Compliance Enforcement

Compliance Enforcement

Libertum enforces compliance constraints in code, not just in documentation. This chapter starts with the licences and registrations held by Libertum group entities — and, just as importantly, what they do not cover — then walks through the enforcement chain end to end: identity, jurisdiction, transfer rules and the evidence each step leaves behind.

Nothing in this chapter is legal advice. Issuers and investors should take advice from their own counsel in every jurisdiction they operate in.

1. Licence register

Libertum group entities hold the following licences and registrations. Each one belongs to a specific legal entity — no single entity holds all of them.

Licence / registration	Holder	Regulator & jurisdiction	Identifiers	Since
Digital Asset Service Provider (DASP / PSAD)	Libertum, S.A. de C.V.	Comisión Nacional de Activos Digitales (CNAD), El Salvador	Registry entry PSAD-0094 · Resolution ref. CNAD-CD-477-2026	31 August 2026
Bitcoin Service Provider (BSP)	Libertum, S.A. de C.V.	Government of El Salvador	Comprobante Digital para Proveedores de Servicio Bitcoin	7 October 2024
Money Services Business (MSB) registration	Libertum LLC	Financial Crimes Enforcement Network (FinCEN), United States	MSB registration no. 31000312444528	Re-registration effective 8 October 2025
Commercial licence — real estate	Al Xolame Assets Real Estate L.L.C	Dubai Department of Economy and Tourism, UAE	Commercial licence no. 1374511	Active

Libertum Ltd, incorporated in the United Kingdom, is the group parent and owns the T-Suite platform. Libertum, S.A. de C.V. is the entity registered with the CNAD.

The full register, with every identifier, is published at Licences and summarised in Start here → Licences.

2. What each licence authorises — and what it does not

DASP licence (PSAD-0094) — Libertum, S.A. de C.V.

Granted by the CNAD under Article 19 (a), (d) and (f), numerals 1 and 2, of the Ley de Emisión de Activos Digitales (LEAD). It authorises Libertum, S.A. de C.V. to provide, for the stablecoins USDT and USDC:

• Custody of digital assets on behalf of clients
• Exchange of digital assets
• Transfer of digital assets
• Receipt and transmission of client orders

It does not:

• Authorise any issuance. Each issuer, and each issuance, registers separately with the CNAD. Using T-Suite does not register an issuer or an offering, and Libertum’s licence does not extend to an issuer’s tokens.
• Cover the promotion, structuring or management of investment products (LEAD Art. 19(e)). Libertum has applied for this authorisation; it has not been granted. The Structuring module is a software tool that helps issuers and their own counsel prepare documentation; it is not a Libertum structuring service.
• Have effect outside El Salvador. It confers no passporting rights and no authorisation in the EU, the United States, the United Kingdom or anywhere else.
• Cover assets other than USDT and USDC, apart from RLUSD, whose custody has been approved by the CNAD. Security tokens issued through T-Suite are not “custodied” under this licence.

BSP registration — Libertum, S.A. de C.V.

A Salvadoran registration covering Bitcoin custody, digital exchange houses and exchanges, and Bitcoin digital wallets. It does not cover tokenized securities.

FinCEN MSB registration — Libertum LLC

A US federal registration as a money transmitter and dealer in foreign exchange under the Bank Secrecy Act (31 CFR 1022.380). Registration with FinCEN is a mandatory filing; FinCEN does not recommend, approve or endorse any registered money services business. It is not a securities licence, and state-level requirements are separate.

UAE commercial licence — Al Xolame Assets Real Estate L.L.C

A Dubai commercial licence for buying and selling real estate. Al Xolame is an asset-holding entity used to acquire and hold real-world property; it is not a financial-services licence.

What remains with issuers and investors

Customers still need their own authorisations in their own jurisdictions. Issuers remain responsible for offering registration or exemption analysis, prospectus or offering-document content, investor-eligibility rules and marketing restrictions. Investors remain responsible for their own tax treatment.

3. Custody under the DASP licence

When an investor or issuer uses the platform-managed Custodian Wallet, custody of USDT and USDC held in it is provided by Libertum, S.A. de C.V. under PSAD-0094. RLUSD can be held in investors’ and issuers’ XRPL custodian wallets; custody of RLUSD has been approved by El Salvador’s CNAD under Libertum’s DASP registration (PSAD-0094). The custody controls that apply to every Custodian Wallet are:

• Keys are generated and stored encrypted by the platform (AES-256-GCM); users never handle a seed phrase.
• Withdrawals go only to saved withdrawal addresses, and a new address can only be used 24 hours after it was added. Adding an address triggers an email with a one-click revoke link.
• Every withdrawal requires step-up verification: a 6-digit email code valid for 10 minutes, or an authenticator-app code (TOTP), or one of eight single-use backup codes.
• Per-transaction and daily limits apply, and withdrawals above a threshold need manual approval by Libertum.
• Withdrawal destinations are sanctions-screened, and Libertum can pause all custodian signing platform-wide if needed.

