The Alkaimi platform, the Alkaimi ledger inside the platform, the Mint, and the Alkaimi Financial Ecosystem™ as a whole: the classes each does not fall into, the one class the platform sits in, and the standard the platform is built to, under the reference law of the European Union, the United Kingdom, the United States, Singapore and Hong Kong, with the test stated and the facts applied.
The Alkaimi platform is the walled garden operating core. The core is the nexus where the gateways of the licensed banks meet. Pegisai Network Services runs the network under the Alkaimi operating license. Inside the core sits the Alkaimi ledger. Every DTA™ is held on the Alkaimi ledger in the client's own DTA holding account. Only the Alkaimi ledger changes control of a DTA, and only on the licensed bank's instruction. Pegisai™ is the administrator of the Alkaimi ledger at all times. Inside the core also sits the Mint. The Mint constructs the DTA and the UVU™ under contract with the licensee. The Alkaimi Financial Ecosystem is the ring of licensed banks, the platform with the Alkaimi ledger and the Mint inside the core, and the administration that connects the banks to the core. For each class below the test is stated first, from the statute or standard that sets the test, and the facts are applied to that test. The legal position of the DTA is on the page The legal position of the Digitized Tangible Asset. The legal position of underwriting is on the page The legal position of underwriting on the platform.
The platform: a financial market infrastructure by design, supervised on designation
Test. CPMI-IOSCO, Principles for Financial Market Infrastructures (2012), paragraph 1.8: an FMI is a multilateral system among participating institutions, including the operator of the system, used for clearing, settling or recording payments, securities, derivatives or other financial transactions; the principles are applied to systemically important FMIs. 12 U.S.C. 5462(6)(A): a financial market utility is any person that manages or operates a multilateral system for transferring, clearing or settling payments, securities or other financial transactions among financial institutions, designated where systemically important. Banking Act 2009 (United Kingdom), Part 5: recognition of payment systems and their service providers for Bank of England oversight.
Facts.
The Alkaimi platform is a multilateral system among participating institutions, the licensed banks, with an operator. The platform records and settles transfers of DTAs between the accounts of the banks' clients. The platform is an FMI in form.
Licensed banks in multiple countries have operated on the platform in wholesale settlement since 1 September 2026. See also Alkaimi Ecosystem, Current Operations. No authority has designated the platform systemically important.
The platform is built to the Principles for Financial Market Infrastructures. The platform expects to be assessed against the principles as volumes grow. Designation brings direct oversight of the operator, and the platform is designed to receive it.
The platform: a service provider to the licensed banks
Test. EBA Guidelines on outsourcing arrangements (EBA/GL/2019/02): an arrangement under which a service provider performs a process, service or activity the institution would otherwise perform, with heightened requirements for critical or important functions. Regulation (EU) 2022/2554 (DORA), Articles 28 to 31: ICT third-party risk, the register of information, the mandatory contractual provisions, and the designation of critical ICT third-party service providers for direct oversight. Financial Services and Markets Act 2000 (United Kingdom), section 312L: the Treasury's designation of critical third parties. Interagency Guidance on Third-Party Relationships: Risk Management (United States, June 2023): the bank remains responsible for every third-party arrangement as if performed in-house. MAS Guidelines on Outsourcing (Singapore); HKMA Supervisory Policy Manual SA-2 (Hong Kong).
Facts.
The licensed bank performs custody, settlement, the rent agreement and the product book. The Alkaimi platform is the nexus through which the bank reaches the Alkaimi ledger, on which those operations are recorded. Pegisai administers the verification, the permission, the movement and the audit on the Alkaimi ledger.
Pegisai Global Holdings administers the platform under contract. Pegisai Network Services runs the network under the license. For every licensed bank the platform is a third-party arrangement supporting critical functions. Every licensee relies on the same provider.
The Alkaimi operating license and each operating agreement carry the provisions the licensee's rules require: the description of the services, the locations of data, service levels, incident notification, the bank's and its supervisor's rights of access and audit, business continuity, and exit with the return of data.
