Compliance Map
Regulatory map, by authority.
Intended posture: Covered User Interface Provider under the SEC Staff Statement of April 13, 2026. Reg BI-style disclosures at /disclosures.
Counsel review pending · not a settled legal conclusion
SEC Covered User Interface Provider
Counsel review pendingIntended framework: SEC Staff guidance concerning non-custodial interfaces facilitating peer-to-peer securities activity without BD/ATS registration, conditional on the factors below. Applicability and exact citation are subject to counsel confirmation; see the Trust page for status.
no custodyno prop bookno solicitationtransparent feesno discretionuser control
US registration regimes
SEC
Covered User Interface Provider (intended posture)
Mithril's intended posture is as a non-custodial interface provider that does not handle customer funds or execute against a proprietary book. Outside securities counsel is completing its opinion on the applicable framework and the facts that support this posture. The definitive memo will be posted here before the first paid user transacts; nothing on this page should be relied upon as a legal conclusion until then.
SEC
Broker-Dealer (15 USC §78o)
Mithril does not solicit transactions, does not handle customer funds or securities, does not carry customer accounts, and is not compensated based on transaction execution. Whether the interface-provider framework or a BD-partner structure is the correct path is the subject of the counsel opinion in progress. If counsel concludes a BD partner is required, one will be named before launch and this section updated.
SEC
Alternative Trading System (Reg ATS)
Mithril does not operate a proprietary matching engine against orders of non-broker-dealer subscribers for purposes of Reg ATS. OTC matching is facilitative — the interface publishes indications of interest; trades settle bilaterally with a qualified third-party escrow agent named in the SPA.
FINRA
Membership
FINRA membership is required of broker-dealers registered under §15(a). As Mithril is not a broker-dealer, FINRA membership does not apply.
SEC
Investment Adviser (IAA)
Mithril does not provide personalized investment advice, does not manage assets on behalf of users, and does not hold itself out as an investment adviser. Content published on the platform is factual and educational.
FinCEN
Money Services Business (MSB)
Mithril does not transmit customer funds. OTC settlement is coordinated through a qualified third-party escrow agent named in the SPA; tokenized trades settle directly on-chain from user-controlled wallets. No custody of fiat or virtual currency by Mithril.
CFTC / NFA
Futures Commission Merchant / Swap Dealer
Perpetual futures referenced on the platform are listed on Hyperliquid and accessed via user-controlled wallets on Solana. Mithril does not operate an exchange, clearinghouse, or intermediary for perps. US persons are geo-blocked from perps-only surfaces.
CFTC
Event Contracts (prediction markets)
Prediction market contracts are aggregated from regulated venues (Kalshi) and non-US venues (Polymarket). US users can only access Kalshi-listed contracts from within the platform; Polymarket contracts are geo-blocked for US users.
via Kalshi (CFTC-registered DCM)
Identity verification tiers
Tier
Verification
Limits
Reverify
Tier 0 — Browse
None
Read-only. Prices, charts, news, watchlist.
—
Tier 1 — Accredited
Rule 501(a) self-attestation
Access VIP, submit IOIs, place limit orders.
12 months
Tier 2 — KYC verified
Government ID, selfie, address
Execute OTC deals, tokenized trades up to $500K notional/day.
24 months
Tier 3 — Enhanced DD
Source of funds, accreditation proof
No per-transaction limit. Institutional tooling.
12 months
KYC handled by Persona (SOC 2 Type II, FINRA-reviewed). AML screening by Chainalysis KYT including OFAC SDN sanctions match on every wallet interaction.
Jurisdictional coverage
Region
Access
Detail
United States
Partial
OTC and tokenized equity available to accredited investors. Perpetual futures blocked. Polymarket contracts blocked. Kalshi contracts available.
United Kingdom
Partial
OTC and tokenized equity available to professional clients (FCA definition). Retail access limited per FCA restrictions on high-risk investments.
European Union
Partial
Available to qualified investors under the Prospectus Regulation. MiCA compliance reviewed for tokenized surfaces.
Canada
Partial
Available to accredited investors under National Instrument 45-106.
Singapore
Partial
Available to accredited investors under Section 4A SFA. MAS sandbox engagement in progress.
Australia
Partial
Available to sophisticated investors (Section 708 Corporations Act).
OFAC-sanctioned regions
Blocked
IP and wallet blocked. Includes: Cuba, Iran, North Korea, Syria, Crimea, Donetsk, Luhansk, plus all SDN-listed entities.
China (mainland)
Blocked
Blocked pending clarification on cross-border securities marketing rules.
Japan
Blocked
Blocked pending JFSA Type II registration review.
Geo-blocking enforced at the edge via IP (Cloudflare) and wallet address (Chainalysis OFAC SDN list). VPN circumvention is a Terms of Service violation.
Data processors & DPAs
Vendor
Scope
Framework
DPA
Clerk
Authentication, session, MFA
SOC 2 Type II, GDPR, HIPAA-ready
Live — DPA executed via self-serve TOS
Supabase
Primary application database (row-level ACL)
SOC 2 Type II, HIPAA, GDPR
Live — DPA executed via self-serve TOS
Vercel
Hosting, edge compute, analytics
SOC 2 Type II, ISO 27001
Live — DPA executed via self-serve TOS
Persona
KYC, accreditation verification, AML screen
SOC 2 Type II, FINRA-reviewed
Selected — DPA countersignature in progress
Chainalysis KYT
On-chain AML screening, OFAC sanctions match
Industry-standard (BSA/AML)
Selected — sales process in progress
Sentry
Error monitoring
SOC 2 Type II, GDPR
Live — DPA executed via self-serve TOS
What Mithril is NOT
- Not a registered broker-dealer or investment adviser.
- Not a securities exchange or Alternative Trading System.
- Not a custodian of user funds, private keys, or securities certificates.
- Not offering personalized investment recommendations. Nothing on the site is an offer or solicitation to buy or sell any security.
- Not a guarantor of counterparty performance. OTC trades settle bilaterally through a qualified third-party escrow agent per the SPA; on-chain trades settle trustlessly.