Trust & compliance
Partners of record today.Our own licences next.
Trust in payments is earned in a specific order: controls first, partners of record second, licenses third. This page states exactly where Splash is on that path — nothing more, nothing less.
Splash is not yet a licensed money-services business. Today, partners of record carry out the regulated activities; Splash operates the software and settlement layer between them.
Rent the license, then own it
The honest sequence for a new corridor: run on partners who already hold the licenses, prove volume and controls, then bring the licenses in-house. The roles that needs, and where each stands today. A counterparty is named once its agreement is signed:
| Role | What it means | Status |
|---|---|---|
| Payout of record | A local disbursement partner of record holds the licence and the client relationship in the destination market. Splash instructs; the partner pays out. | Not yet signed |
| Collection of record | A provider of record holds incoming USD. This is the one role with a named provider anywhere on this page, because it is the one that is live. | Airwallex · live on the testnet corridor |
| FX and liquidity | A regulated venue prices and fills the USD leg, sourced per corridor as volume justifies a dedicated agreement. | Not yet signed |
| Client-asset custody | Client funds sit with a custodian of record, never with Splash. splash_core structurally cannot hold a value-bearing field, and CI enforces that on every push. | Not yet signed |
The licensing path
- In preparation
Labuan FSA — money-broking application under preparation with counsel.
- Planned
Further licences are sequenced by corridor demand, and none is named until an application is filed.
Audit trail by construction
Every settlement produces a tamper-proof, encrypted audit record stored permanently and anchored on Sui, retained for seven years. Records are private by default; regulators and auditors can be granted visibility on authorization — decryption is a permissioned act, not a data request. This aligns with Sui's regulator-visible confidential-transfer direction: confidential to the public, verifiable to the people who are supposed to verify.
Controls that gate every payment
- Human approval
Every payment is prepared by Zeke and released only by a human on the Action Queue — maker-checker, with dual approval above your threshold.
- Corridor gating
Corridors arm and pause under explicit controls; settlement halts on a peg deviation or compliance flag before any value moves.
- Partner custody
Partners of record hold client funds. Splash-side control is maker-checker — Zeke prepares, a named human releases — and splash_core holds no client value, which is a property CI enforces rather than a key policy asserted in prose.