Helvetic Broker is a portfolio tracking and informational platform. We do not execute, transfer, or custody any funds on behalf of users. API keys that are stored or processed on our servers are strictly read-only, ensuring we can only retrieve data and cannot perform any transactions. Keys with higher permissions (such as transfers) are stored and processed only on the user’s mobile device, encrypted in the device’s secure trust store. These keys can only be accessed after user authentication via biometrics or PIN code, meaning only the user can control and use their keys. We may help prepare unsigned transaction suggestions (e.g., for DEX interactions), but the user must always execute the final action themselves in their own wallet or third-party service.

Under current U.S. federal and state regulations, Helvetic Broker’s read-only server-side keys and user-controlled transaction keys do not classify the platform as a money transmitter or broker-dealer:

• The Financial Crimes Enforcement Network (FinCEN) defines a “money transmitter” as an entity that accepts and transmits funds. Since we never hold or move any assets and server-side keys are read-only, we do not meet this definition.
• The Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) regulate trading execution and custody services. We do not execute trades or custody funds, so we are not subject to SEC broker-dealer or CFTC intermediary requirements.
• At the state level, Money Transmitter Licenses (MTLs) are required only for firms that handle, transmit, or store cryptocurrency. Our hybrid model—server-side read-only keys and user-side transaction-only keys—keeps us exempt.

In the UK, the Financial Conduct Authority (FCA) oversees crypto-related activities. Key points for our model:

• The FCA registers firms providing custody or exchange services under the Payment Services Regulations (PSRs). We do not hold customer funds or provide payment services.
• Under the Money Laundering Regulations (MLRs), we are exempt as a data-only provider using read-only server-side keys.
• Transaction-capable keys remain fully under the user’s control on their mobile device, with no access by Helvetic Broker.
• We do not fall under the FCA’s regulated activities because we neither execute transactions nor custody assets.

Swiss regulation by FINMA categorizes virtual asset service providers (VASPs) under the Anti-Money Laundering Act (AMLA). For Helvetic Broker:

• Registration with an SRO (self-regulatory organization) is required only for firms that transmit or hold crypto assets. Our server-side read-only keys and user-side storage of transaction keys do not qualify.
• We do not act as an intermediary or custodian, as transaction-capable keys never leave the user’s device and remain encrypted in the secure trust store.
• We remain a technology provider, not a financial intermediary.

Under the EU’s MiCA (Markets in Crypto-Assets) regulation:

• Crypto-Asset Service Providers (CASPs) must register and meet AML/KYC requirements if they execute transactions or custody assets.
• Since all keys on our servers are strictly read-only and any transaction-capable keys are stored and processed only on the user’s device, we are not classified as a CASP.
• No authorization or passporting under MiCA is required for purely informational and user-controlled services.