1. Status of this notice
This notice describes what the Service does and does not do with respect to anti-money-laundering (AML), countering the financing of terrorism (CFT), and sanctions. It is not a Bank Secrecy Act program, not a money-services-business policy, and not a substitute for your institution’s BSA/AML or sanctions program.
2. Operator is not your financial institution
In this version Operator does not hold customer funds, does not transmit currency as a business, does not operate a hosted wallet, and does not clear trades. Paper Desk balances and local matching are design records. You must not treat Operator as a bank, broker-dealer, or money transmitter merely because the interface has Issuer KYB, a holder allowlist, or a Connect MetaMask button.
3. What Program Review is
Issuer KYB and holder packets run a completeness, format, and name-screen control in the browser (“Program Review”). It can refuse a “passed” status when required fields are missing, when names fail a simple screen, or when attestations are unchecked.
Program Review is not customer identification under 31 C.F.R. § 1020.220, not customer due diligence under the CDD rule, not beneficial-ownership verification against a government registry, not a credit check, not accreditation verification under Rule 501 of Regulation D, and not a live query of OFAC’s SDN list, the EU consolidated list, or similar.
4. Sanctions representations
You represent that you are not, and are not acting for, a person on the OFAC Specially Designated Nationals and Blocked Persons List, a person located in a comprehensively sanctioned jurisdiction, or a person with whom U.S. persons may not deal. You will not use the Service to evade sanctions, export controls, or securities-law offering restrictions.
The Service does not geo-block visitors who only read documentation. Absence of a block is not a license. You must stop if your counsel or your bank tells you to.
5. Holder allowlist is not KYC
A restricted RWA will not fill a Desk buy unless the connected wallet is a passed holder sponsored by that issuer. That is a local matching gate. It does not identify the natural person, does not collect government ID, and does not travel under the Travel Rule. Issuers remain responsible for any CIP, accreditation, or transfer-restriction program that actually applies to their offering.
6. Recordkeeping
KYB packets, holder packets, and mint specifications live in your browser. Operator does not retain a server-side copy in this version and cannot produce them to a regulator on your behalf. If your program requires five-year retention, use Export JSON snapshot on the Legal index (Device records) and store that file under your own controls before clearing site data.
7. Suspicious activity
Operator does not file SARs for local design activity. If you are a financial institution using the Converter, your own SAR, CTR, and sanctions-alerting duties are unchanged. Do not use the Desk’s seed book or simulated fills as evidence of a real market.