The platform: the license under competition law
Test. Article 101 TFEU. Commission Regulation (EU) 2026/877, the Technology Transfer Block Exemption Regulation applying from 1 May 2026, exempts technology licenses between a licensor and a licensee within the market-share thresholds and without hardcore restrictions (price fixing, output limits, market allocation). The United Kingdom's Technology Transfer Agreements Block Exemption Order. Sherman Act, section 1, under which vertical restraints are judged by the rule of reason. Competition Act 2004 (Singapore), section 34. Competition Ordinance (Hong Kong), the first conduct rule.
Facts.
The Alkaimi operating license is a technology transfer agreement. Pegisai Global Holdings licenses the granular value recognition™ and DTA technologies, the marks and the know-how to an independently owned bank holding company under an operating agreement.
The license as published grants the rights and bars the liens. No published term sets a price for the services a licensee sells to clients. No published term assigns a territory a licensee may not enter.
The commons allocates underwriting signatures by bid under published rules. Every pool carries the competition-law assessment its counsel already runs.
The Alkaimi ledger: not a trading venue
Test. MiFID II, Directive 2014/65/EU, Article 4(1)(19), (21), (22) and (23): a trading venue is a multilateral system in which multiple third-party buying and selling interests in financial instruments interact in a way that results in a contract; Article 1(7) requires every such system to be authorized as a regulated market, an MTF or an OTF. The United Kingdom carries the same definitions. Securities Exchange Act of 1934, section 3(a)(1) and Rule 3b-16. Securities and Futures Act 2001 (Singapore), Part II: an organized market in securities, derivatives contracts or units in collective investment schemes.
Facts.
Nothing on the Alkaimi ledger is a financial instrument, a security or a capital markets product. The DTA is outside every one of those classes.
No buying interest and no selling interest interact on the Alkaimi ledger. There is no order, no quote, no match and no price. A DTA moves from one client's DTA holding account to another as the settlement of an obligation the two clients already have, on the licensed bank's instruction. The move is final.
Nothing is traded.
The Alkaimi ledger: not a central securities depository or a securities settlement system
Test. Regulation (EU) No 909/2014, Article 2(1)(1): a CSD is a legal person that operates a securities settlement system and provides the initial recording of securities in book-entry form or the central maintenance of securities accounts. Directive 98/26/EC, Article 2(a): a system is a formal arrangement with common rules for the execution of transfer orders in securities or funds, designated by a Member State. Securities Exchange Act, section 3(a)(23): a clearing agency. The United Kingdom, Singapore and Hong Kong carry the same object: securities.
Facts.
No securities exist on the Alkaimi ledger. The Alkaimi ledger records DTAs in the clients' own DTA holding accounts.
Finality on the Alkaimi ledger rests on the rules of the Alkaimi ledger under English law and on the licensee's agreement. The Alkaimi ledger verifies, permits and executes the move. The move is final when the DTA moves.
The Alkaimi ledger: governed by English law, with control in the client's hands
Test. UNIDROIT Principles on Digital Assets and Private Law (2023): a digital asset capable of control can be the subject of proprietary rights; the law governing proprietary issues is the law expressly specified in the asset or in the system on which the asset is recorded. Uniform Commercial Code, Article 12, section 12-105: a person has control of a controllable electronic record where the record or the system gives the person the power to avail itself of substantially all the benefit and the exclusive power to prevent others and to transfer control; a power is exclusive even if the system limits the use of the record or has a protocol programmed to cause a change, and even if the power is shared; section 12-107: the record's jurisdiction is the jurisdiction the record or the system expressly provides. Property (Digital Assets etc) Act 2025 (England and Wales), section 1: a digital thing is not prevented from being an object of personal property rights.
Facts.
English law governs the DTA and the rules of the Alkaimi ledger. The choice is written into the rules of the Alkaimi ledger and into every operating agreement. The arbitral seat is chosen by region. The bank-client relationship of each licensee stays under the licensee's own law.
The client holds title to the DTA. The client can hold electronic possession of the DTA. The client's DTA holding account identifies the client as the holder.
