ARCHIVED VERSION 8.0 — superseded by version 9.0 with effect from 2 November 2026; for an existing customer it applies until they accept version 9.0 on sign-in, and until 30 November 2026 at the latest. Source: commit 85b0dac in our source repository. Kept unchanged for reference; it is not the current text.
---
title: "Regulatory Status & Partner Disclosure"
version: "8.0"
lastReviewed: "2026-10-12"
---
# Regulatory Status & Partner Disclosure
This page sets out CashXChain's own regulatory status, the licensed institutions through which the regulated parts of our service are provided, and who issues the stablecoins used where an Order is settled via a Stablecoin.
Every authorisation stated below links to the public register entry of the competent authority, so that each can be checked independently. Where a register cannot be linked directly, the entry names the source it rests on.
## 1\. Our regulatory status
**CashXChain Inc.** is registered with FinCEN as a Money Services Business. As a financial institution for purposes of the U.S. Bank Secrecy Act, it is subject to U.S. federal anti-money-laundering regulation under FinCEN's regulations for money services businesses (31 CFR Chapter X), and it maintains a written Anti-Money Laundering Compliance Program under them. Its registration is set out in full below.
**CashXChain UG (haftungsbeschränkt)** operates the CashXChain platform and is the contracting party for every customer agreement. It is a technology infrastructure provider. It is not a bank, credit institution, payment institution, e-money institution, crypto-asset service provider, broker, investment firm or financial advisor, and it is not authorised or supervised as such under [PSD2](https://eur-lex.europa.eu/eli/dir/2015/2366/oj), [MiCAR](https://eur-lex.europa.eu/eli/reg/2023/1114/oj), [KWG](https://www.gesetze-im-internet.de/kredwg/), [ZAG](https://www.gesetze-im-internet.de/zag_2018/) or any other financial services regulation (all sources retrieved 19 August 2026).
**Funds and advice.** Neither company holds, transmits or custodies customer funds, and neither provides financial, investment, tax or legal advice. All regulated payment services, crypto-asset conversions, fiat on/off-ramps, custody and settlement are executed exclusively by licensed and regulated partner institutions in their own names and under their own regulatory authorisations. Use of the CashXChain platform does not constitute a financial services relationship with CashXChain UG (haftungsbeschränkt) or CashXChain Inc.
## 2\. What this means for you
When you use CashXChain, you are using a technology platform that connects and orchestrates regulated services. The regulated payment, currency-conversion, custody and settlement steps are carried out by our licensed Partner institutions, each in its own name and under its own authorisation. Your funds are never held by CashXChain.
## 3\. At a glance
Circle is an issuer, not a Partner: where an Order is routed via a Stablecoin, settlement may use a token Circle issues, but you enter into no contract with Circle through us. The rows marked *in use* below it are Partners, and you enter into a contractual relationship with each of them in addition to your contract with us. Which Partner terms you accept, and how, is set out in clause 6 of the Terms of Service and is not repeated here. The entries marked *under evaluation* provide no part of the service today.
## 4\. Stablecoin issuer
### Circle
**Entity.** In the European Economic Area, both USDC and EURC are issued by **Circle Internet Financial Europe SAS**, Circle's French subsidiary. Outside the EEA, USDC is issued by **Circle Internet Financial, LLC**.
**Role.** Issues the stablecoins used where an Order is settled via a Stablecoin, redeems them, and holds the reserves that back them. Circle is a stablecoin issuer, not a payment or custody Partner of CashXChain.
**Regulatory status — EEA.** Circle Internet Financial Europe SAS is licensed as an electronic money institution by the Autorité de contrôle prudentiel et de résolution (ACPR), the French prudential authority attached to the Banque de France, with effect from 1 July 2024 under the EU E-Money Directive (EMD2), and is entitled to provide payment services under PSD2 as part of that authorisation. The authorisation is listed in the French [REGAFI register](https://www.regafi.fr/) (retrieved 27 August 2026), which is where it can be checked.
