How to assess a digital-asset issuer

This guide is how the RCA desk opens an issuer file. It is not legal advice, it is not a paid due-diligence report, and it is not a representation that completing the checklist makes an onboarding 'safe'. It is the minimum structure we think a professional should be able to defend.

1. Identify the legal person

Name the issuer, not the brand. Obtain a register extract and, where available, an LEI. Map affiliates that hold reserves, write the white paper, operate the contract, or face the customer. If the website and the register disagree, the register wins until reconciled.

2. Map control

Ask what public sources show about directors, shareholders and beneficial owners. Note the regime that requires the disclosure. Where the home company law does not publish owners, say so—do not infer them from LinkedIn.

3. Characterise the instrument

What legal right does the token represent? E-money, a fund interest, a note, a contractual claim, a deposit, or none of the above? Which jurisdiction's characterisation is being relied on? A MiCA category does not answer a US securities question.

4. Collect the document set

• White paper, prospectus, offering memorandum or terms — with version and date.
• Licence, authorisation, registration or notification evidence from a primary register.
• Attestation or audit — scope, standard, as-of date, named entity.
• Custody, bank and administrator agreements or their public summaries.
• Smart-contract administration: multisig, pause, upgrade, and public assignment of those roles.

5. Date everything and record the gaps

Every material claim in an RCA profile carries a source, a source date and an RCA review date. Status is one of: proposed, in force, consultation, amended, withdrawn, reported, verified, unverified, evidence gap. If a private data room exists, we cannot see it; we mark the public gap rather than inventing comfort.

Company X's legal issuer, control structure, offering document, token contract, custody relationships and jurisdictional context indicate the following evidence picture—here are the original sources, dates, gaps and implications.