The verification, permission and audit functions of the Alkaimi ledger, and the licensed bank's custodial check at the gateway, are limits and protocols of the system in which the record is recorded. The receiver's powers on a default are protocols in the rules of the Alkaimi ledger. Neither Pegisai nor the licensed bank can move a client's DTA for its own account.
The Alkaimi ledger: the client's DTA outside the bank's estate
Test. The property status of the DTA under the 2025 Act, the UNIDROIT Principles and UCC Article 12. The custody rules of each jurisdiction, under which a custodian holds the client's asset for the client and the asset is not available to the custodian's creditors. The Basel liquidity standard, under which a deposit is a liability with a run-off in stress.
Facts.
The DTA is the client's property. The licensed bank holds the DTA in custody in the client's own DTA holding account, off the bank's balance sheet. No DTA is the bank's asset or the bank's liability. The one exception is a DTA the bank itself issues from an asset the bank holds.
No claim runs from the client against the bank on the DTA. The bank receives no money for a DTA, and owes the client no payment on a DTA, because the client holds the DTA as property. The licensee's book is whole reserve. The book carries no deposit, so no run can form against it.
When a licensee fails, nothing of the client's is in the estate. The Alkaimi ledger moves the client's DTA holding account to another licensee's gateway under the rules of the Alkaimi ledger. Pegisai remains the administrator of the Alkaimi ledger throughout.
The Alkaimi ledger: not a payment system, and the group is not a money transmitter
Test. Directive (EU) 2015/2366, Article 4(25): funds are banknotes and coins, scriptural money or electronic money; Article 4(7): a payment system is a funds-transfer system. The United Kingdom's Payment Services Regulations 2017 carry the same funds concept. Financial Services (Banking Reform) Act 2013, section 41: a payment system is a system for enabling persons to make transfers of funds, and a system whose primary purpose is not that is excluded. 31 CFR 1010.100(ff)(5): a money transmitter accepts currency, funds or other value that substitutes for currency from one person and transmits it to another; the definition excludes a person that only operates a clearance and settlement system or acts as an intermediary solely between regulated institutions, and excludes a bank. Payment Services Act 2019 (Singapore) and the Payment Systems and Stored Value Facilities Ordinance (Hong Kong) carry the same objects.
Facts.
No funds move on the Alkaimi ledger. A DTA is not banknotes or coins, not scriptural money and not electronic money. No DTA is priced in a currency.
Currency moves only on the licensed banks' own books, at the desk, outside the walled garden, under the banking license each bank already holds.
The group accepts no currency, funds or value from anyone. The group transmits nothing to anyone. The Alkaimi ledger changes control of a DTA on the licensed bank's instruction, acting solely between licensed banks.
The Alkaimi ledger: not a distributed-ledger infrastructure, and not a crypto-asset service provider
Test. Regulation (EU) 2023/1114 (MiCA), Article 3(1)(1) and (5): a crypto-asset is a digital representation of value or rights transferred and stored using distributed ledger technology or similar technology; Article 3(1)(16) lists the crypto-asset services. Regulation (EU) 2022/858 covers DLT market infrastructures. Basel SCO60 applies to bank exposures to assets that depend on cryptography and distributed ledger or similar technology. Financial Services and Markets Act 2023 (United Kingdom), section 69: a cryptoasset is any cryptographically secured digital representation of value or contractual rights that can be transferred, stored or traded electronically and uses technology supporting the recording or storage of data; the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, in force 25 October 2027, make safeguarding, dealing, arranging and operating a trading platform regulated activities in qualifying cryptoassets, which must be fungible and transferable and more than a record of value or rights. Singapore's digital payment token and Hong Kong's virtual asset are each a medium of exchange accepted by the public.
Facts.
The Alkaimi ledger is one custodial record under bank supervision. The Alkaimi ledger uses no distributed ledger and no blockchain.
The Mint constructs a series of unique DTAs from one stack. Every stack is segregated from every other stack. A DTA of one stack is not interchangeable with a DTA of another stack.
Custody sits with the licensed bank in the client's own DTA holding account. Pegisai as administrator safeguards nothing for any client and operates no trading platform, because nothing is traded.
