KYC / AML screeningTreasury 3/5 + 48hPhysical custodyReserve attestationData protection

Layered controls: screening → treasury governance → custody → attestation → data protection.

Compliance & Security

Compliance is a precondition, not a patch. These controls run across funds, assets and disclosure.

KYC / AML

Mandatory identity & source-of-funds screening before funding; unclear funds rejected.

Custody

Physical gold held by a Brink's-grade custodian, independent of the operator.

3/5 Multisig + Timelock

Treasury needs 3-of-5; large transfers forced through a 48-hour timelock; tech team holds no keys.

LGPD

Personal data hashed & anonymized, minimal retention, no raw storage.

Audit & Reserve Proof

On-chain audit and reserve attestation; coverage published quarterly.

Disclosure discipline

Every figure published on one basis, reconcilable line by line — no selective presentation.

Partner institutions

FunctionProviderStatus
KYC / AML screeningInternational compliance providerMandatory before funding; named on contract
Asset custodyBrink's-grade custodianIndependent of the operator; named on contract
AuditIndependent audit firmMonthly reconciliation; annual external audit
Legal opinionCross-border issuance counselCovers the raise and each jurisdiction
Geological reportNI 43-101 / JORC Qualified PersonIssued and signed to international standard

Safeguards in place

These controls are designed or already operating, spanning funds, assets and disclosure.

C1 Treasury multisig + timelock

3/5 multisig + 48h timelock; no single point can move funds.

C2 Milestone vesting

5.5% vests by milestone with cliff and clawback, tied to performance.

C3 Qualified-investor gate

KYC/AML required to participate; limited to eligible investors.

C4 Quarterly coverage disclosure

Output, price and coverage published quarterly and traceable.

C5 Independent attestation

Gold delivery claims and reserves reconciled periodically by a third party.

C6 Gold transit insurance

Physical gold fully insured in transit.

C7 Lease renewal track

Three staggered leases; Yarumo to 2037 — ample operating runway.

C8 LGPD data compliance

PII hashed, minimal retention, compliant with Brazil’s LGPD.

C9 Lock-up and redemption cadence

Lock-up and redemption executed by rule in orderly batches.