REVIEW EDITION / NAME & OPERATING TERMS PENDING / NO FUNDS ACCEPTED

04 / DIGITAL ASSETS & CRYPTO

Digital value.
Clearly defined control.

Crypto requires an asset-specific and network-specific review. Ownership, wallet control, provenance and the proposed custody arrangement are separate questions.

BEYOND A WALLET BALANCE

What is held?
Who can act?
Where can it move?

Asset and network

Identify the token or coin, blockchain, token contract where relevant and custody arrangement. BTC, ETH and stablecoins are examples for inquiry, not a promise that every asset or network is accepted.

Control and provenance

Use an approved verification method to assess control and appropriate records to review origin and authority. A balance screenshot or transaction hash alone is not sufficient proof of lawful ownership.

KNOW THE MOVEMENT RULES

No implied custody.
No assumed liquidity.

Document whether assets remain in an owner-controlled wallet, move to a custodian or are transferred to an accepted counterparty. Define any restrictions, permitted activity, loss allocation, withdrawal conditions, reporting and return responsibility before funding.

Where fiat conversion is involved, agree the provider, pricing and transfer route separately. Names and contractual labels do not settle the regulatory treatment of actual conversion or transmission activity.

Background: FinCEN guidance on convertible virtual currency business models.

THE NEXT STEP

Start with the asset.
Not the promise.

A short, non-sensitive inquiry is the starting point. Eligibility, counterparties and terms must be confirmed before any transaction.

Explore your route