RWA tokenization compliance position

Fundshing documents its RWA tokenization compliance position for technology services, issuer workflows, partner responsibilities, data protection, AML expectations, and risk disclosures.

Last updated: April 1, 2026

1. Our Role

  • Fundshing provides advisory, exposure, and technology services for project issuers and backers.
  • All financial commitments are made directly between backers and issuers or their licensed service providers.

We are not:

  • A broker-dealer, exchange, or crowdfunding platform
  • A “crypto-asset service provider (CASP)” under EU Regulation (MiCA)
  • An investment adviser, custodian, or regulated execution venue

2. Jurisdictional Registration

Fundshing S.R.L. (Romania)

Registered in Romania and operating under applicable Romanian and EU frameworks, including data protection, AML/CTF, and relevant capital markets considerations.

3. Disclaimers

Platform Disclaimer

General liability and responsibility notice.

Backer Disclaimer

Specific acknowledgment for backers before confirming project interest.

Issuer Terms

Responsibilities of project issuers using Fundshing’s advisory and exposure services.

Key points:

  • All ROI, project valuations, and metrics are provided by issuers.
  • Fundshing does not verify or guarantee financial performance.
  • Use of the platform is at your own risk.

4. Risk Warnings

  • Tokenized projects, crypto-assets, and early-stage ventures are highly speculative.
  • You may lose part or all of your commitment.
  • Liquidity may be limited, and legal or regulatory frameworks may change.
  • Past performance is not indicative of future results.
  • Backers must conduct independent due diligence and seek professional legal, financial, and tax advice.

5. Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF)

  • Fundshing does not handle investor funds directly. AML/CTF checks are carried out by issuers or their licensed service providers.
  • Issuers using our platform must comply with applicable EU AML and counter-terrorism financing requirements.
  • Issuers must maintain appropriate KYC (Know Your Customer) processes.
  • Risk-based onboarding, monitoring, and recordkeeping are expected to be maintained by the responsible parties.

6. Data Protection

  • GDPR (EU) applies to our processing of personal data in relevant contexts.
  • We apply data minimization, access controls, and appropriate security measures.
  • See our Privacy Policy for full details.

7. Governing Law

  • Operations are governed by the laws of Romania, unless otherwise required by mandatory law.
  • Disputes are subject to the jurisdiction of the competent courts of Romania, unless otherwise agreed.

Regulatory Position

Our legal position emphasizes issuer-led execution, AML/CTF responsibilities with licensed providers, and strong data-protection practices within our operating framework.

Legal Position & Controls

Role & Scope

Defined

Advisory, exposure, and technology services for issuers and backers. Transactions occur with issuers or their licensed partners.

No custody of client funds or tokens by Fundshing.

No Regulated Activities

Declared

Fundshing is not a broker-dealer, funding portal, investment adviser, custodian, or CASP under MiCA.

Platform content is informational and does not constitute investment advice.

Issuer-Led Transactions

Operational

Issuers manage investment documentation, onboarding, and settlement with their chosen licensed providers.

Backers are redirected to issuer ecosystems for execution.

Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF)

EU AML Requirements

Required

Issuers using our platform are expected to comply with applicable EU AML directives and local implementing laws.

CDD, monitoring, sanctions checks, and recordkeeping by issuers or partners.

KYC Programs

Required

Appropriate identity verification processes are maintained by issuers or regulated partners.

Risk-based onboarding and ongoing monitoring.

Execution by Licensed Providers

Required

Where regulated activity is required, execution should be handled by licensed intermediaries or service providers.

Fundshing does not directly execute regulated transactions.

Data Protection

GDPR (EU)

In Scope

Personal data is handled in line with GDPR principles and applicable Romanian data protection law.

Lawful basis, minimization, data subject rights, and breach response.

Security Program

Active

Defense-in-depth security, access controls, monitoring, and incident response.

Controls aligned to industry-standard security practices.

Privacy Governance

Active

Internal procedures support confidentiality, retention controls, and accountable processing.

Privacy requests and compliance escalations are handled through internal review.

Jurisdictional Registration

Our entity operates within a clear Romanian and European legal framework.

🇷🇴

Romania (EU)

Registered Entity

Fundshing S.R.L. operates under Romanian and applicable EU legal frameworks, including data protection, AML/CTF, and relevant capital markets considerations.

Frameworks / Laws:

MiCAProspectus RegulationAMLD5/6GDPR

Compliance Policies

Comprehensive policies governing our operations and supporting regulatory adherence.

Anti-Money Laundering Policy

AML standards and due diligence expectations applicable to issuers and execution partners.

Last Review
12/1/2025
Next Review
6/1/2026

Know Your Customer Policy

Identity verification and onboarding requirements maintained by issuers or regulated partners.

Last Review
11/15/2025
Next Review
5/15/2026

Data Retention Policy

Guidelines for data collection, storage, access, and deletion procedures.

Last Review
10/30/2025
Next Review
4/30/2026

Incident Response Policy

Procedures for handling security incidents, internal escalation, and data breach response.

Last Review
12/15/2025
Next Review
6/15/2026

Continuous Monitoring & Auditing

Regular assessments and monitoring help support ongoing compliance and security.

Security Audits

Periodic vulnerability assessments and security reviews support platform resilience.

Review Cycle: Periodic
Focus: Security posture

Compliance Reviews

Internal and external legal or compliance reviews help maintain alignment with applicable requirements.

Review Cycle: Ongoing
Focus: Regulatory alignment

Operational Monitoring

Platform monitoring and internal controls help identify unusual activity and operational issues.

Coverage: Ongoing
Focus: Stability & control

Risk Management Framework

Operational Risk Controls

  • Role-based access controls and internal approval procedures
  • Separation of advisory activity from transaction execution
  • Compliance monitoring and internal escalation procedures
  • Business continuity and incident response planning

Technology Risk Mitigation

  • Security reviews for critical systems and workflows
  • Access logging and monitoring for sensitive environments
  • Regular updates, patching, and vulnerability management
  • Secure development and deployment practices

Transparency & Reporting

Transparent communication helps users, issuers, and partners understand our compliance posture.

Policy Disclosures

Clear information about platform terms, privacy, and compliance-related policies.

Regulatory Updates

Material legal, regulatory, or operational updates relevant to platform usage.

Control Reviews

Summaries of security, governance, and control review activities where appropriate.

Compliance Reporting

We maintain a confidential reporting channel for compliance concerns, potential violations, or unethical behavior. Reports are reviewed seriously and handled with appropriate confidentiality.

8. Contact Compliance Team

For questions related to compliance, risk, or legal matters, please contact us.

Compliance Hotline
+40 733 631 603
Address
📍 Romania: Fundshing S.R.L., Sos. Nicolae Titulescu, No. 48, cam. 2, Bucharest, Romania

We respond to compliance inquiries within 2 business days.

Stay Informed

Subscribe to receive updates on regulatory changes, compliance requirements, and industry best practices that may affect your platform usage.

Regulatory updates • Compliance alerts • Industry insights

Questions About Compliance?

Our team is available to discuss compliance positioning and answer your questions.