Automation prepares the work. Authorised people approve and execute.

Human approval is a control, not a bottleneck. The agentic layer monitors continuously, prepares work and raises exceptions. It does not approve or execute regulated activity. Every gate below requires an authorised operator decision, recorded with the operator identity, the timestamp and the compliance snapshot the decision was made on.

Launch a compliant offering with filing, allocation and post-close controls.

Owner

Operations, with registered principal sign-off at filing and closing

Approval gates

2 — regulatory filing (01.04) and closing allocation (01.06)

Evidence

Document hashes anchored to IPFS; filing confirmations and allocation computation written to the ledger

Systems

Middesk · SEC EDGAR · IPFS · blue sky filing agent · policy engine

1. OPS-01.01

   Issuer onboarding

   Entity KYB, beneficial ownership identification under the FinCEN CDD rule (US issuers no longer file BOI reports after the 14 Aug 2026 final rule), background check, platform MSA execution, account provisioning under issuer-role access control.

2. OPS-01.02

   Offering structuring

   Security type, exemption selection (Reg D 506(b)/(c), Reg A+, Reg S), token model under the SEC staff Statement on Tokenized Securities (28 Jan 2026), pricing mechanics, allocation method, minimum and maximum raise, closing schedule.

3. OPS-01.03

   Document preparation

   PPM, subscription agreement, investor questionnaire and accreditation form generation, hash-anchored for tamper evidence.

4. OPS-01.04

   Regulatory filing

   Form D to EDGAR, blue sky notice filings across target states (Rule 506 offerings stay state-preempted but notice filings still apply), fee coordination, confirmation tracking under SLA.

   Human approval gate
5. OPS-01.05

   Distribution

   Portal activation, offering room gated by compliance status, subscription open, real-time allocation tracking, partial close management.

6. OPS-01.06

   Closing and allocation

   Minimum raise confirmation, subscription finalisation, escrow release trigger, pro-rata or discretionary allocation, cap table recording.

   Human approval gate
7. OPS-01.07

   Post-close administration

   Position confirmations, certificate issuance, transfer restriction ledger entry, 1099 and K-1 setup, reporting cadence activation.

Admit only investors who meet identity, eligibility and suitability rules.

Owner

Compliance

Approval gates

1 — compliance officer decision on the completed case (02.07)

Evidence

Verification results, screening hits, suitability score and the operator decision record, retained per investor

Systems

Persona · Middesk · Parallel Markets · ComplyAdvantage · policy engine

1. OPS-02.01

   Account registration

   Email verification, profile collection, jurisdiction self-declaration, device fingerprinting, session initialisation.

2. OPS-02.02

   Identity verification

   Government ID capture with liveness detection, document extraction, database cross-reference, 200+ country coverage.

3. OPS-02.03

   Entity verification

   EIN, secretary of state registry, beneficial owners of legal entity customers under the FinCEN CDD rule, verified at the first account per the 13 Feb 2026 exceptive relief and again on risk triggers, state good-standing check.

4. OPS-02.04

   Accreditation verification

   Income (two years of returns, W-2), net worth statements, professional licence (Series 7, 65 or 82) or entity assets, with expiry tracking. For Rule 506(c), the minimum-investment path in the SEC staff letter of 12 Mar 2025: at least $200,000 for an individual or $1,000,000 for an entity, written representations, and no third-party financing of the purchase.

5. OPS-02.05

   Sanctions and AML screening

   OFAC SDN, EU consolidated, HMT, UN and FinCEN 314(a), plus PEP check, adverse media scan, geographic risk scoring, 30-day rescan.

6. OPS-02.06

   Suitability assessment

   Reg BI scoring across experience, risk tolerance, liquidity horizon, income and net worth relative to subscription size, concentration limits.

7. OPS-02.07

   Operator approval

   Review case with the full compliance profile, SLA-gated queue, compliance officer decision before access is provisioned.

   Human approval gate

Convert verified subscriptions into reconciled, approved allocations.

Owner

Operations, with compliance review before allocation

Approval gates

1 — compliance review of subscription, payment and compliance snapshot (03.05)

Evidence

Executed documents with signature audit trail, payment match records, allocation notice receipts

Systems

Policy engine · e-signature · wire and ACH · stablecoins from an allowlist of regulated issuers (USDC, RLUSD today)

1. OPS-03.01

   Eligibility gate

   Eleven dimensions evaluated: identity, entity, accreditation, sanctions, suitability, jurisdiction, offering access, subscription limits, investor count, affiliate status, holding period.

2. OPS-03.02

   Document execution

   Subscription agreement, risk disclosure, offering-specific addenda, e-signature capture with timestamped audit trail.

3. OPS-03.03

   Funding instruction

   Rail selection: wire with bank instructions, ACH pull, or a stablecoin from an allowlisted regulated issuer. The GENIUS Act takes effect by 18 Jan 2027; USDT and DAI are not accepted from US persons, and the allowlist is a policy setting that follows issuer licensing.

