Money, in plain English.
The token, the wallet and the referral payouts each touch a different slice of UK financial regulation. Here is exactly how each one stays on the safe side - by structure, not by hope - and why we route the regulated burden through Stripe instead of becoming a regulated money-handler ourselves.
We provide the window. Stripe provides the safe.
Money never sits on Boundless balance sheets. Cards are tokenised by Stripe (PSD2-licensed, PCI Level 1, FCA-authorised EMI), settlements move on Stripe rails, and payouts to advocates run through Stripe Connect. Boundless keeps a ledger - not the funds. That single architectural choice removes the heaviest financial regulations from our perimeter and routes them to a regulated specialist.
We provide the window. Stripe provides the safe.
$BNDL, the wallet, and referrals - each one mapped to its regulator.
Primary issuance of fractional ordinary equity by the company itself. Sits inside the FSMA s.85 small-issue exemption (≤€8m / 12 months), which is why no FCA-approved prospectus is required pre-IPO. Marketing is approved under FSMA s.21 by an external authorised firm. Investor categorisation gate live on /token. CGT-only tax treatment under HMRC CRYPTO22050 + share-pool rules.
Internal scrip - redeemable 1:1 against Boundless services only, hard-capped at £10k per user. That places it inside the limited-network exemption (PSR 2017 Sched 1 Pt 2 §2(k)), so it is not e-money. Cash-out is processed through Stripe Connect, where Stripe is the licensed e-money issuer. We are an agent of Stripe, never a PSP.
KYC, sanctions screening and payout rails are operated by Stripe Connect under MLR Reg. 39 reliance. Boundless never captures CDD docs directly. Per-payee structured to fit the £1k trading allowance for casual income; a downloadable annual statement (PDF + CSV) covers HMRC self-assessment if the threshold is exceeded.
Every body with a say on the money leg.
Click any card for the duties, our position, the risks they introduce and the lawful exemption levers we use.
Mapped, mitigated, monitored.
| Risk | Category | Likelihood | Impact | Mitigation | Status |
|---|---|---|---|---|---|
Card charge-backs / disputed payments Layer 22 money-path guard · /app/audit | Financial | medium | medium | Stripe Radar + 3DS2 SCA on every card auth · B2B accounts use PO/invoice with signed acceptance log · friendly-fraud rebuttal pack auto-assembled from the audit chain (delivery receipt, login trail, usage record). | Mapped |
Financial-promotion breach on $BNDL marketing FSMA s.21 · /token gate · audit chain | Regulatory | low | high | Every token-related communication is signed off by an FCA-authorised person under FSMA s.21 before publication. Investor-categorisation gate on /token (high-net-worth, sophisticated, or restricted-investor self-cert). No celebrity endorsements. 24h cooling-off on first investment. Signed copy + categorisation evidence chained to Layer 23. | Mapped |
$BNDL recategorised as security / CIS / cryptoasset Legal opinion · token.functions · HMRC CRYPTO22050 | Legal | low | high | Standing legal opinion on file: $BNDL is a fractional ordinary-equity instrument, not a unit in a collective investment scheme (no pooling for return), not a cryptoasset under MLR Reg. 14A (no DLT-as-medium-of-exchange), and not a transferable security on a secondary market pre-IPO. Treasury cash-backed; CGT-only tax treatment confirmed against HMRC CRYPTO22050 / share-pool rules. | Mapped |
Wallet balances cross the e-money definition PSR Sched 1 §2(k) · Stripe e-money licence · wallet_ledger | Regulatory | low | high | Wallet is internal scrip: redeemable 1:1 against Boundless services (limited-network exemption, PSR 2017 Sched 1 Pt 2 §2(k)) plus an explicit £10k per-user cap. Cash-out is processed through Stripe Connect - Stripe is the licensed e-money issuer, we are an agent. Balance ledger is append-only and reconciled per ledger entry. | Mapped |
Advocate-payout abuse for layering / money-laundering Stripe Connect KYC · MLR 2017 Reg 28 · referral_payouts trigger | Legal | low | high | Every payout name-matched to bank account by Stripe Connect KYC, sanctions-screened on each disbursement, capped at £1k per advocate per month without enhanced due diligence. Single named MLRO (mlro@boundless.tel). All payout state changes auto-audited via handle_payout_status_change trigger. | Mapped |
Advocate awards reclassified as employment income ITTOIA 2005 s.783A · advocate T&Cs · /app/wallet-ledger | Regulatory | low | medium | T&Cs explicit 'introducer, not employee'. Per-payee structured to fit the £1,000 trading-allowance and the £6k CGT allowance for any token component. Annual statement (CSV + PDF) downloadable from the wallet ledger, mirroring 1099-style reporting for HMRC. Advocate self-certifies tax status at sign-up. | Mapped |
Chargeback / first-party fraud on top-up or withdrawal Stripe Radar · Stripe Connect · Layer 23 | Financial | low | medium | Top-ups go through Stripe Radar with 3DS2 SCA. Withdrawals are KYC-gated by Stripe Connect Express. Boundless never custodies funds end-to-end - Stripe is the regulated money-handler. Chargeback rebuttal pack auto-assembles from Layer 23 audit chain. | Mapped |
PSD2 Strong Customer Authentication failure on movement of funds PSR 2017 Reg 100 · Stripe SCA · Layer 14 | Regulatory | low | medium | All card payments go through Stripe with 3DS2 SCA enforced by default. Step-up auth (biometric or OTP) required on wallet movements >£100. Inherence + possession factors logged to the audit chain. | Mapped |
User-side HMRC reporting on referral or token gains /app/wallet-ledger · HMRC SA guide · CRYPTO22050 | Reputational | low | low | In-app annual statement (PDF + CSV) downloadable from /app/wallet-ledger covering: referral income vs £1k trading allowance, token disposals vs £3k (24/25) / £6k (prior) CGT allowance, and any token-as-income event valued at GBP-spot. Plain-English HMRC-self-assessment guide linked. | Mapped |
No fine print, no surprises.
Cash-backed treasury. Investor-categorisation gate. Independent s.21 sign-off. Plain-English risk warnings on every surface.
$BNDL is a high-risk investment in a private company. You may lose the full amount invested. Pre-IPO holdings are not covered by the Financial Services Compensation Scheme. Past valuations are not a reliable indicator of future returns.
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Total lawful cost avoidance across all surfaces (telecoms + money): ~£1,728,000 /yr.