1. Statement
JIL Sovereign Technologies, Inc. (“Operating Co”) is not a Money Services Business or Money Transmitter under 31 U.S.C. § 5330 or the regulations of the Financial Crimes Enforcement Network (FinCEN), and is not licensed as a Money Transmitter under the Money Transmission Acts of any US state. Operating Co does not hold, route, or transmit funds in any jurisdiction.
2. Operational Basis
The Platform performs verification, attestation, monitoring, and signaling. When a milestone is approved, the Platform transmits an HMAC-signed authorization signal to the Foundation's designated banking or custody integration. The Foundation's bank or custodian executes the actual transfer on Foundation's rails. Operating Co never has custody of, control over, or signing authority for any account holding charitable funds.
3. Per-Jurisdiction Posture
- United States: No state-level money transmission license required across all 50 states + DC + territories. Foundations operate within their existing 501(c)(3) regulatory framework.
- Switzerland: No FINMA banking license; no payment institution license. Platform role does not constitute Geldueberweisung or Vermoegensverwaltung under Swiss law.
- UAE: No CBUAE license. Platform role is technology services, not financial services. UAE charitable association operates within Cabinet 58/2020.
- Singapore: No MAS license (no captured activity).
- Brazil: No BACEN license. Platform operates as technology service.