Withdrawal availability and the networks enabled for custody are set per deployment. The issuer-side view is covered in the Issuer Guide.

4. Supervision and reporting

Libertum, S.A. de C.V. is a supervised entity of the CNAD. It has quarterly reporting obligations to the CNAD commencing in Q3 2026, and notifies the CNAD before commencing licensed operations.

5. KYC pipeline

Investor clicks "Complete KYC"
    ↓
Frontend → backend → SumSub access token issued (project-scoped, single-use)
    ↓
SumSub iframe loads in browser
    ↓
Investor submits ID + selfie + (jurisdiction docs)
    ↓
SumSub processes (machine + manual review)
    ↓
Webhook → backend → kycStatus = IN_PROGRESS
    ↓
Webhook → backend → kycStatus = APPROVED or REJECTED
    ↓
On APPROVED, the platform registers the investor on the IdentityRegistry contract
(via the relayer, against the offering's identity infrastructure)

Approved KYC unlocks the ability to place primary orders, but does not by itself authorise transactions in any specific offering — wallet whitelisting and the offering’s own rules come next. Issuers complete the equivalent KYB process before they can publish.

6. Whitelist gating

Even after KYC is APPROVED:

1. Investor connects a wallet.
2. The platform creates a whitelist request linked to {investor identity, wallet address, offering}.
3. Email goes to the issuer’s transfer agent: review needed.
4. The transfer agent opens the Transfer Agent app → Wallet Whitelist → reviews.
5. The transfer agent approves or rejects.
6. If approved, the platform calls the offering’s IdentityRegistry to register the wallet. The investor is now eligible to receive tokens for that offering.

7. Country restrictions, investment limits and accreditation

Jurisdiction and investment-size rules are enforced at three layers:

• Platform country restrictions. Libertum maintains a global country grey-list and black-list. It is applied at signup and offered to issuers in the Tokenization Wizard, so restricted countries cannot be selected for an offering.
• Offering rules, checked at order time. Before an order is accepted, the platform checks the offering’s minimum and maximum investment (a maximum is required on every offering), the investor’s cumulative position, any accredited-tier cap, hold time, maximum balance and the offering’s country allow- or restrict-list. A country allow-list is a strict whitelist: any country not on it is refused.
• On-chain compliance modules (next section) re-check the same rules in the token contract itself, so they hold even outside the platform.

Accreditation — Status: Live. Investors apply on the Accreditation page with answers and documentary evidence. The application is reviewed by the platform the investor registered on (its team members with the accreditation permission), and Libertum can review any application. A reviewer approves it with an accreditation type and an expiry date, rejects it with a reason, or requests more information; approvals expire automatically. An approved, in-date accreditation from any platform lets the investor invest up to an offering’s accredited-tier cap. Accreditation does not otherwise restrict which offerings an investor can see; issuers who need accredited-only offerings should still apply their own eligibility checks. The decision to approve an accreditation, and its legal basis, rest with the reviewing platform.

8. On-chain transfer validation

When an investor (or an agent on their behalf) calls transfer(to, amount) on an ERC-3643 Token:

1. Is sender frozen? → revert if yes.
2. Does sender have enough non-frozen balance? → check freezePartialTokens.
3. Is receiver in IdentityRegistry? → revert if no.
4. For each compliance module enabled on Modular Compliance:
   • Country Allow: receiver’s country claim in allow-list?
   • Country Restrict: receiver’s country claim NOT in block-list?
   • Supply Limit: total supply + (mint amount, if mint) ≤ cap?
   • Max Balance: receiver’s resulting balance ≤ cap?
   • Hold Time: tokens being moved older than hold-time?
5. All pass → execute transfer; emit Transfer event.
6. Any fail → revert.

This happens before any tokens move. There is no after-the-fact compliance check — the chain itself rejects non-compliant transfers. On Cardano, the equivalent programmable-token standard (CIP-113) is live on Cardano mainnet and preview, on the Cardano Foundation’s canonical CIP-113 deployment; see Token Standards.

9. Force transfer override

forcedTransfer(from, to, amount) skips step 1 (sender frozen) and step 2 (sufficient non-frozen balance) — so an agent can move tokens out of a frozen or partially-frozen wallet in legitimate compliance scenarios. Steps 3 and 4 still apply: the receiver must be verified, and all compliance modules must still pass. This is the critical safety: a force transfer can never put tokens in a non-compliant wallet.

recoveryAddress(lostWallet, newWallet, identity) is similar but performs the IdentityRegistry update atomically with the transfer — re-linking the new wallet to the same identity in one operation.

10. Audit trail and evidentiary model

Every compliance action produces evidence in more than one place, so that no single system has to be trusted on its own.

