Compliance
This is the master page for everything CashXChain publishes on compliance, licensing and regulation: who we are and how we are registered, how the service is structured, which institutions perform the regulated steps, and how we handle anti-money-laundering, KYC / KYB, sanctions, transfer information, data protection and security. Each section states our position briefly and names the document that sets it out in full, so that this one page — also at legal.cashxchain.com/compliance — leads to every answer. It is a disclosure, not a term of the Terms of Service.
1. At a glance
| Question | Answer | Set out in |
|---|---|---|
| Who operates the platform, and who do customers contract with? | CashXChain UG (haftungsbeschränkt), Amtsgericht Traunstein, HRB 34664 | Contracting Entity & Governing Law |
| Is CashXChain registered with a U.S. authority? | Yes. CashXChain Inc. is registered with FinCEN as a Money Services Business and money transmitter under FinCEN MSB Registration Number 31000341178304, and is publicly listed in FinCEN ’s MSB Registrant Search. As a financial institution under the Bank Secrecy Act , it is subject to U.S. federal anti-money-laundering regulation. The registration is not a licence. CashXChain Inc. does not currently provide money transmission services and has no customer relationships with platform users | Licenses & Registrations |
| Does CashXChain hold a financial-services licence? | No. Neither CashXChain UG (haftungsbeschränkt) nor CashXChain Inc. holds a banking, payment, e-money or crypto-asset service licence, or a U.S. state money transmitter licence | Regulatory Status & Partner Disclosure |
| Who performs the regulated payment, exchange, custody and settlement steps? | Licensed and supervised Partners, each in its own name and under its own authorisation | Regulatory Status & Partner Disclosure |
| Does CashXChain hold customer funds? | No. Where funds are held, a Partner holds them under its own safeguarding obligations | Terms of Service, clauses 5 and 11 |
| Does every payment settle in a stablecoin? | No. Only where the route selected for an Order uses one; where it does, the stablecoin is typically held only in transit | Terms of Service, clause 11 |
| How is anti-money-laundering handled? | Partners carry the statutory obligations for the regulated steps. CashXChain Inc. maintains a written Anti-Money Laundering Compliance Program under the Bank Secrecy Act . CashXChain UG (haftungsbeschränkt) is not an obliged entity under § 2 GwG and may report voluntarily | Public AML Statement |
| How are businesses verified? | The business, its representatives and its beneficial owners are verified before the first transaction and reviewed during the relationship | KYC / KYB Notice |
| How are sanctions handled? | Customers, owners and counterparties are screened, and there is no dealing on a confirmed match | Public Sanctions Statement |
2. Our entities and registrations
2.1 CashXChain UG (haftungsbeschränkt) — Rosenheim, Germany; Amtsgericht Traunstein, HRB 34664; D-U-N-S® Number 317026184. It operates the platform and is the party to every customer agreement. It is a technology and orchestration provider: it holds no licence under PSD2 , MiCAR , KWG or ZAG , and it is not an obliged entity (Verpflichteter) within the meaning of § 2 GwG , so it has no direct reporting obligation under § 43 GwG and no freezing obligation under § 46 GwG .
2.2 CashXChain Inc. — New York, NY, USA; incorporated in Delaware, File No. 10567097. Registered with FinCEN as a Money Services Business and, as a financial institution under the Bank Secrecy Act , subject to U.S. federal anti-money-laundering regulation.
FinCEN registration. CashXChain Inc. is a Delaware corporation and a financial institution for purposes of the U.S. Bank Secrecy Act, registered with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, as a Money Services Business (MSB) and money transmitter under FinCEN MSB Registration Number 31000341178304. CashXChain Inc. is publicly listed in FinCEN’s MSB Registrant Search .
CashXChain Inc. is located at 48 Wall Street, Suite 1100, PMB 1024, New York, NY 10005, United States of America.
