Compliance & Regulatory
Compliance is not a feature. It's the foundation.
Banks don't onboard counterparties they can't underwrite. This page summarizes D1's regulatory footprint, AML program, settlement framework, and audit posture. A complete due diligence pack — including entity charts, license copies, and audited policies — is available to qualified institutional counterparties under NDA.
Request our institutional due diligence packLicenses & Registrations
Regulated where it counts.
D1 operates through licensed and registered entities in the United States, Mexico, and Switzerland. Our regulatory footprint reflects deliberate jurisdictional choices — anchoring in the regulators institutional counterparties expect to see, while maintaining the regional presence required to serve clients across the Americas.
United States
- Entity
- D1 Technologies Incorporated
- FinCEN
- Money Services Business — Reg. No. 31000323879675
- State license
- Florida Money Services Businesses Part II — FT230000456
- Scope
- Money transmission and convertible virtual currency services in licensed jurisdictions
Mexico
- Entity
- D1 Technologies Latam SA de CV
- Registration
- Vulnerable Activity Registration under LFPIORPI
- Scope
- Operations as a vulnerable activity provider, with reporting obligations to UIF (Unidad de Inteligencia Financiera)
Switzerland
- Entity
- Coming 2026
- Status
- Coming 2026
- Scope
- AML supervision under the Swiss Anti-Money Laundering Act (AMLA), supervised through SRO membership
A complete entity chart, including beneficial ownership disclosure to the level required for institutional counterparty diligence, is available in our due diligence pack.
Anti-Money Laundering
A program built for FI-grade counterparty diligence.
D1's AML program is designed to meet the standards of the financial institutions we serve as a counterparty. Every element of the program is documented, audited, and available for review by qualified counterparties.
Risk-based onboarding
Customer Identification Program (CIP) and Customer Due Diligence (CDD) procedures aligned to FinCEN, FATF Recommendations, and applicable local requirements. Enhanced Due Diligence (EDD) for higher-risk relationships, including Politically Exposed Persons (PEPs), high-risk jurisdictions, and complex ownership structures.
Sanctions screening
Real-time screening against OFAC, UN, EU, UK HMT, and other applicable sanctions lists at onboarding and on an ongoing basis. Sanctions program oversight conducted by our Compliance function with documented escalation procedures.
Transaction monitoring
Risk-based transaction monitoring across fiat and digital asset flows, including blockchain analytics through industry-standard providers. Suspicious activity is reviewed by trained analysts and reported to FinCEN and applicable foreign financial intelligence units.
Travel Rule compliance
Compliance with FATF Recommendation 16 (Travel Rule) for digital asset transfers. Counterparty information is exchanged with VASPs and FIs through industry-standard messaging protocols.
Governance
A dedicated Chief Compliance Officer reports to the Board on AML program effectiveness. Annual independent AML program testing and ongoing employee training programs.
Available under NDA: AML/BSA Policy, Sanctions Policy, Customer Identification Program, Travel Rule procedures, and most recent independent AML audit.
Trade Settlement
We are not a custodian. We settle trades.
D1 does not currently provide custody services. We are a trade execution and settlement counterparty. Each transaction is settled directly with the client, on a per-trade basis, with no pooling of assets and no commingling of client funds with D1 operating funds or with other clients' funds at any point in the settlement flow.
This distinction matters. Custody implies ongoing safekeeping of client assets under a regulated custody framework. We do not hold client assets in that capacity today. Instead, we execute trades on behalf of institutional counterparties and settle each leg of each trade directly to the client's designated wallet, account, or onward custody provider.
Per-trade, per-client
Every trade is settled individually against the specific client's account or wallet. There is no omnibus account, no pooled settlement, and no internal book transfer between clients.
No commingling
Client funds in transit through the settlement flow are segregated from D1 operating funds at all times. D1 does not finance its operations from client balances and does not extend client assets as collateral, working capital, or for any purpose outside the specific trade being settled.
Onward custody is the client's choice
Where a client maintains digital assets after settlement, those assets are held with a custody provider of the client's choosing — whether the client's own qualified custodian, an institutional wallet provider such as Fireblocks, or other arrangements. D1 integrates with major institutional custody providers to support clean settlement into the client's preferred environment.
