Empire Stock Transfer Integration
Empire Stock Transfer Integration
Qualified Custodian · Sole Investor Onboarding Authority · Ed25519 Attestation · Master Securityholder File
Deep-dive into the regulatory and technical integration between the platform and Empire Stock Transfer — the SEC §17A-registered entity that holds every Common Class B share, verifies every investor, and signs every custody attestation that makes the 42 Transfer Hook controls function. This integration applies across all three production modules: Equities (Module 1), Real Estate (Module 2), and CORECM — Carbon Ore, Rare Earth, and Critical Minerals (Module 3).
Empire is not a vendor. Empire is load-bearing infrastructure. Without Empire, no ST22 token can exist.
The platform is operated by Groovy Company, Inc. The trading venue is CEDEX. Empire Stock Transfer (Patrick Mokros, Founder) is the sole §17A-registered transfer agent and qualified custodian for all three RWA Tokens product modules.
Table of Contents
Empire's Dual Role
Regulatory Foundation
Custody Architecture
Ed25519 Attestation Lifecycle
Master Securityholder File
Investor Onboarding Flow
KYC — Individual Verification
KYB — Entity Verification
AML and OFAC Screening
Wallet Verification (KYW)
Accredited Investor Verification
Transfer Hook Integration Map
Protective Conversion Mechanics
Tripartite Agreement Structure
Conflict of Interest Disclosure
Empire Operational Continuity
Module-Aware Custody Coverage
1. Empire's Dual Role
Empire Stock Transfer serves two distinct functions in the platform's architecture. Both are mandatory for Category 1 Model B compliance. Neither can be replaced by the platform or any other component.
RoleScopeRegulatory BasisReplaceable?
Qualified Custodian
Holds all Common Class B shares in irrevocable, perpetual custody. Signs Ed25519 attestations every Solana block (~400ms). Maintains authoritative share count.
SEC Exchange Act §17A
No — custody must be performed by a §17A-registered entity
Sole Investor Onboarding Authority
Performs all KYC (individuals), KYB (entities), AML (Chainalysis KYT plus TRM Labs), OFAC/SDN screening, accreditation verification, and wallet registration.
BSA CIP (31 CFR §1020.220), FinCEN CDD Rule, Reg D Rule 501
No — the platform does not perform onboarding
Why this architecture exists: Category 1 Model B requires that investor verification and custody are performed by a regulated entity with §17A obligations — not by the platform operator. If the platform performed investor onboarding, the architecture would be Category 2 (third-party sponsored) with counterparty risk. Empire's independence is the structural guarantee that eliminates counterparty risk.
What the Platform Does NOT Do
FunctionPerformed ByPlatform Role
Hold investor assets
Empire Stock Transfer
None — the platform holds no shares
Verify investor identity
Empire Stock Transfer
Portal routes to Empire dashboard
Store KYC/KYB documents
Empire Stock Transfer
The platform has no access to investor PII
File SARs with FinCEN
Empire Stock Transfer
The platform provides transaction analytics
Make accreditation determinations
Empire Stock Transfer
The platform enforces via Transfer Hook (Control 12)
Maintain shareholder records
Empire Stock Transfer (MSF)
Solana blockchain serves as notification layer
2. Regulatory Foundation
Empire's Registrations
RegistrationAuthoritySinceScope
Transfer Agent
SEC, Exchange Act §17A
2006
Shareholder record maintenance, proxy distribution, dividend disbursement, ownership transfer
Qualified Custodian
SEC custody requirements
Operating
Irrevocable custody of securities on behalf of beneficial owners
Regulatory Obligations
RequirementCFR ReferenceImplementation
Customer Identification Program (CIP)
31 CFR §1020.220
Four-pillar identity verification at onboarding
Customer Due Diligence (CDD)
31 CFR §1010.210
Risk-based assessment at onboarding plus ongoing
Beneficial Ownership
31 CFR §1010.230
UBO identification at 25% or higher for entities
Suspicious Activity Reports (SARs)
31 CFR §1010.320
Filing for transactions at $5,000 or above meeting BSA criteria
Currency Transaction Reports (CTRs)
31 CFR §1010.311
Filing for fiat transactions at $10,000 or above
Recordkeeping
31 CFR §1010.410
5-year retention for KYC, KYB, and AML records
OFAC Screening
Executive Orders plus 31 CFR Parts 500–598
Real-time SDN screening at onboarding plus hourly refresh
Transfer Agent Rules
17 CFR §§240.17Ad-1 through 17Ad-22
Timely processing, recordkeeping, safeguarding
Empire's Credentials
AttributeDetail
SEC registration
Section 17A of the Securities Exchange Act of 1934
Operating since
2006
Companies served
530+ publicly traded companies
Geographic scope
Operations across 5 continents
DLT integration
Master Securityholder File with blockchain notification layer (Category 1 Model B)
3. Custody Architecture
Custody Flow
Custody Properties
PropertySpecification
Custody type
Irrevocable — shares cannot be withdrawn by the issuer
Duration
Perpetual — no expiration, no termination by issuer
Custodian independence
Empire is an independent entity — not owned by Groovy Company, Inc.