No DTA is a medium of exchange accepted by the public. A DTA moves only between DTA holding accounts through licensed banks.
The Alkaimi ledger: data protection
Test. Regulation (EU) 2016/679, Article 4(7) and (8): the controller determines the purposes and means of processing; the processor processes on the controller's behalf. Article 28: the processor acts on documented instructions under a binding contract. Chapter V: transfers outside the Union. The United Kingdom GDPR and the Data Protection Act 2018, the Gramm-Leach-Bliley Act (United States), the Personal Data Protection Act 2012 (Singapore) and the Personal Data (Privacy) Ordinance (Hong Kong) carry the same structure for a bank's customer records held by a service provider.
Facts.
The Alkaimi ledger holds the account records of clients of licensed banks. The licensed bank opens the account, knows the client and determines why the data is processed. The bank is the controller.
The group processes the records on the bank's behalf, under the license, to run the Alkaimi ledger. The group is the processor. The license carries the processor terms, the transfer mechanisms, and residency where a licensee's law requires it.
The Mint and the issuer: who issues, who constructs, who owes
Test. A bearer instrument in electronic form has an issuer, the person on whose account the bearer instrument is created; a minter constructs the bearer instrument; an obligor owes on the bearer instrument. Electronic money: Directive 2009/110/EC, Article 2(2), monetary value represented by a claim on the issuer, issued on receipt of funds; the Electronic Money Regulations 2011 (United Kingdom); e-money under the Payment Services Act 2019 (Singapore). Stablecoins: MiCA, Titles III and IV; the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, the activity of issuing a qualifying stablecoin; the GENIUS Act of 2025, section 2(22); Hong Kong's Stablecoins Ordinance. Securities: the tests on the page The legal position of the Digitized Tangible Asset.
Facts.
The issuer of a DTA is the asset holder whose asset is recognized. The licensed bank can act as the asset holder's agent under the Alkaimi operating license, which Pegisai Global Holdings issues for the use of the granular value recognition and DTA technologies.
The Mint constructs the DTA and the UVU under contract with the licensee. The Mint issues nothing on its own account. The Mint receives no funds, holds no reserve and redeems nothing.
A DTA is tangible asset value, custodial held, by Alkaimi Financial Ecosystem members only, as property, as a digitized bearer instrument, on the Alkaimi Financial Ecosystem ledger. The DTA carries the recognized value of the asset holder's own asset. A DTA references no currency and holds no peg. No issuer is obligated to redeem a DTA at a fixed currency amount.
No electronic-money issuer regime, no stablecoin issuer regime and no securities issuer regime reaches the asset holder, the licensed bank as agent or the Mint as contractor.
The ecosystem: anti-money-laundering and sanctions
Test. FATF Recommendation 15 and the FATF glossary: a virtual asset service provider conducts, as a business and for or on behalf of another, the exchange, transfer, safekeeping or administration of virtual assets; the Updated Guidance of October 2021 excludes those who provide only ancillary infrastructure or software. Directive (EU) 2015/849 and Regulation (EU) 2024/1624, the Money Laundering Regulations 2017 (United Kingdom), the Bank Secrecy Act (United States), and the banks' notices in Singapore and Hong Kong place the obligations on the institutions that hold accounts and move value for customers. Sanctions law, in the United States, the European Union and the United Kingdom, binds every person and prohibits the facilitation of a prohibited transaction.
Facts.
A licensed bank opens every account on the Alkaimi ledger under bank-grade customer due diligence. Every movement of a DTA is between accounts at licensed banks, inside the banks' existing due diligence, record-keeping and reporting.
The group holds no account for any client. The group conducts no transaction for or on behalf of any client. The Alkaimi ledger executes the licensed bank's instruction, and Pegisai administers the Alkaimi ledger. A liquidation on the Alkaimi ledger executes on the licensed banks' ledger accounts under the license and the rules of the Alkaimi ledger.
Sanctions law binds the group directly. The participation rules of the Alkaimi ledger admit only licensed banks and the pools and clients those banks have screened.
