Hi. Certainly, that’s not a problem, please see your questions answered below:
STSS Limited is the entity that controls the EXT bank accounts that custody the EUR assets, correct? Or is that the Stasis Foundation?
STSS Limited controls only our IP and Wallet development. The entity that holds EURS reserves is a specially designated for the stablecoin reserve holding purpose only and is called STSS (Malta) Ltd. It’s established in the EU, audited by BDO, and is compliant with the MFSA out of Malta and their Virtual Financial Assets Act from 2017. Both entities belong to the Stasis Foundation.
Is STSS Limited or the Statis Foundation regulated as an Authorized Payment Institution in any European country? If so, does STSS Limited or the Stasis Foundation have passporting rights across the EU?
No and no - they are not required to do so currently as they are not involved in either the stablecoin issuance or trading. No licensing exists presently for a stablecoin issuer, but we do self regulate our SPV to the highest standards similar to category 2 licensed investment companies that qualify as MiFID firms.
Is STSS Limited or the Stasis Foundation registered with the European Banking Authority to provide payment or e-money services? If not, can you explain why?
Neither entity you mentioned is involved in the stablecoin issuance or trading. The SPV entity is compliant with the VFA Act in Malta and serves as a safeguard of reserves.
We chose the most efficient way to facilitate secondary market transactions - by creating a competition among partners who hold licenses themselves and offer the most convenient terms for customers to transact. We call this fungible settlement infrastructure and there are currently multiple licensed endpoints available, for example, XMT Gozo Ltd., UAB NexPay, Nortide Capital AG, SCB AG, and others.
Does STSS Limited or the Stasis Foundation operate a KYC/AML compliance program for all liquidity providers purchasing EURS from or exchanging EURS with the STSS Limited?
The SPV entity conducts KYC/AML on all transactions it facilitates although it is only used to face accredited investors buying or selling significant amounts of EURS (5mm+). Everything below is facilitated by the liquidity providers mentioned above as well as our “Sellback” interface which is accessible both through web and mobile here: www.stasis.net/sellback
and is also available via OpenAPI: https://stasis.net/sellback/api/v2/docs/swagger.
Currently, it has no KYC requirements for transactions below 250 euro lifetime, but we are working to increase that limit to 1000 euro per customer in August.
If neither entity performs exchange services, can you please describe the relationship, if any, with XMT Gozo Ltd? I believe I read that XMT Gozo Ltd. also provides exchange services for EURS?
Please see the above.
If XMT Gozo Ltd. provides exchange services, can please clarify whether it is regulated as an Authorized Payment Institution in any European country and, if so, whether it passporting rights across the EU?
XMT Gozo is authorized by MFSA to operate under the Vfa class 4 license.
If XMT Gozo Ltd. provides exchange services, does it operate a KYC/AML compliance program?
Can you disclose the beneficial owners or controlling persons of the Statis Foundation (the entity that controls STSS Limited, as described in an earlier thread: [EURS] - Adding crypto Euro to MCD)?
There are no beneficial owners, but a board of directors constitution of which we are happy to disclose to our verified clients. Our project is literally a charity to the industry to create a clean, transparent, institutional-grade quality cash-on-chain, financed by the gains our stakeholders made by investing in Bitcoin back in 2013. CEO of STASIS is one of the directors on the board of the foundation. We welcome other industry veterans to join the board.
In your economic model, are “liquidity providers” the only entities able to directly exchange EURS with STSS Limited, the Stasis Foundation, or XMT Gozo Ltd.?
Anybody who can be qualified as an accredited investor by MiFID terms or an entity, licensed to hold customer’s funds is able to face our SPV to directly exchange EURS. But so far competition among liquidity providers made the terms for retail customers probably the most attractive on the on/off ramp market: it is free for SEPA transfers to purchase, just 0.1% with 50 Eur cap to sell and using Visa/MC 1.5% for EU-issued cards and 3.5% for the rest.
We hope this info helps to clarify any doubts. Let us know if you have any more questions, please.