Compliance
4 min
Every transfer asks four questions
Identity, jurisdiction, lock-up, holder cap. If one answer is no, nothing moves, and the reason is written down.
Before a unit of any Mintage issue changes wallet, the token asks four questions about the buyer and the moment.
Is the buyer who they say they are? The receiving wallet must be linked to an identity with a current KYC and AML claim from a verifier we accept. Claims expire: a buyer whose KYC lapsed yesterday is refused today.
May they hold it where they are? Each issue carries the permitted countries and investor types of its documents. When Orvel Partners, a US retail investor, tried to buy Halden Private Credit I notes reserved for accredited US investors, the transfer stopped at rule 2.
Is the unit free to move? Lock-ups are dates, and the contract knows the date. During Vale Street Logistics’ 12-month lock-up the contract refused 61 transfers, each recorded as “Blocked · rule 3 · lock-up”.
Is there room on the register? Some issues cap the number of holders. Once the cap is reached, the next new holder is refused the same way.
A refused transfer is not an error. It is the register doing what the documents told it to do, at the moment it matters, with a reason the issuer can read.
Rafael Monteiro
General Counsel and Head of Transfer Agency