4. OPS-03.04

   Payment matching

   Automated reconciliation to subscription records, hash verification on-chain, bank reference for wire and ACH, retry queues for failed matches.

5. OPS-03.05

   Operator review

   Case assembled from subscription, payment and compliance snapshot. Approval routes to allocation; rejection routes to notice and refund.

   Human approval gate
6. OPS-03.06

   Allocation

   Cap table position creation, token minting where digital, custody wallet crediting, settlement confirmation, allocation notice delivery.

Settle and reconcile under configurable custody approval tiers.

Owner

Custody operations, under the four-tier approval engine

Approval gates

Threshold-driven — auto, single-sign, dual-control or committee quorum (04.02)

Evidence

Append-only hash-chained ledger meeting Rule 17a-4 (audit-trail or WORM option); 6 years for blotters and ledgers, 3 years for other records; examiner-accessible endpoint

Systems

Qualified custodian · RS256 JWT request signing · Chainlink Proof of Reserve · ledger

1. OPS-04.01

   Wallet provisioning

   Vault creation per offering at the qualified custodian, twelve wallet roles, threshold configuration, per-request RS256 JWT signing on every custodian API call. Where the broker-dealer partner holds crypto asset securities itself, its controls follow the SEC staff statement of 17 Dec 2025.

2. OPS-04.02

   Approval workflow

   Auto-approve below threshold, single officer, dual control, or committee quorum at a configurable N-of-M.

   Human approval gate
3. OPS-04.03

   Settlement execution

   On-chain submission through the custodian SDK: nonce management, gas estimation, broadcast, confirmation polling, finality check.

4. OPS-04.04

   Reconciliation

   Post-settlement balance reconciliation across vaults against cap table positions, discrepancy detection, exception queue, escalation routing.

5. OPS-04.05

   Ledger write

   Every custody movement recorded to the append-only hash-chained ledger, retained by Rule 17a-4 record type, examiner endpoint.

6. OPS-04.06

   Proof of reserve

   A Proof of Reserve adapter publishes verified custody balances on-chain, so auditors verify backing without relying on our representations.

Govern transfers and corporate actions across cap table and token ledgers.

Owner

Operations, with compliance clearance before execution

Approval gates

2 — restriction clearance (05.02) and structural action authorisation (05.06)

Evidence

Restriction analysis, recipient qualification record, synchronised cap table and on-chain transfer references

Systems

Rust distribution engine · XRPL · EVM · transfer agent · SEC EDGAR

1. OPS-05.01

   Transfer request

   Holder-initiated, with recipient identification, AML pre-check on the receiving wallet or entity, policy engine pre-evaluation before queue entry.

2. OPS-05.02

   Restriction check

   Rule 144 holding period, lock-up agreement check, right-of-first-refusal notification workflow, affiliate status analysis.

   Human approval gate
3. OPS-05.03

   Recipient qualification

   Receiving investor identity and accreditation verification, suitability re-evaluation for the specific security, sanctions rescan.

4. OPS-05.04

   Transfer execution

   Cap table position update, on-chain XRPL or EVM transfer, transfer agent notification, both ledger layers synchronised. The SEC proposal to modernise transfer agent rules for blockchain records (1 Sep 2026) is tracked on the calendar below.

5. OPS-05.05

   Distribution events

   Record date snapshot, per-holder pro-rata calculation in the Rust engine, multi-rail payment processing.

6. OPS-05.06

   Structural actions

   Splits, conversions, forced redemptions, mergers: cap table recalculation, token burn or mint, holder notifications, 8-K coordination where required.

   Human approval gate

Automate monitoring and preparation without delegating regulated authority.

Owner

Operations engineering; every output lands in a human queue

Authority

Monitor, prepare and escalate only. No agent approves, executes or files. Supervised as agentic AI under the FINRA 2026 Annual Regulatory Oversight Report.

Evidence

Agent identity, input snapshot and generated artefact recorded alongside the operator who acted on it

Systems

Rust distribution engine · keeper automation · review case queue · ledger

1. OPS-06.01

   Compliance monitor

   Flags expired identity verification, lapsed accreditation or an overdue sanctions rescan, and generates the review case for an officer.

2. OPS-06.02

   Settlement reconciliation

   Polls custody balances after settlement, compares against expected positions, raises an exception ticket above threshold.

3. OPS-06.03

   Filing preparation

   Watches offering milestones and drafts Form D amendments, blue sky renewal reminders and filing schedules. Filed only by an authorised principal at 01.04.

4. OPS-06.04

   Investor communications

   Subscription confirmations, funding instructions, allocation notices, distribution announcements, maturity notices, and Regulation S-P breach notices drafted for sending within 30 days.

5. OPS-06.05

   Yield distribution

   Validates coupon dates, computes per-holder amounts in the Rust engine, queues settlement for the 04.02 approval tier.

6. OPS-06.06

   Risk scoring

   Re-evaluates suitability and portfolio concentration against market conditions and updated financial profiles.

7. OPS-06.07

   Examiner readiness

   On-demand export of trade blotter, audit trail, investor files and cap table snapshot in examination format.