Check it yourself. Search the registration number in FinCEN’s MSB Registrant Search (retrieved 27 September 2026), or read the registration record as published by FinCEN (PDF, dated 27 September 2026), reproduced here unaltered.
CashXChain Inc. does not currently provide money transmission services. U.S. payment services are provided by licensed Partners. CashXChain Inc. maintains a written Anti-Money Laundering Compliance Program in accordance with the Bank Secrecy Act and applicable FinCEN regulations.
Registration with FinCEN as a Money Services Business is a federal registration requirement. It does not constitute a licence, approval, certification, endorsement or authorisation by FinCEN, and it does not replace any licence that may be required under applicable U.S. state law. CashXChain Inc. currently holds no U.S. state money transmitter licences and does not conduct activities for which such a licence is required.
CashXChain Inc. does not contract with, and does not maintain customer relationships with, users of the CashXChain platform. Use of the CashXChain platform does not, by itself, establish a customer relationship with CashXChain Inc. Customer agreements relating to the CashXChain platform are entered into with CashXChain UG (haftungsbeschränkt) or the applicable CashXChain operating entity, as specified in the relevant agreement.
2.3 Every registration, with its issuing authority, its reference and where it can be checked, is on Licenses & Registrations.
3. How the service works
3.1 CashXChain operates the technology and orchestration layer: the interfaces, the routing logic, the reconciliation and the reporting. We instruct Partners on the customer’s behalf and present the result.
3.2 The regulated steps — converting between official currency and stablecoin, holding funds, and executing the payment, transfer or exchange — are performed by licensed Partner institutions under their own licences. The statutory anti-money-laundering, sanctions and transfer-information obligations that attach to those steps sit with the Partners, inside their own regulatory perimeter.
3.3 Not every Order settles via a stablecoin. Whether one does depends on the corridor and on the route our routing logic selects; where it does, the stablecoin is typically held by a Partner only in transit. The stablecoins used are electronic money tokens under MiCAR . In the payment service, transfers are made only between accounts held at regulated providers, never to or from self-hosted wallets. The contractual position is in clauses 5, 10 and 11 of the Terms of Service.
3.4 We describe our position accurately and do not claim regulated status we do not have. Where a document in this Legal Center could be read as claiming otherwise, this page governs the reading.
4. Partners, issuer and institutions under evaluation
| Who | What they do | Entity you deal with | Supervised by | Status |
|---|---|---|---|---|
| Circle | Issues USDC and EURC | Circle Internet Financial Europe SAS (EEA) | ACPR / Banque de France | In use |
| Sokin | Named accounts, payments, currency conversion | Plata Capital Canada Inc. | FINTRAC, Bank of Canada | In use |
| Stablegate | Stablecoin transit and settlement | STGG AG | FINMA-recognised SRO, member No. 101275 | In use |
| Stripe | Card acquiring and payment processing | Stripe Technology Europe, Limited | Central Bank of Ireland | In use |
| Binance | Scope not settled | — | — | Under evaluation |
| BitGo | Custody, wallet infrastructure and stablecoin settlement; scope not settled | — | — | Under evaluation |
| Bridge | Stablecoin orchestration, issuance and on/off-ramps; scope not settled | — | — | Under evaluation |
| Coinbase | Developer platform and embedded wallets | — | — | Under evaluation |
4.1 Each Partner’s entity, authorisation and register entry — and, where a register cannot be linked directly, the source an entry rests on — is set out on Regulatory Status & Partner Disclosure. Institutions under evaluation provide no part of the service, and no authorisation of theirs is relied on.
5. Who is accountable
| Function | Person or address |
|---|---|
| Money Laundering Reporting Officer (MLRO) | Dr. Martin Israel, Managing Director — [email protected] |
| Data protection contact | [email protected]. No data protection officer is required; the assessment is in clause 14 of the Privacy Policy |
| Security and vulnerability reports | [email protected], under Responsible Disclosure |
| Complaints | [email protected], under the Complaints Procedure |
5.1 We appointed an MLRO although no statute requires CashXChain UG (haftungsbeschränkt) to. It is the person who owns financial-crime risk internally, and the escalation point for anything a member of staff, a customer or a Partner raises.