**Regulatory status — elsewhere.** Circle holds a New York BitLicense from the [New York State Department of Financial Services](https://www.dfs.ny.gov/virtual_currency_businesses) (since 2015; retrieved 19 August 2026), is a FinCEN-registered money services business, and holds money transmitter licences across the United States, which Circle lists state by state on its own [licences page](https://www.circle.com/legal/licenses) (retrieved 27 August 2026). On 10 July 2026 Circle received [final OCC approval](https://www.circle.com/pressroom/circle-receives-final-occ-approval-to-establish-national-trust-bank) (retrieved 19 August 2026) to operate Circle National Trust, a federally regulated national trust bank providing fiduciary digital-asset custody, with further authorisations in the United Kingdom, Singapore, Bermuda and Canada.
**How MiCAR treats these tokens.** Both USDC and EURC are **electronic money tokens** and are therefore governed by **Title IV** of MiCAR, not Title III. Title III applies to asset-referenced tokens, which reference a basket rather than a single official currency, and neither USDC nor EURC is one. Two consequences of Title IV matter to a holder, and both can be checked rather than assumed:
- The issuer must publish a crypto-asset white paper. Circle publishes one for each token: [MiCA USDC White Paper](https://www.circle.com/legal/mica-usdc-whitepaper) and [MiCA EURC White Paper](https://www.circle.com/legal/mica-eurc-whitepaper) (both retrieved 27 August 2026).
- A holder has a right of redemption at par value, at any time. Circle's [MiCA Redemption Policy](https://www.circle.com/legal/mica-redemption-policy) (retrieved 27 August 2026) sets out how that right is exercised.
**Reserves.** Circle publishes the composition of the reserves and monthly third-party attestations at [circle.com/transparency](https://www.circle.com/transparency) (retrieved 27 August 2026).
**Why this matters to you.** Where an Order is routed via a Stablecoin, the token's issuer and the rules it answers to are part of your risk picture even though you never contract with it. An electronic money token under Title IV is redeemable at par from a supervised issuer — which is why the Stablecoins used on our platform are electronic money tokens and not tokens that offer neither.
**Documents.** [Licences](https://www.circle.com/legal/licenses) · [EEA Terms of Use](https://www.circle.com/legal/eea-terms) · [USDC Terms](https://www.circle.com/legal/usdc-terms) · [EURC Terms](https://www.circle.com/legal/eurc-terms) · [MiCA Redemption Policy](https://www.circle.com/legal/mica-redemption-policy) · [Privacy Policy](https://www.circle.com/legal/privacy-policy) · [Transparency and reserves](https://www.circle.com/transparency) (all retrieved 27 August 2026)
## 5\. Our regulated Partners
Each licensed institution below performs regulated steps in our service under its own authorisation, in its own name and on its own regulatory responsibility.
### Sokin
**Entity.** Plata Capital Canada Inc., trading as Sokin. 333 Bay Street, Suite 2400, Toronto ON M5H 2T6, Canada. Sokin is a trading name used by companies in the Plata Capital group. The group company that holds the name is Plata Capital Limited, registered in England and Wales under company number 10958599, registered office c/o Mishcon de Reya, Africa House, 70 Kingsway, London WC2B 6AH ([Companies House](https://find-and-update.company-information.service.gov.uk/company/10958599), retrieved 26 August 2026). The entity that contracts with you is the Canadian one.
**Role.** Accounts in your own business name, local and international payments, and currency conversion.
**Regulatory status.** Plata Capital Canada Inc., operating as Sokin, is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business. FINTRAC's [Money Services Business Registry](https://fintrac-canafe.canada.ca/msb-esm/reg-eng) lists it as *Registered* under registration number **N300000117**, first approved on 10 April 2019 and valid until 6 February 2028, for foreign exchange, money transferring, virtual currency and payment services (retrieved 8 October 2026). As Sokin sets out on its [regulation page](https://sokin.com/legal/regulation) (retrieved 8 October 2026), Plata Capital Canada Inc. is also registered with the Bank of Canada under the Retail Payment Activities Act (RPAA); registered payment service providers are listed in the Bank of Canada's [PSP registry](https://www.bankofcanada.ca/regulatory-oversight/retail-payments/psp-registry/) (retrieved 8 October 2026).
