Compliance Framework

OpenSettle's product architecture is designed to remain outside the scope of money transmission and custody regulation. This document summarizes our reasoning; it is not legal advice.

In the United States, the Bank Secrecy Act defines money transmitters as entities that "receive funds for transmission to another person." OpenSettle never receives customer funds. Customer payments flow through a deterministic smart contract directly to the merchant's wallet, with OpenSettle's fee atomically forwarded to OpenSettle's own wallet in the same transaction.

In the EU, MiCA classifies Crypto-Asset Service Providers (CASPs) around custody, exchange, and transfer services. OpenSettle does not provide custody, does not operate an exchange, and does not initiate or execute transfers on behalf of third parties.

We screen every declared settlement wallet against OFAC sanctions and equivalent UK/EU lists prior to activation, and continuously re-screen. Sanctioned addresses cannot be used to settle payments through our platform.

SOC 2 Type I was completed in January 2026. SOC 2 Type II observation period is active. Copies are available under NDA from compliance@opensettle.com.