Operational security
For assets in flight during settlement, D1 maintains institutional-grade operational controls, including Multi-Party Computation signing, policy-based approval workflows, and continuous monitoring through industry-standard infrastructure.
Forward-looking — Swiss custody offering, 2026
D1 plans to launch a regulated digital asset custody offering through our Swiss entity, expected to commence in 2026. The offering will be subject to applicable Swiss regulatory requirements and authorizations. Further detail will be made available to qualified counterparties as the offering approaches launch.
Until that offering is live, D1 does not hold itself out as a custodian and does not provide custody services in any jurisdiction.
Available under NDA: Settlement procedures documentation, operational security overview, and details on the planned Swiss custody offering as it progresses through regulatory authorization.
Audit & Controls
Independent verification.
D1's controls and reporting are designed to support institutional counterparty diligence, regulator inquiries, and internal audit requirements at our clients.
Independent audit
Annual financial audits conducted by an independent third-party auditor. AML program independent testing conducted annually in line with regulatory expectations. Penetration testing and information security review conducted on an ongoing basis.
Information security
Information security program aligned to recognized industry frameworks. Multi-factor authentication, role-based access control, encrypted data at rest and in transit, and continuous monitoring across production systems.
Counterparty reporting
Real-time balance and transaction reporting, customizable transaction limits and approval workflows, exportable audit trails for compliance and finance teams at counterparty institutions.
Regulatory reporting
Suspicious Activity Reports filed in applicable jurisdictions in line with regulatory obligations. Currency Transaction Reports filed where applicable. All reporting handled by our Compliance function with documented procedures and Board oversight.
Available under NDA: Most recent financial audit, AML independent testing report, penetration test summary, and information security policies.
Restrictions
What we won't do.
D1's regulatory anchors define not just what we can do, but what we explicitly will not do. We disclose this so counterparties understand the boundaries of our service from the first conversation.
Prohibited jurisdictions
We do not provide services to individuals or entities located in, organized under the laws of, or otherwise subject to comprehensive sanctions in jurisdictions including, but not limited to: Cuba, Iran, North Korea, Syria, the Crimea, Donetsk, and Luhansk regions of Ukraine, and other jurisdictions designated by OFAC or applicable sanctions authorities.
Prohibited activities
We do not facilitate activities including, but not limited to: anonymity-enhancing services that obscure transaction provenance, gambling operations in jurisdictions where gambling is not licensed, unregistered securities offerings, or any activity prohibited under applicable AML, sanctions, or financial crime law.
Client eligibility
D1 serves financial institutions and qualified institutional and corporate clients. We do not provide retail services. Minimum eligibility criteria, including jurisdictional, regulatory status, and account size requirements, apply to all client relationships.
Data Protection
How we handle counterparty and end-client data.
D1 processes client data in accordance with applicable privacy and data protection law, including the EU General Data Protection Regulation (GDPR) where applicable, the Mexican Federal Law on Protection of Personal Data Held by Private Parties, and US state privacy laws applicable to our operations.
Client data shared with D1 in the course of our counterparty relationship is handled under written confidentiality and data processing terms in our Master Services Agreement. We do not sell, lease, or share client data with third parties for marketing purposes.
A full Privacy Notice is available at d1.app/privacy. A Data Processing Addendum is available on request.
Conducting diligence on D1?
We've done institutional onboarding from both sides of the table. We know what your compliance, risk, and treasury teams need. Request our institutional due diligence pack and we'll deliver entity charts, license documentation, audited policies, and most recent independent reports — under NDA, within one business day of your request.
Request our institutional due diligence packD1 Technologies and its affiliated entities operate under the licenses, registrations, and regulatory statuses described above. Information on this page is provided for informational purposes and is updated periodically. Specific products, services, and jurisdictions of availability are governed by the applicable Master Services Agreement, onboarding documentation, and regulatory restrictions. Nothing on this page constitutes legal, tax, regulatory, or investment advice. Counterparties should conduct their own diligence and consult their own advisors.