**The rest of the group.** Sokin operates through a different company in each jurisdiction, and the authorisations differ accordingly. The table follows [Sokin's regulation page](https://sokin.com/legal/regulation) (retrieved 30 September 2026). It is here so that a reference you come across elsewhere can be placed — none of these entities other than the Canadian one is your counterparty, and no authorisation of theirs is relied on in our service.
| **Jurisdiction** | **Entity** | **Authority and reference** |
| --- | --- | --- |
| **Canada — yours** | Plata Capital Canada Inc. | FINTRAC money services business N300000117; Bank of Canada under the RPAA |
| EEA | Plata Capital Europe AS, Oslo | Financial Supervisory Authority of Norway, electronic money institution, FRN 995073064, passported into the EU |
| United Kingdom | Plata Capital UK Limited | Financial Conduct Authority, electronic money institution, reference 1029250. Also a distributor of Modulr FS Limited (FCA FRN 900573) |
| United States | Plata Capital USA Inc | Registered with FinCEN as a money services business; works with regulated US banking partners |
| Australia | Sokin Australia Pty Ltd | ASIC, AFSL 536975; AUSTRAC reporting entity and registered independent remittance dealer; AFCA member 92855 |
| UAE | Sokin DIFC Limited | Dubai Financial Services Authority, Category 3D Money Service Provider, FRN F011898 |
| Singapore | Sokin Capital Singapore Pte. Ltd. | Monetary Authority of Singapore, major payment institution |
| India | Plata Capital India Private Ltd | Services provided with NSDL Payments Bank Limited, a payments bank licensed by the Reserve Bank of India |
**Acceptance.** You accept Sokin's Terms and Conditions through us, when you accept our Terms of Service, and the record of that acceptance goes to Sokin with your onboarding documents. Sokin then runs its own business verification before your accounts are opened.
**Operational limits.** Card acceptance and card issuing are not available through the embedded solution. Stablecoin support is limited to USDT and USDC on the Ethereum and Tron networks. Accounts in your own business name are available in GBP, EUR, USD and CAD; other currencies are held in pooled accounts in Sokin's name with a reference that identifies you.
**Why we work with Sokin.** Sokin provides accounts in your own business name in GBP, EUR, USD and CAD across the corridors we operate and settles on local rails in each of them. In every case, the funds are held by Sokin, not by us.
**Documents.** [Platform Terms & Conditions](https://sokin.com/platform-terms-conditions) (PDF, dated March 2026) · [Privacy Policy](https://sokin.com/privacy-policy) · [How Sokin is regulated](https://sokin.com/legal/regulation) (retrieved 30 September 2026; the others 27 August 2026)
Where Sokin needs further information about a payment or about you, it may request it through us.
### Stablegate
**Entity.** STGG AG, operating under the brand name Stablegate. Dammstrasse 16, 6300 Zug, Switzerland. Commercial Register of the Canton of Zug, CHE-282.984.669.
**Role.** Stablecoin transit and settlement.
**Regulatory status.** A Swiss financial intermediary that carries out customer due diligence, monitoring and reporting under the [Swiss Anti-Money Laundering Act (AMLA)](https://www.fedlex.admin.ch/eli/cc/1998/892_892_892/en). Its Terms of Business state that it is a member of a [FINMA-recognised self-regulatory organisation](https://www.finma.ch/en/authorisation/self-regulatory-organisations-sros/) (retrieved 27 August 2026) under member No. 101275. **It is not directly licensed by FINMA, and it is not authorised under MiCAR or by any EU or EEA financial supervisory authority.** SRO membership is supervision for anti-money-laundering purposes; it is not a licence to provide financial services.
**Contracting entity.** STGG AG, the Swiss company named above. Stablegate's own onboarding and its Terms of Business govern your contract with it, including the law that applies to that contract.
**Why we work with Stablegate.** Moving between official currency and a stablecoin needs a counterparty that is supervised for anti-money-laundering purposes and settles on both SEPA and public networks. Stablegate does both under one contract.
