Compliance

Clavestra Orbital operates as a regulated digital asset custody provider with full AML/CFT compliance at all entry and exit points.

Licensing Status

Swiss SRO Membership (VQF)

AML/CFT supervision as financial intermediary under Swiss AMLA

Regulatory body: FINMA (via VQF Self-Regulatory Organization)

In Progress

Gibraltar DLT Provider License

Full conduct regulation under 9 regulatory principles

Regulatory body: Gibraltar Financial Services Commission (GFSC)

Phase 2 — Planned

FINMA Crypto-Institution License

Direct FINMA supervision under new crypto-specific category

Expected availability: Late 2026 / Early 2027

Future

AML/CFT Framework

Customer Due Diligence (CDD)

  • ✓ Identity verification (passport, national ID)
  • ✓ Address verification (utility bill, bank statement)
  • ✓ Beneficial ownership identification
  • ✓ Source of funds verification
  • ✓ Enhanced due diligence for high-risk clients

Transaction Monitoring

  • ✓ Real-time sanctions screening (OFAC, EU, UN, SECO)
  • ✓ Suspicious activity detection and flagging
  • ✓ Suspicious Activity Reporting (SAR) procedures
  • ✓ Travel Rule compliance (FATF Recommendation 16)
  • ✓ Record retention (minimum 10 years per Swiss AMLA)

KYC Requirements for Clients

All clients must complete KYC verification before depositing or withdrawing funds. Clavestra serves B2B clients only — licensed financial service providers, payment processors, and institutional clients.

Required Documentation

  • • Certificate of incorporation
  • • Proof of registered address
  • • Identification of all directors and beneficial owners
  • • Proof of regulatory license (where applicable)
  • • Source of funds declaration
  • • Intended use case and expected transaction volumes

Regulatory Classification

What We Are

  • ✓ Licensed custody service provider
  • ✓ AML/CFT supervised financial intermediary
  • ✓ Digital asset vault service for businesses
  • ✓ B2B service provider to licensed entities

What We Are NOT

  • ✗ Not a cryptocurrency exchange
  • ✗ Not a token issuer or ICO
  • ✗ Not a bank or lending platform
  • ✗ Not a mining operation

Corporate Structure

Clavestra Capital Holdings Ltd (Malta, C113811)

→ Clavestra Orbital GmbH (Lugano, Switzerland)

CEO & Founder: Vincent Soons

CSO & Co-Founder: Luuk Soons

CTO & Director: Swiss-resident (St. Gallen)

Risk Disclosures

Digital assets, including Bitcoin and stablecoins, are subject to significant risks. Clients should be aware of the following before engaging our custody services:

  • ◆ Market volatility: The value of digital assets, particularly Bitcoin, can fluctuate significantly. Clavestra does not provide investment advice or guarantees on asset value.
  • ◆ Technology risk: While our federated architecture is designed to eliminate single points of failure, no system is entirely free from technical risk. We maintain disaster recovery procedures and encrypted cross-jurisdictional backups.
  • ◆ Regulatory risk: The regulatory environment for digital assets continues to evolve. Changes in legislation across jurisdictions may affect the availability or terms of our services.
  • ◆ Counterparty risk: While threshold cryptography ensures no single guardian can access funds, the federation requires a minimum threshold of operational guardians to process transactions.
  • ◆ Stablecoin peg risk: Stablecoins such as USDT and USDC are designed to maintain a 1:1 peg with the US dollar but this peg is not guaranteed. Clavestra does not issue stablecoins and is not responsible for the reserves of third-party issuers.

This is not an exhaustive list of risks. Clients should conduct their own due diligence and seek independent professional advice before using digital asset custody services.

Audit & Reporting

Ongoing Obligations

  • ✓ Annual AML audit conducted by independent auditor
  • ✓ Periodic reporting to SRO supervisory body
  • ✓ Continuous cryptographic proof of reserves
  • ✓ Record retention for minimum 10 years

Regulatory Reporting

  • ✓ Suspicious Activity Reports (SARs) filed with MROS
  • ✓ Annual compliance report to VQF
  • ✓ Disclosure of material changes to business operations
  • ✓ Guardian network status reports

Complaints Procedure

Clavestra Orbital is committed to resolving client concerns promptly and fairly. If you are dissatisfied with any aspect of our service, please follow the procedure below:

Step 1

Submit

Send a written complaint to complaints@clavestra.ch with a description of the issue, your account reference, and any supporting documentation.

Step 2

Acknowledge

We will acknowledge receipt of your complaint within 5 business days and assign a dedicated compliance officer to review your case.

Step 3

Resolve

We aim to provide a final response within 30 business days. If you remain unsatisfied, you may escalate to our supervisory body (VQF).

Compliance Inquiries

For compliance-related questions, regulatory inquiries, or to request our AML/CFT policy summary, please contact us at:

compliance@clavestra.ch