Regulatory Status
1. Core Regulatory Classification
FinTEM (registered as Finoment LLC in the USA) is strictly classified as a Financial Technology Infrastructure Provider.
- 1.1. No Banking License Required: FinTEM does not provide banking services, currency exchange, or deposit-taking activities. As a pure-play technical orchestration layer, our operations do not fall under the licensing requirements of traditional banking or “Money Service Business” (MSB) regulations in our operating jurisdictions.
- 1.2. Technical Facilitator: Our role is limited to providing the software environment (SaaS) and API connectivity that enables data transmission between Merchants and regulated financial entities.
2. Flow of Funds and Custody
- 2.1. Non-Custodial Model: FinTEM does not receive, hold, transmit, or take possession of client funds at any stage of the transaction lifecycle.
- 2.2. Settlement Authority: All financial settlements, clearing, and fund movements are executed exclusively by licensed Payment Service Providers (PSPs), Acquiring Banks, and regulated financial institutions with whom the Merchant maintains a direct contractual relationship.
3. Compliance with Regional Standards
While FinTEM is not a regulated financial entity, we strictly adhere to global compliance frameworks to ensure the integrity of our network:
- 3.1. USA (Wyoming): Finoment LLC operates in compliance with Wyoming’s blockchain and fintech-friendly corporate statutes, focusing on software services and technical data management.
- 3.2. Emerging Markets (CIS, MEA, Africa): FinTEM coordinates with regional partners who hold valid licenses from their respective Central Banks to ensure that all localized routing complies with regional monetary policies.
4. Data Protection and Security Standards
FinTEM’s regulatory posture is supported by high-level security audits and data protection compliance:
- 4.1. Privacy: We comply with the General Data Protection Regulation (GDPR) regarding the processing of transactional metadata.
- 4.2. PCI-DSS Framework: Although we do not store card data, our infrastructure is built to align with PCI-DSS Level 1 technical security requirements to support our partners’ compliance status.
5. Independent Responsibility of Merchants
It is the sole responsibility of the Merchant to ensure that their business model, licensing (e.g., Forex, iGaming), and use of the FinTEM API comply with the laws of their operating jurisdiction and the terms of their licensed Payment Service Providers.