On The Record
Biweekly briefings on infrastructure compliance, digital asset regulation, and what it means for operators building on Fexr.
✦ Published every other Wednesday · Legally reviewed before publication
Why B2B SaaS Infrastructure Providers Are Not VASPs Under FATF Guidance
Enterprise legal teams often conflate "you touch crypto" with "you are a VASP." This briefing walks through FATF Recommendation 15's four qualifying activities and shows exactly where the line is drawn.
On-Chain Sanctions Screening: What It Is, How It Works, and Why It Shifts AML Risk
The AML concern that kills deals: "what if a sanctioned party joins our loyalty pool?" This briefing explains the difference between UI-layer and contract-layer blocking, and what it means for your own compliance obligations.
DMCC, VARA, and the Software Infrastructure Gap: How UAE Frameworks Treat Non-Custodial SaaS Providers
Every GCC enterprise buyer and international vendor due-diligence team will ask "are you VARA-regulated?" This briefing explains the framework, where the exemption sits, and why it matters for banking.
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