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Crypto Conversion Transaction — Compliance Checklist

M1 → JSON(hex) → .fin → Crypto (USDT/BTC/ETH) — End‑to‑End Controls

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How to use

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Critical controls: Legal entity & signatories, multi‑currency bank accounts, Swift.net access, bank whitelist of receiving server, POF authenticity, .fin signature validation, regulated liquidity providers, secure smart contract & address controls, AML/KYC & regulatory compliance.

1) Entity & Identity

Legal entity validity (registry, charter, Good Standing)

Authorized signatories verified; in‑person/video meeting held

CIS (Company Identity Statement) received and validated

UBO identified; sanctions/PEP screening completed

Business purpose and fund nature (M1) aligned

Operational address/contact validated (lease/bills, etc.)

2) Banking & Swift.net

Multi‑currency accounts at a reputable international bank

Operating history & Swift.net registration

Swift.net access granted and linked to accounts

Bank officer verified (corp email/direct line); callback done

Receiving server whitelisted in bank network

Account ↔ server link configured and tested

Emergency halt procedure documented (bank/server)

3) Funds & POF

Original POF per deal (bank‑issued with seal/signature)

Direct callback with issuing bank (e.g., UBS Geneva)

POF amount/currency/account consistency check

Legitimacy of source (on‑ledger M1) documented

No third‑party liens/claims confirmed

4) Server & Security

Receiving server location/ownership/access controls clear

TLS, HSM/key mgmt, multisig, etc. in place

Vulnerability scans, monitoring, audit logs enabled

Time sync (NTP) & log retention policy set

Data protection (encryption/access rights) compliant

5) Conversion & Files (.fin)

M1→JSON(hex)→.fin modules installed & function‑tested

Swift.net digital signature validation procedure

.fin integrity (hash/checksum) recorded

Sandbox / small‑value test transfer successful

Audit trail for convert/sign/transfer preserved

6) Liquidity Providers (Exchanges / LPs)

Accounts opened and authorized signers approved

Regulatory status/license/VASP registration confirmed

Address allowlist and corporate wallets enforced

Custody/settlement SOP and daily reconciliation

Fees, slippage, FX, gas limits configured

Counterparty AML/KYC policies received & reviewed

7) Smart Contract & Address Controls

Contract code reviewed/audited (or 3rd‑party report)

Deploy chain/version/ChainID documented

Payout address list (allowlist) dual‑approved

Emergency controls (pause/guardian) validated

Testnet/small dry‑run before production

8) Regulatory, Tax & Accounting

FATF Travel Rule / reporting obligations met

KYC/KYB & sanctions (SDN/UN/EU) screening done

Cross‑border transfer/permits/licenses satisfied

Accounting (IFRS/GAAP) and audit evidence ready

Tax exposure (VAT/withholding/crypto tax) assessed

Record retention pack (contracts/POF/signatures/logs/TxIDs)

9) Post‑Trade Ops & Reconciliation

Daily reconciliation: bank, server, exchange, on‑chain

Bundle receipts/TxIDs/bank confirms for archive

Escalation matrix & contact tree tested

Periodic risk reviews and management reporting

* Based on the provided process and common compliance practice. Obtain independent legal, regulatory, and tax advice before any transaction.