**Documents.** [Terms of Business](https://docs.stablegate.com/docs/verification/common/terms) (retrieved 27 August 2026) · [Privacy Policy](https://docs.stablegate.com/docs/verification/common/privacy) · [Non-Serviced Countries](https://docs.stablegate.com/docs/verification/common/countries) · [Non-Serviced Business Sectors](https://docs.stablegate.com/docs/verification/common/business) · [Document Requirements](https://docs.stablegate.com/docs/verification/common/documents) (all retrieved 19 August 2026)
### Stripe
**Entity.** Stripe Technology Europe, Limited. Address as recorded on the Central Bank of Ireland register: P.O. Box 559, Dublin 1, Ireland.
**Role.** Card acquiring and payment processing.
**Regulatory status.** Authorised as an electronic money institution under Regulation 9 of the European Communities (Electronic Money) Regulations 2011 (as amended), which implement EMD2 in Ireland, and supervised by the Central Bank of Ireland. The register records the entity type as "E-Money Institutions PSD2", which carries passporting across the EEA.
**Why we work with Stripe.** Card acceptance requires an acquirer authorised in the EEA. Stripe covers the card rails our customers use and settles into the same corridors we operate.
**Documents.** [Central Bank of Ireland register entry, reference C187865](https://registers.centralbank.ie/FirmDataPage.aspx?firmReferenceNumber=C187865) (retrieved 27 August 2026) · [Stripe legal pages (Ireland)](https://stripe.com/ie/legal) · [Connected Account Agreement](https://stripe.com/legal/connect-account) · [Services Agreement](https://stripe.com/legal/ssa) · [Privacy Policy](https://stripe.com/privacy) (all retrieved 19 August 2026)
Stripe's Connected Account Agreement calls our contract with you the "Platform Provider Agreement". Where you have no access to the Stripe Dashboard, that agreement directs you to contact us, not Stripe, for support on the Stripe services.
## 6\. Under evaluation
None of the four below provides any part of our service today. They are listed because they are under active evaluation. **No authorisation of any of them is claimed or relied upon anywhere in this disclosure.** Where an entry sets out a public register record, it does so only so that a reference you come across elsewhere can be placed. If an engagement is agreed, it moves into the section above with its licensed entity, its role and its register entry, in the same form as the Partners there.
### Binance
Under evaluation as a Partner. The scope of any engagement and the contracting Binance entity are not settled.
### BitGo
Under evaluation as a Partner for qualified custody, wallet infrastructure and stablecoin settlement. The scope of any engagement and the contracting BitGo entity are not settled.
**The public record.** BitGo operates through a different company in each jurisdiction. The entries below were checked against the register named in each on 27 September 2026.
| **Entity** | **Authority and reference** |
| --- | --- |
| BitGo Europe GmbH, Mainzer Landstraße 10, 60325 Frankfurt am Main, Germany | Federal Financial Supervisory Authority (BaFin) — crypto-asset service provider under MiCAR since 9 May 2025 for custody and administration and for transfer services, and since 2 September 2025 also for exchange, execution and reception and transmission of orders, passported across the EEA ([ESMA interim MiCA register](https://www.esma.europa.eu/sites/default/files/2024-12/CASPS.csv), retrieved 8 October 2026); also recorded as a crypto custodian and as a payment institution in [BaFin's company database](https://portal.mvp.bafin.de/database/InstInfo/institutDetails.do?cmd=loadInstitutAction&institutId=157322) (BaFin-ID 50085544; retrieved 8 October 2026) |
| BitGo Bank & Trust, National Association, Sioux Falls, South Dakota, USA | Office of the Comptroller of the Currency — on 12 December 2025 the OCC [conditionally approved](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-125.html) the conversion of BitGo Trust Company, Inc. into a national trust bank (retrieved 8 October 2026); BitGo [states](https://investors.bitgo.com/news/news-details/2025/BitGo-Secures-OCC-Approval-to-Convert-to-Federally-Chartered-National-Trust-Bank/default.aspx) that its trust company has operated as BitGo Bank & Trust, N.A. since that day (retrieved 8 October 2026) |
| BitGo New York Trust Company, LLC | New York State Department of Financial Services — limited purpose trust charter since March 2021, listed on the [NYDFS list of virtual currency businesses](https://www.dfs.ny.gov/virtual_currency_businesses) (retrieved 8 October 2026) |
BitGo lists its other entities and authorisations on its own [disclosures page](https://www.bitgo.com/legal/disclosures/) (retrieved 27 September 2026).