Operational audit records

• On-chain events (immutable): Transfer, AddressFrozen, AddressUnfrozen, TokensFrozen, RecoveryAddress and the rest of the ERC-3643 event set.
• Off-chain database records with actor, timestamp, decision and reason for every approval, rejection, freeze and override.
• Issuer’s Transfer Journal — the issuer-facing view that combines both.
• Investor’s Transaction History — the investor-facing slice of the same data.
• SumSub decision log — every KYC/KYB decision archived.

The on-chain and off-chain views agree because the event indexer writes to the database only once an on-chain event has been observed and confirmed.

Agreement evidence (e-signature)

When an offering requires a signed investment agreement, every signature produces an Audit Trail record that both the investor and the issuer can open:

Signature record

Field	What it proves
Timestamp	When the signature was applied
Signer IP address	Where the request came from
Signer user-agent	Which browser/device string was used
OTP verification time	That the signer confirmed a one-time code sent to their verified email
Nonce	That the signing request was unique and cannot be replayed

Cryptographic proofs

Proof	What it binds
Body SHA-256	The exact agreement text the investor saw, including resolved merge fields
PDF SHA-256	The exact executed PDF
Certificate ID	A unique identifier for the execution certificate
Libertum HMAC seal	An HMAC-SHA256 over the record, keyed with a Libertum platform secret, proving the record was issued by Libertum and not altered
On-chain anchor (optional)	When enabled for the deployment, the record’s hash is anchored in a transaction on Base or Cardano

Verifying the evidence

From the Audit Trail screen, a party can export the audit record as JSON and download the executed PDF. With those two files:

• Anyone can verify offline that the PDF is unaltered (recompute its SHA-256 and compare with the record) and that the agreement text matches (recompute the body hash).
• Anyone can check an on-chain anchor, where one exists, against a public block explorer.
• The HMAC seal can only be verified by Libertum, because it uses Libertum’s secret key. There is currently no public verification endpoint; verification requests go through Libertum support. (Smart-contract certificates are different: they can be verified publicly at /verify — see Compliance §11.)

No screenshot or export of an Audit Trail should be published, because it contains the signer’s IP address and identifiers.

11. Smart-contract certificates

Every offering deployed on T-Suite is automatically checked on-chain and receives a signed Smart Contract Certificate, issued by Libertum, S.A. de C.V. (CNAD-registered Digital Asset Service Provider, PSAD-0094) as the platform provider. It is Libertum’s technology certificate for the deployed contracts.

Coverage

• EVM: ERC-3643, ERC-20 and ERC-721 offerings.
• Cardano: CIP-113 programmable tokens.
• XRP Ledger: issued currencies and Multi-Purpose Tokens (MPTs).
• Imported tokens are certified “as observed — not deployed by Libertum”.

What it records

• It separates the rules the contract enforces on-chain (for example identity checks, transfer restrictions, supply and balance limits) from the controls the platform enforces off-chain (for example KYC review, whitelisting workflow and order-time checks).
• It is signed with an Ed25519 signature, and its fingerprint is anchored on the offering’s own chain.
• It is re-checked nightly. If the contract changes, a new version is issued and the previous one is marked superseded; if a check fails, the certificate badge is hidden.

Where it appears

• Issuers see the certificate on the offering dashboard and in the data room.
• Investors see a “Certified by Libertum” badge on the offering.
• Anyone can verify a certificate — its signature, its on-chain anchor and the PDF fingerprint — at https://tsuitenew.libertum.io/verify/CERTIFICATE-NUMBER, replacing CERTIFICATE-NUMBER with the number printed on the certificate.

It records the results of Libertum’s automated technical checks at the time stated. It is not a certification for a public offering under the Digital Assets Issuance Law (LEAD), and it is not a regulatory approval of the offering or its issuer.

Libertum does not act as a certifier for public offerings under the LEAD; that is a separate role in the public-issuance process. Issuers still complete their own registration with the CNAD and obtain whatever reviews their offering requires.

12. What Libertum does NOT do

• Libertum is a technology provider, not a broker-dealer. Securities-law obligations (registration, exemption analysis, prospectus content, jurisdiction-specific disclaimers) remain with the issuer and their counsel.
• Libertum’s DASP licence does not register or authorise issuers or issuances. Each issuer and each issuance registers separately with the CNAD, and offerings in other jurisdictions follow those jurisdictions’ rules.
• No promotion, structuring or management of investment products. The Structuring module produces drafts for the issuer and its counsel to review; it is not legal advice and not a Libertum service.
• No automated tax advice. The Statements area produces transaction statements; tax classification and filing remain the investor’s responsibility.
• No custody of investor fiat. Fiat moves through payment-rail intermediaries (Stripe, bank transfers to issuer accounts). Custody provided by Libertum, S.A. de C.V. is limited to USDT and USDC under PSAD-0094, plus RLUSD custody approved by CNAD, as described above.