The ecosystem: not a benchmark
Test. Regulation (EU) 2016/1011, Article 3(1)(1): an index is a figure published or made available to the public and regularly determined by a formula, a calculation or an assessment on the basis of underlying assets or prices; Article 3(1)(3): a benchmark is an index by reference to which the amount payable under a financial instrument or a financial contract, or the value of a financial instrument, is determined, or an index used to measure the performance of an investment fund; Article 3(1)(18): a financial contract is a consumer credit or mortgage credit agreement. The United Kingdom's Benchmarks Regulation carries the same definitions.
Facts.
The UVU is the universal denomination of value, set once, by definition. The UVU is never recalculated. No formula, calculation or assessment determines the UVU on any day. A licensed bank's desk reads each currency against the transmutation reference point (TRP), and that reading is the currency's own market price.
No financial instrument references the UVU. A DTA is not a financial instrument. The value of a DTA is determined by reference to nothing, because the recognized value never moves.
No financial contract references the UVU. The rent agreement is custody. The underwriting contract is suretyship. Neither is a credit agreement.
No investment fund measures performance against the UVU. No DTA is priced in a currency.
Where the classification rests
In each jurisdiction the classification of the Alkaimi platform, the Alkaimi ledger, the Mint, the Alkaimi operating license and the administrator's role rests with the licensed bank's supervisor. Where a designation is made, the classification rests with the designating authority. Each rests under that jurisdiction's law, confirmed by the licensee's counsel.
Nothing on this page is an offer, a solicitation or a public offering, or legal, financial or investment advice.
Sources: CPMI-IOSCO, Principles for Financial Market Infrastructures (April 2012). 12 U.S.C. 5462 and 5463; 12 CFR Part 234 (Regulation HH). Banking Act 2009, Part 5; Financial Services (Banking Reform) Act 2013, section 41. EBA/GL/2019/02. Regulation (EU) 2022/2554 (DORA), Articles 28 to 31. Financial Services and Markets Act 2000, section 312L; PRA Supervisory Statement 2/21. Interagency Guidance on Third-Party Relationships: Risk Management, 88 FR 37920 (9 June 2023). MAS Guidelines on Outsourcing; HKMA Supervisory Policy Manual SA-2. Commission Regulation (EU) 2026/877; Leegin Creative Leather Products v. PSKS, 551 U.S. 877 (2007); Ohio v. American Express Co., 585 U.S. 529 (2018); Competition Act 2004 (Singapore), section 34; Competition Ordinance (Cap. 619). Directive 2014/65/EU (MiFID II), Articles 1(7) and 4(1), Annex I. Regulation (EU) No 909/2014 (CSDR), Article 2(1) and the Annex. Directive 98/26/EC, Article 2. Securities Exchange Act of 1934, sections 3(a)(1), 3(a)(23) and 17A; Rule 3b-16. UNIDROIT Principles on Digital Assets and Private Law (2023). Uniform Commercial Code, Article 12, sections 12-105 and 12-107. Property (Digital Assets etc) Act 2025. Directive (EU) 2015/2366 (PSD2), Article 4 and Annex I. 31 CFR 1010.100(ff). Regulation (EU) 2023/1114 (MiCA), Article 3(1). Regulation (EU) 2022/858. Basel Framework SCO60. Financial Services and Markets Act 2023, section 69; the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102). Regulation (EU) 2016/679, Articles 4 and 28 and Chapter V. Directive 2009/110/EC, Article 2(2); the Electronic Money Regulations 2011; GENIUS Act of 2025, section 2(22). FATF Recommendation 15 and the Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (October 2021). Directive (EU) 2015/849; Regulation (EU) 2024/1624; the Money Laundering Regulations 2017; the Bank Secrecy Act. Regulation (EU) 2016/1011, Article 3(1). Securities and Futures Act 2001 (Singapore), Part II and Part VIAB; Payment Services Act 2019; Securities and Futures Ordinance (Cap. 571); Payment Systems and Stored Value Facilities Ordinance (Cap. 584); Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). Pegisai Global Holdings, The Alkaimi Financial Ecosystem in Function: Granular Value on a Neutral Rail.
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