### Bridge
Under evaluation as a Partner for stablecoin orchestration, issuance and on- and off-ramps. Bridge is a Stripe company: Stripe completed its acquisition of Bridge on 4 February 2025 ([Stripe announcement](https://stripe.com/newsroom/news/stripe-completes-bridge-acquisition), retrieved 8 October 2026). The scope of any engagement and the contracting Bridge entity are not settled.
**The public record**, as checked on 27 September 2026:
| **Entity** | **Authority and reference** |
| --- | --- |
| Bridge Building S.A., 26 Boulevard Royal, L-2449 Luxembourg | Commission de Surveillance du Secteur Financier (CSSF) — crypto-asset service provider under MiCAR since 29 June 2026, for custody and administration, exchange, execution of orders and transfer services, passported across the EEA ([ESMA interim MiCA register](https://www.esma.europa.eu/sites/default/files/2024-12/CASPS.csv), retrieved 8 October 2026). Bridge also states, on its [licence page](https://www.bridge.xyz/legal/licenses/non-us-licenses) (retrieved 8 October 2026), that it holds a CSSF electronic money institution licence (W00000024) |
| Bridge Building Inc., Delaware, USA | Money transmitter licences in 33 U.S. jurisdictions, NMLS ID 2450917, according to Bridge's own [licence list](https://www.bridge.xyz/legal/licenses/us-licenses-and-registrations) (last updated 8 December 2025; retrieved 8 October 2026), which can also be looked up on NMLS Consumer Access; registered with FinCEN as a Money Services Business, MSB Registration No. 31000339846068 ([FinCEN MSB Registrant Search](https://www.fincen.gov/resources/msb-state-selector), retrieved 8 October 2026) |
| Bridge Ventures LLC | Office of the Comptroller of the Currency — [preliminary conditional approval](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1365.pdf) of 12 February 2026 to organise Bridge National Trust Bank, New York; final approval follows only once all pre-opening requirements are met (retrieved 8 October 2026) |
Bridge states that USDC and EURC — both electronic money tokens under MiCAR — are the only stablecoins it supports for users in the EEA ([Bridge documentation](https://apidocs.bridge.xyz/get-started/introduction/what-we-support/payment-routes.md), retrieved 27 September 2026).
### Coinbase
Under evaluation as a Partner for the Coinbase Developer Platform and embedded wallets. The contracting entity and the authorisation it would rely on are not settled.
Separately, Coinbase, Inc. and Coinbase Crypto Services, LLC act as sub-processors in our v1 and v2 validation environments only, as disclosed in our Sub-processor List. That is a data-processing relationship, not a regulated Partner relationship.
## 7\. Our technology providers
The following provide infrastructure only and perform no regulated financial step: Cloudflare (network, security, hosting and edge compute, AI inference for the website assistant, and cookieless analytics), Amazon Web Services (cloud hosting, Frankfurt), Resend (email delivery), and Google Workspace (productivity and email). Full processing details, locations and transfer safeguards are in our Sub-processor List.
## 8\. Intellectual property
The core methods behind our service are protected by utility models registered at the [German Patent and Trade Mark Office (DPMA)](https://www.dpma.de/english/) and searchable in [DPMAregister](https://register.dpma.de/DPMAregister/pat/uebersicht) (both retrieved 26 August 2026); the full portfolio, with each register entry, is on IP & Copyright.
## 9\. Licences and registrations
CashXChain Inc. is registered with FinCEN as a Money Services Business (clause 1). Neither CashXChain company holds a banking, payment, e-money or crypto-asset service licence, and CashXChain Inc. holds no U.S. state money transmitter licence. Our corporate registrations are listed in our Licenses & Registrations overview.
## 10\. Updates and contact
We keep this page current as our arrangements evolve, and a Partner is added here before it provides any part of the service, and removed promptly when it ceases to. Questions can be sent to compliance@cashxchain.com or legal@cashxchain.com.