Legal draft

Regulatory status and service boundary

What ChainClose is designed to do, what it is not authorised to claim and where a named partner must own regulated execution.

Counsel and partner approval pending

Current status

ChainClose is a pre-launch finance-operations software product. It is not currently represented as an authorised financial services provider, crypto asset service provider, accountable institution, tax practitioner, audit firm or legal practice.

Software activities

  • Read-only evidence ingestion, reconciliation and exception workflow.
  • Accounting, tax and regulatory preparation tools with named human approval.
  • Treasury views, receivable matching and persisted approval workflow.
  • Status and reconciliation orchestration around a separately authorised provider.

Activities ChainClose does not perform

  • Hold customer money, crypto assets or private keys.
  • Accept write-capable exchange credentials for the finance product.
  • Give investment recommendations or exercise discretion over transactions.
  • Execute, settle or intermediate a crypto-asset transaction before the approved partner structure is live.
  • File a tax/CARF return or submit goAML/Travel Rule data unless a named approved channel is contracted and enabled.

Partner-enabled Settle

ChainClose builds and tests one canonical business API and settlement data model first: KYB status, intent, executable quote, independent approval, order, signed status events, three-way reconciliation, journals, tax handoff and evidence. The deterministic mock adapter supplies synthetic data and moves no money; a selected authorised CASP business API then maps its provider schema into the same contract through a versioned adapter.

The preferred production route remains an appointed-juristic-representative plus embedded/API rail where counsel and the principal approve, with a dual-contract embedded technology model as fallback. An own Cat I licence is prepared only if validated demand and margin justify its incremental burden. Before Settle is enabled, this page will name the one route actually used, executing legal entity, FSP number and authorised activities; customer and complaints ownership; KYB/FIC/Travel Rule responsibilities; custody/settlement path; fee, spread and any remuneration; support/escalation; and termination/continuity route. Register status will be rechecked immediately before launch.

Tax, accounting and CARF

Outputs are preparation materials and calculations for review. The customer and its appointed practitioners decide policy, advice, returns and submissions. Applicable reporting CASPs retain their own CARF obligations and decisions.

Change triggers

Custody, discretionary conversion, order routing, batching, pre-staged execution, partner remuneration/ranking, advice-like copy, lending/yield and direct regulatory submission require fresh legal/perimeter review before implementation or release.

Official sources

External references used for the factual and regulatory context on this page.