Segregation
Common B shares segregated per issuer — no commingling
Insurance
Per Empire's §17A insurance requirements
Audit
Quarterly independent custody audit published on-chain
CUSIP
Each Common B share class receives a unique CUSIP identifier (Module 1); property identifier (Module 2); basin identifier (Module 3)
Attestation
Ed25519 signed per Solana block (~400ms)
What "Irrevocable" Means
Once Common B shares are deposited with Empire, the issuer cannot withdraw them. This is not a policy — it is a contractual commitment in the tripartite agreement. The only way shares leave custody is through protective conversion (Controls 35–38), which converts them to common stock delivered to shareholders — not returned to the issuer.
This irrevocability is what makes the 1:1 backing guarantee credible. If the issuer could withdraw shares at any time, the custody attestation would be meaningless — the issuer could empty the custody account and leave token holders with worthless tokens. Irrevocable custody eliminates this attack vector by design.
4. Ed25519 Attestation Lifecycle
How It Works
Empire Stock Transfer signs a custody balance attestation on every Solana block (~400ms). The signed payload is submitted to the on-chain CustodyOracle account by the platform's relay service. The Transfer Hook reads this account on every ST22 transfer (Control 1).
Attestation Payload
Attestation Lifecycle
Attestation Security Properties
PropertyMechanism
Authentication
Ed25519 — only Empire's HSM-backed private key can produce valid signatures
Freshness
Slot number in payload — stale attestations rejected (above 1 slot returns Error 6002)
Replay prevention
Slot plus timestamp — captured attestations cannot be replayed in future blocks
Tamper detection
Signature covers all payload fields — any modification invalidates signature
Independence
Empire signs; the platform's relay transmits; Solana verifies. No single entity controls all three.
Public verifiability
Empire's public key is registered on-chain. Anyone can verify attestation signatures independently.
Key Lifecycle
PhaseProcess
Key generation
Empire generates Ed25519 keypair on HSM (hardware security module)
Key registration
Empire public key registered in CustodyOracle account at oracle initialization
Key usage
Empire signs every attestation with private key. Relay submits. Solana verifies with registered public key.
Key rotation
Empire generates new keypair → communicates new public key to the platform → governance proposal to update on-chain → 48h timelock → 3-of-5 multi-signature executes → old key deauthorized
Key compromise
Immediate: halt all transfers (Control 42). Empire revokes key. New key registered. 2-of-3 oracle consensus before resume.
2-of-3 Oracle Consensus
For discrepancy resolution and post-halt resume, 2-of-3 independent sources must agree:
SourceTypeAuthority
Primary
Empire Ed25519 per-block attestation
Authoritative — Empire holds the shares
Secondary
Platform internal verification node
Cross-references Empire data against on-chain supply
Tertiary
Quarterly third-party audit (published on-chain)
Independent institutional confirmation
Production Record
Zero discrepancy events across three beta issuers (GROO, GRLF, MSPC) and over $7M in processed liquidity. The 1:1 backing ratio has been maintained at every block with zero exceptions. This record reflects the integrity of Empire's custody operations and the reliability of the attestation architecture.
