Eligibility and transfers
Who may hold units, what every transfer is checked against, and what the compliance authority can do.
Who may hold units
An investor holds units only after two things have happened onchain: the compliance authority has written an investor record for their wallet, with a country code, and it has opened their sukuk account, which starts frozen.
Registration is refused if the country is on the series' restricted list. The demo series is not offered to residents of the United States or Indonesia. Indonesia is on the list because the series settles in a stablecoin, and the rupiah is mandatory for domestic transactions there.
How identity is checked
Verification runs through Sumsub, with an identity document and a liveness check. The widget in the browser is only the interface. The decision is taken by the operator's API, which reads Sumsub's own record of the verdict and the document's country, and registers the investor only then.
The prototype uses Sumsub's sandbox, and the API refuses production credentials. The country is the document's country, not proven residence. Sanctions and AML screening are not configured. Identity checks and an allow-list are necessary for a real offering. They are not sufficient.
What every transfer is checked against
On each transfer of units, the compliance program refuses unless:
- the recipient has an investor record for this series,
- the recipient's country is not restricted,
- the recipient's balance after the transfer is within the holding cap.
A revoked investor's account is frozen, so they can neither send nor receive.
What the compliance authority can do
It can freeze an account. It can also move units without the holder's signature, for lost keys, inheritance, or an order from a court or regulator. The library refuses to build such a transfer without a reason and the authority that ordered it, and writes both onchain with the transfer. The recipient must still be a registered investor within the holding cap.
Nothing onchain stops whoever holds that key from using it directly, so this control rests on who holds the key. Holding it in a multisig is designed and not built (issue 19).
What is stored about you
The chain stores a wallet address and a two-letter country code per investor, and no other personal data.