and we welcome questions or comments:

1. Who is the interested party for this collateral application?

Crypto.com, the issuer of the CRO token.

2. Provide a brief high-level overview of the project, with a focus on the applying collateral token.

[a] Crypto-com Overview

Crypto-com was founded in 2016 on a simple belief: it’s a basic human right for everyone to control their money, data and identity. Crypto-com serves over 5 million customers today, providing them with a powerful alternative to traditional financial services through a wide range of products such as the Crypto-com App, the Crypto-com Card, the Crypto-com Exchange and DeFi offerings.

Crypto-com is built on a solid foundation of security, privacy and compliance and is the first cryptocurrency company in the world to have ISO/IEC 27701:2019, CCSS Level 3, ISO27001:2013 and PCI:DSS 3.2.1, Level 1 compliance. Crypto-com is headquartered in Hong Kong with a 500+ strong team. Find out more by visiting https://crypto.com.

[b] Crypto-com and DeFi
To better support its mission, Crypto-com has been venturing into the decentralized finance space. It has launched Crypto-com DeFi Wallet - a non-custodial wallet that lets users have full control of their private keys, and Crypto-com DeFi Swap - a web application where users can provide liquidity and/ or swap tokens, and receive rewards powered by CRO. In addition, Crypto-com has been actively conducting research on DeFi topics, including the DeFi Research Hub with a repertoire of self-produced reports, and a recent joint collaboration with BCG on the Rise of DeFi.

In addition, Crypto-com is developing Crypto.com Chain, a decentralized blockchain that aims to let users pay anywhere, in any crypto, for free.

[c] CRO Overview

The Crypto-com Coin (CRO) token is the token that powers the overall Crypto-com ecosystem with over 5 million users, including token utility across payment, trading and financial services use cases (including De-Fi). Issued in 2018, CRO has gained significant traction in the crypto market and is one of the top 15 crypto currencies with around 3 billion USD market capitalization (at time of writing).

For more details on us and CRO, please refer to our whitepaper: https://crypto.com/images/crypto_com_whitepaper.pdf.

3. Provide a brief history of the project.

Founded in 2016, Crypto-com has built a comprehensive ecosystem of payments, trading and financial services. Some milestones to highlight below:

[a] On payment

  • Started to ship the MCO VISA card in October 2018; now shipping in countries in Asia, Europe and the Americas
  • Announced the Crypto-com Chain and CRO token in November 2018
  • Launched Crypto-com Pay checkout solution (powered by Crypto-com Chain) in March 2019
  • Launched Crypto-com Chain Thaler Alpha Testnet in September 2019
  • Launched Crypto-com Chain Block Explorer v2.0 in June 2020

[b] On trading

  • Launched the open beta program for Crypto-com App in May 2018
  • Launched Crypto-com Exchange beta version in November 2019 and The Syndicate on Crypto-com Exchange in December 2019
  • Completed key Crypto-com Exchange infrastructure upgrades in June 2020

[c] On financial services

  • Launched Crypto Earn and Crypto Credit in May 2019
  • Launched the Crypto-com (Non-Custodial) DeFi Wallet in May 2020
  • Launched Crypto-com DeFi Swap in September 2020

4. Link the whitepaper, documentation portals, and source code for the system(s) that interact with the proposed collateral, and all relevant Ethereum addresses. If the system is complex, schematic(s) are especially appreciated.

5. Link any available audits of the project. Both procedural and smart contract focused audits.

Crypto-com has completed a detailed security assessment, which included external penetration testing, threat modeling through to risk control reviews. In addition to being the first cryptocurrency company in the world to have ISO/IEC 27001:2013, ISO/IEC 27701:2019, PCI:DSS 3.2.1, Level 1 compliance and CCSS, Crypto-com has obtained external audit certifications from Quantstamp and Certik for the smart contracts deployed:

The smart contracts and DeFi operating model of Crypto-com DeFi Swap were audited by blockchain researchers at SlowMist:

6. Link to any active communities relating to your project.

7. How is the applying collateral type currently used?

The CRO token is a top-15 market cap token at time of writing and is actively traded on top exchanges (see Q9).

In addition, the CRO token has token utility across the Crypto-com ecosystem, such as:

  1. Trading: Enjoy discounted fees, higher earnings, priority token allocations and more on the Crypto-com Exchange and Crypto-com Wallet App (with 5M+ users worldwide);

  2. Payment: Gain access to exclusive benefits of the MCO Visa Card (top up with crypto and spend in fiat at 40M+ VISA merchant locations) and mobile crypto payment;

  3. Financial Services: Get preferential rates on Crypto Earn & Crypto Credit offered by Crypto-com; unlock decentralized finance offerings.

For more details on the utility of CRO, please refer to our whitepaper: https://crypto.com/images/crypto_com_whitepaper.pdf.

8. Does one organization bear legal responsibility for the collateral? What jurisdiction does that organization reside in?

CRO is issued by CRO Protocol Labs, a private company incorporated in the Cayman Islands and it bears responsibility for the issuance of CRO.

9. Where does exchange for the asset occur?

Exchanges: Crypto-com Exchange, Huobi Global, OKEx, UPbit, Bibox, Bittrex, Bithumb, Gate-io, Bithumb Global, ZB-com, HitBTC, BitMart, Probit, Indodax and more

Token Swaps: Crypto-com DeFi Swap, Uniswap v2

10. (Optional) Has your project obtained any legal opinions or memoranda regarding the regulatory standing of the token or an explanation of the same from the perspective of any jurisdiction? If so, those materials should be provided for community review.


11. (Optional) Describe whether there are any regulatory registrations for the token and provide related documentation (including an explanation of any past or existing interactions with any regulatory authorities, regardless of jurisdiction), if applicable.

At the time of writing I am not aware of any regulatory registrations for the token.

12. (Optional) List any possible oracle data sources for the proposed Collateral type.

Please refer to the exchanges where CRO is traded (Q9).

CRO Coinmarketcap page: Crypto.com Coin price today, CRO to USD live, marketcap and chart | CoinMarketCap

CRO Coingecko page: Crypto.com Coin price, CRO chart, market cap, and info | CoinGecko

In addition, Crypto-com has launched the decentralized price reference data feeds first for CRO/ETH (price feed here) and soon to be followed by CRO/USD on the Chainlink Network in preparation for a deeper integration into the rapidly growing DeFi ecosystem. (link: Crypto.com Successfully Integrates Chainlink to Power Ambitious DeFi Roadmap for CRO)

13. (Optional) List any parties interested in taking part in liquidations for the proposed Collateral type.

N/A. The liquidation of CRO will follow the standard process of MakerDao.


Welcome to the Maker forums. This is tangentially related, but I’ve noticed that DAI liquidity on crypto.com is extremely low. Would adding CRO as collateral allow crypto.com to use its reserves of CRO (assuming you have some), to provide more liquidity for DAI on crypto.com? I know your answer is probably contingent on a number of factors like stability fee and debt ceiling, but I’m curious if there is any plan to use this facility to provide more DAI liquidity on your exchange, and if the answer is yes, what risk parameters would make this more attractive?


Hello - thanks for your question. We are of course committed to improving liquidity of DAI on our platforms, and we would be happy to have direct conversations with the team on the risk parameters.