Investment Process: Compliance Constraints

An investment is subject to the applicable regulation, decision criteria, custody requirements, and supporting evidence. The normal subscription sequence is Subscribe and fund, and the closing sequence is Closing a Successful Offer.

Real-world asset investments can be securities in the United States and financial instruments in other jurisdictions. The Issuer and the applicable compliance owner determine the security type, exemption, jurisdiction, disclosures, and required Investor checks for each fund.

1. Investor eligibility and applicability

Before an Investor receives access to restricted fund information or submits an investment, the applicable process records the identity, eligibility, and suitability results required by the fund and jurisdiction.

United States: Regulation D

• Rule 506(b): The Issuer must follow the applicable pre-existing relationship and investor qualification rules. A reasonable-belief accreditation result can use the permitted self-certification or other evidence.
• Rule 506(c): The Issuer can use general solicitation only when all purchasers are accredited and the Issuer takes reasonable steps to verify that status. Evidence can include a CPA letter, tax records, brokerage statements, or another permitted verification method.

Other jurisdictions and instruments

• MiFID II: If the instrument is a financial security, the applicable process records the Investor's knowledge, experience, and required appropriateness or suitability result.
• MiCA: When MiCA applies to a crypto-asset payment, that payment uses an authorized E-Money Token (EMT) or Asset-Referenced Token (ART). This constraint is scoped to the applicable MiCA payment.

2. Identity and anti-money laundering

The applicable CIP process collects and verifies the Investor's name, date of birth or business information, address, and government identification before opening the relevant account. BSA/AML and sanctions screening, including applicable FATF Travel Rule information for crypto payments, remain owned by the responsible compliance and payment services.

The decision record identifies the profile, checks performed, result, provider reference, reviewer or service, and any hold or recovery action. The exact threshold and information exchange depend on the applicable rule and payment rail.

3. Custody and settlement

For a contingent fund offering, Investor funds are held in the qualified escrow or segregated account identified by the offering terms. The Issuer does not receive those funds before the applicable closing conditions are met and the qualified custodian or settlement owner authorizes release.

Settlement follows the selected payment rail, custody arrangement, fund terms, and owning service. Where a rail and contract support delivery-versus-payment coordination, that coordination applies only to that rail and contract. The general sequence for a successful close is to verify the closing conditions, close and release the applicable escrow, and then perform token issuance or the digital share-register update through the owning service. Payment and asset delivery are not universally simultaneous or atomic across payment rails.

See Successful Closing & Fund Disbursement and Electronic Payment for the related constraints.

4. Transparency and records

The applicable process provides human-readable records of the Investor's activity, including:

• Accepted fund terms, amount, price, date, time, security identity, and signature state.
• Eligibility, identity, AML, payment, escrow, and settlement results.
• Trade confirmation or other required transaction notice.
• Closing evidence and any refund or recovery result.

Immediately after an Investor commits, the platform issues an immutable commit confirmation with the exact date, time, price, token quantity, and platform remuneration.

Signed agreements, support chat logs, and transaction history are stored in WORM (Write Once, Read Many) records. They cannot be altered or deleted. The responsible compliance owner and record owner preserve these records under the applicable retention policy.

Record references include SEC Rule 10b-10 and SEC Rule 17a-4. The responsible compliance owner determines the applicable notice and retention requirements for the fund and jurisdiction.

Summary of controls

Control	Reference	Constraint
Accreditation or eligibility check	Applicable Regulation D, Reg CF, Reg A, or other rule	Record the required Investor result before the restricted action.
Escrow or segregated custody	SEC Rule 15c2-4 where applicable	Release follows the applicable closing conditions and custodian decision.
Trade or transaction record	SEC Rule 10b-10 where applicable	Provide the required transaction details and preserve the evidence.
Record retention	SEC Rule 17a-4 or other applicable rule	Preserve the required records under the responsible owner's retention policy.