6. What the programme covers
| Area | Where it is described |
|---|---|
| Registrations, and what CashXChain itself holds | Licenses & Registrations |
| Partners, their authorisations, and the stablecoin issuer | Regulatory Status & Partner Disclosure |
| Who you contract with, governing law and forum | Contracting Entity & Governing Law |
| Anti-money-laundering posture, standards and controls, including CashXChain Inc.’s obligations under the Bank Secrecy Act | Public AML Statement |
| Sanctions screening and what we do on a match | Public Sanctions Statement |
| Business and beneficial-owner verification | KYC / KYB Notice |
| Information that must accompany a transfer | Travel Rule Notice |
| Businesses and countries we will not serve | Prohibited & Restricted Businesses |
| What customers may and may not do | Acceptable Use Policy |
| Conflicts of interest | Conflicts-of-Interest Disclosure |
| Personal data, and who processes it for us | Privacy Policy, Sub-processor List |
| Security controls | Security Statement |
| How we handle an incident or a data breach | Incident Notification Policy |
| Crypto-asset and settlement risk | Crypto-Asset Risk Warnings |
| Energy and environmental profile of settlement | Environmental Disclosure |
| Complaints and escalation to an authority | Complaints Procedure |
7. Voluntary reporting
7.1 CashXChain UG (haftungsbeschränkt) is not a Verpflichteter under § 2 GwG and has no reporting obligation under § 43 GwG . CashXChain Inc.’s obligations as a registered Money Services Business under U.S. law are described in clause 2 of the Public AML Statement and are not affected by this clause.
7.2 We reserve the right to report voluntarily to competent authorities where we become aware of indicators of money laundering, terrorism financing, sanctions evasion, fraud or other serious criminal activity. This includes criminal complaints under § 158 StPO . We do so in good faith and independently of any regulatory obligation, and we do not need a customer’s agreement to do it.
7.3 We also alert the relevant Partner, which is the obliged entity and which makes any report it owes under its own obligations.
7.4 Where a tipping-off prohibition binds a Partner, such as § 47 GwG or an equivalent rule, or where disclosure could prejudice an investigation, neither we nor the Partner will tell you that a report has been made or that an investigation is under way. Do not read the absence of a notice as the absence of a report.
7.5 We do not hold customer funds and cannot freeze them. Funds sit with a licensed Partner, and any hold is that Partner’s decision under its own obligations. What we can do is contractual: restrict access, decline instructions, and close accounts, under clause 24 of the Terms of Service.
8. What we expect of customers
8.1 Complete and current information about your business, its ownership and its control, and prompt notice when any of it changes.
8.2 Accurate originator and beneficiary information on every instruction, no structuring around thresholds or monitoring, and no use of the platform for an undisclosed third party.
8.3 Cooperation with information requests from us, from a Partner, or from an authority acting through us.
8.4 The full obligations are in clauses 8 and 14 of the Terms of Service and in the Acceptable Use Policy.
9. Raising something with us
9.1 Suspected financial crime, or a question about whether a use is permitted: [email protected].
9.2 A security vulnerability: [email protected], on the terms in Responsible Disclosure. We do not pursue researchers who follow it.
9.3 A complaint about the service or a decision we took: the Complaints Procedure sets out the timescales and names the competent authority if you remain dissatisfied.
9.4 A concern raised in confidence, including by a member of our own staff, can go to [email protected] and reaches the MLRO. We do not retaliate against anyone who raises a concern in good faith.
10. Review
We review this page and the documents it points to at least annually, and sooner where the law, our Partners or our services change. Every revision is recorded in the Versioned Terms Archive & Change Log.