Regulatory

KYC, AML and permissioned wallets: who can hold a token

Pablo Marques2 min read

There is a popular image of a token: an anonymous address sends to another anonymous address, no questions asked. For a regulated asset, that image is exactly what cannot happen. In a serious issuance, who is allowed to hold the token is a rule, and the rail has to enforce it.

If you read about the ERC-3643 standard, you already saw the mechanics. Here the focus is the regulatory why: KYC, AML and permissioning are not bureaucracy pasted on top: they are what makes the token compliant with the rule.

KYC and AML, without jargon

  • KYC (Know Your Customer) is knowing who is on the other side: identifying and verifying the holder before they enter the operation.
  • AML (Anti-Money Laundering) is the set of controls that prevents the structure from being used for money laundering or for entering where it shouldn't.

In traditional finance, these controls exist at account opening and in custody. The challenge of tokenization has always been: how do you maintain that rigor when the ledger is transferable by nature?

Permissioning answers this

The answer is the permissioned wallet. Instead of any address being able to receive the token, only wallets previously approved in KYC/AML enter the list of who can hold that asset. Each transfer is checked against this rule before completing: ineligible recipient, transfer blocked.

The control stops living in a parallel spreadsheet and becomes a property of the ledger itself, which we described in what tokenization is as a programmable ledger.

Why this is an advantage, not a limitation

It's tempting to read permissioning as a constraint. It's the opposite. In a regulated asset, knowing exactly who holds what (and being able to prove it at any moment) is precisely what the rule requires and what a serious investor values. Permissioning is what allows tokenization to operate within the CVM Resolutions 88 and 175, and not at their margin.

A token that accepts any wallet may look freer; for a regulated asset, it is simply inadequate. The good rail is the one that knows how to say no. If your operation needs to control the holder base, talk to us: the eligibility rule is part of the design from day one.

Notice

Forward Factory is an infrastructure platform for asset tokenization and does not provide investment advice, recommendations or counseling. The solutions described here do not constitute a public offering of securities. When a token represents a security, it observes the corresponding regulation, and the structuring of issuances adopts know-your-customer and anti-money-laundering (KYC/AML) procedures. Any offerings observe the applicable regulation of the Brazilian Securities and Exchange Commission (CVM), including CVM Resolutions No. 88 and No. 175. Past performance is no guarantee of future results; investments involve risk.

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