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.
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
Registered in Romania and operating under applicable Romanian and EU frameworks, including data protection, AML/CTF, and relevant capital markets considerations.
3. Disclaimers
General liability and responsibility notice.
Specific acknowledgment for backers before confirming project interest.
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
DefinedAdvisory, 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
DeclaredFundshing 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
OperationalIssuers 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
RequiredIssuers 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
RequiredAppropriate identity verification processes are maintained by issuers or regulated partners.
Risk-based onboarding and ongoing monitoring.
Execution by Licensed Providers
RequiredWhere 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 ScopePersonal 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
ActiveDefense-in-depth security, access controls, monitoring, and incident response.
Controls aligned to industry-standard security practices.
Privacy Governance
ActiveInternal 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 EntityFundshing S.R.L. operates under Romanian and applicable EU legal frameworks, including data protection, AML/CTF, and relevant capital markets considerations.
Frameworks / Laws:
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.
Know Your Customer Policy
Identity verification and onboarding requirements maintained by issuers or regulated partners.
Data Retention Policy
Guidelines for data collection, storage, access, and deletion procedures.
Incident Response Policy
Procedures for handling security incidents, internal escalation, and data breach response.
Continuous Monitoring & Auditing
Regular assessments and monitoring help support ongoing compliance and security.
Security Audits
Periodic vulnerability assessments and security reviews support platform resilience.
Compliance Reviews
Internal and external legal or compliance reviews help maintain alignment with applicable requirements.
Operational Monitoring
Platform monitoring and internal controls help identify unusual activity and operational issues.
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.
We respond to compliance inquiries within 2 business days.
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Questions About Compliance?
Our team is available to discuss compliance positioning and answer your questions.