Boundaries before expansion
Activities are assessed against the requirements that apply to the specific product, customer, and jurisdiction — rather than assumed from a single registration.
Compliance
We view compliance as an ongoing responsibility that should inform governance, risk management, disclosures, technology operations, and customer communications.
Compliance principles
Compliance is not a one-time registration or filing. It is a set of obligations that must be met repeatedly, in day-to-day operations.
Activities are assessed against the requirements that apply to the specific product, customer, and jurisdiction — rather than assumed from a single registration.
Internal controls, escalation paths, and disclosure practices are written down so that they can be reviewed, audited, and improved.
Registration and filing status is described precisely, including what it does not mean.
Corporate entity
The company and operating-entity information published on this website should be read together with the applicable corporate records and official filings.
Where applicable, information about money services business registration and related obligations should be verified against the relevant official records, including the scope of the registered activities.
A Form D notice is a filing associated with an exempt securities offering. A filing should not be described as SEC approval, endorsement, or a general licence to operate a digital asset exchange.
Registration and filings do not replace the need to assess the requirements applicable to each product, service, customer, and jurisdiction.
What it indicates: The entity exists and is registered in its jurisdiction of incorporation.
What it does not indicate: Authorization to provide financial services.
What it indicates: Registration as a money services business with the relevant federal authority, with associated AML programme obligations.
What it does not indicate: A licence covering every product or jurisdiction.
What it indicates: A notice filing associated with certain exempt securities offerings.
What it does not indicate: SEC approval, endorsement, or a trading licence.
What it indicates: Subject to separate licensing and permissions that depend on the service and jurisdiction.
What it does not indicate: Implied by any of the registrations above.
Ongoing controls
Registration is the starting point. The operating work sits in controls, disclosure, and review.
Customer due diligence, transaction monitoring, escalation, and record-keeping appropriate to the registered activities.
Material information about services, fees, and risks kept current, consistent, and accessible.
Periodic review of controls, permissions, and vendor arrangements, with findings tracked to closure.
Tracking changes in applicable requirements and adjusting processes before they become findings.
AML programme
An anti-money-laundering programme is a set of connected controls, not a single policy document. Each element below is reviewed and tested independently.
Identity verification, beneficial-ownership review where relevant, and risk-based onboarding before an account is used.
Rules and thresholds are reviewed periodically and tuned as typologies change; alerts are investigated and documented.
Defined escalation paths and reporting obligations, with decisions recorded and retained for review.
Records are retained for the periods required by applicable rules and kept retrievable for regulators and auditors.
Staff complete role-appropriate training, and acknowledgements are recorded rather than assumed.
Controls are tested periodically by a function separate from the one that operates them, with findings tracked to closure.
Regulatory change
Rule changes are only useful if they reach procedures, systems, and disclosures. The cycle below is how that hand-off is meant to work.
01
Track changes in applicable rules, guidance, and enforcement practice across the jurisdictions where services are offered.
02
Translate each change into a concrete impact on products, disclosures, controls, and customer communications.
03
Assign owners, update procedures and system configurations, and record the effective date of the change.
04
Test that the change works as intended and that affected disclosures were actually published, not merely drafted.