Legal draft

Partner execution, fees and complaints

The disclosure framework that must be completed before any customer can use the Settle rail.

No production execution partner appointed

Partner identity and authority

The final page will name the executing/settling legal entity, FSP number, authorised crypto-asset activities, register-check date, customer contract structure and any representative appointment. A logo, API key or commercial discussion is not sufficient.

The production page and accepted customer schedule will activate one truthful legal route for each rail. It will not present the representative, dual-contract and own-licence structures as simultaneous alternatives. Provider-specific schedules may coexist for a qualified second rail, but each transaction must identify its actual executing CASP and controlling terms before approval.

API-first qualification states

What each rail state proves
StatePermitted useWhat it does not prove
Synthetic business API / mock adapterProduct, data-model, maker-checker, webhook, reconciliation, journal, tax and video-demo testing with synthetic dataNo KYB acceptance, funds movement, regulated execution, custody, Travel Rule or partner SLA
Named partner sandboxProvider payload mapping, authentication, idempotency, quote/order/status, failure and second-rail contract testsNo production authority, safeguarding, customer execution or commercial performance unless separately evidenced
Named partner production railCustomer use only after licence, contract, legal perimeter, data, security, pricing and operational gates passDoes not make ChainClose the custodian or executing principal unless an approved future structure expressly changes that fact

Customer journey and control ownership

Draft Settle responsibility map
StepChainCloseAuthorised partner / customer
KYB/onboardingOrchestrates status and evidencePartner decides regulated onboarding
Intent and approvalPersists exact intent and maker-checker evidenceCustomer authorises
QuoteDisplays exact terms and expiryPartner prices and issues
Execution/settlementTracks state; no custodyPartner executes/settles
ReconciliationMatches partner, chain and ZAR cash evidenceCustomer resolves exceptions
ComplaintsRoutes software issueNamed owner handles regulated complaint

Fees, spread and ranking

ChainClose subscription/usage, partner fee, spread, network/bank cost, tax and any remuneration/revenue share will be shown separately before approval. Partner ordering will use disclosed objective criteria; no undisclosed payment may determine a recommendation or default route.

The final provider schedule must state quote expiry, gross amount, partner fee, spread or exchange-rate methodology, network/bank cost, ChainClose usage fee, tax, minimum/maximum and who invoices each item. A sandbox number is illustrative and cannot silently become a production price. No exclusivity or minimum-volume commitment is accepted before sandbox proof, commercial modelling and a technically qualified second-rail path.

Complaints and escalation

The final page will distinguish software/support complaints from execution, conduct, KYB, settlement and safeguarding complaints; identify each legal owner and response route; state escalation and applicable ombud/regulator routes; and explain what happens during a dispute or outage.

Continuity and termination

The final structure will cover quote expiry, outage/fallback, duplicate prevention, pending orders, evidence export, complaint continuity, customer/data portability and migration to a second rail. No exclusivity will be implied before sandbox proof and second-rail design.