Executive Summary
VERITAS is a public-benefit compliance layer that businesses adopt to ensure digital asset payments are fully recorded, identity-verified, properly jurisdiction-mapped, and audit-ready. It does not custody funds, does not transmit assets, and does not broker trades. The system ensures compliance through credentialing, logging, and reporting — not through financial control.
Regulatory Classification: Not a Money Transmitter
VERITAS never controls user funds. All payments occur peer-to-peer from user wallets. Veritas provides rules, attestations, and recordkeeping — not transmission or custody.
Identity, AML, and Recordkeeping Architecture
VERITAS uses Persona for identity verification and Chainalysis for forensic risk analysis. Payments are stamped with compliance states and stored in PDAs as immutable audit logs.
| Layer | Function | Enforcement |
|---|---|---|
| Identity Gate | Business/employee verification | Persona Attestation |
| Credential Minting | Compliance NFTs | Non-transferable PDAs |
| Audit Logging | On-chain reporting | PDA log entries |
| Risk Escalation | Flagged transactions | Chainalysis triggers |
Requested Outcome
VERITAS seeks a No-Action Interpretation confirming that a non-custodial identity & reporting infrastructure for digital asset business payments does not constitute money transmission.
- Wallet custody remains with the user
- Protocol does not initiate, route, or hold funds
- Revenue derived only from compliance credentials + reporting