5. Master Securityholder File
What Is the MSF?
The Master Securityholder File is the authoritative, legally binding record of all Common Class B share ownership. Maintained by Empire Stock Transfer. It IS the official shareholder register for all ST22-backed securities across Modules 1, 2, and 3.
Under Category 1 Model B, the Solana blockchain serves as the operational notification layer — not the legal record of ownership. Empire's MSF is the legal record. The blockchain notifies Empire of transfers, and Empire updates the MSF accordingly.
Legal Basis
Every ST22 transfer on CEDEX constitutes an effective entitlement order under UCC Article 8 (§8-102(a)(8)), triggering an update to the MSF. Wyoming Digital Asset Statute (W.S. 34-29-101) provides additional statutory support for DLT-based securities ownership records.
MSF Update Flow
MSF Data Architecture
FieldDescriptionSource
Investor legal name
Full name as verified during KYC/KYB
Empire CIP
Investor wallet address
Solana wallet linked to verified identity
Empire KYW
Mint address
ST22 token mint (Common B share class)
Platform mint creation
Share balance
Number of Common B shares held
On-chain balance (authoritative)
CUSIP / property identifier / basin identifier
Securities or asset identifier for the Common B class
Empire issuance record
Jurisdiction
US (Reg D) or Non-US (Reg S) or US retail (Reg CF)
Empire onboarding determination
Accreditation status
Verified accredited; non-US person; or Reg CF investor
Empire verification
KYC expiry
Date KYC verification expires
Empire records
Holding period start
Date tokens were delivered
On-chain HoldingPeriodAccount
6. Investor Onboarding Flow
End-to-End Process
7. KYC — Individual Verification
Empire Stock Transfer performs all individual identity verification per BSA CIP requirements (31 CFR §1020.220).
Required Information
FieldRequiredVerification Method
Full legal name
Yes
Government-issued photo ID
Date of birth
Yes
Government ID match
Residential address
Yes (no P.O. boxes)
Utility bill or bank statement (under 90 days)
SSN/TIN (US persons)
Yes
Database verification (LexisNexis or equivalent)
Passport number (non-US)
Yes
Document verification plus country of issuance
Email address
Yes
Email confirmation
Phone number
Yes
SMS verification
Solana wallet address
Yes
Ed25519 signature challenge (KYW)
Accepted Documents
Document TypeUS PersonsNon-US Persons
Government-issued photo ID
Driver's license, state ID, passport
Passport (required)
Address proof
Utility bill, bank statement (under 90 days)
Same
Liveness verification
Biometric selfie match
Same
Re-Verification
KYC is not one-time. Empire re-verifies investors periodically and on trigger events:
TriggerAction
KYC expiry (annual)
Re-verification required — Transfer Hook Control 14 blocks expired KYC
Material change (name, address, citizenship)
Update required — investor provides new documentation
AML score change (crosses threshold)
Automatic re-review by Empire compliance
OFAC SDN list update
Re-screening on every transfer (Controls 8–10)
Unusual transaction pattern
Enhanced review triggered by platform analytics
8. KYB — Entity Verification
For corporate, fund, trust, and other non-individual investors. Per FinCEN Beneficial Ownership Rule (31 CFR §1010.230).
Required Information
FieldRequiredVerification Method
Legal entity name
Yes
Formation documents
DBA names
If applicable
State registration
Principal business address
Yes
Business utility bill or lease
EIN/TIN
Yes
IRS confirmation letter
State or country of formation
Yes
Articles of incorporation or organization
Entity type
Yes
Formation documents
Authorized signatories
Yes
Board resolution or operating agreement
Ultimate Beneficial Owners (25% or higher)
Yes
UBO declaration plus identity verification per KYC
UBO Requirements
Every individual who directly or indirectly owns 25% or more of the entity must be identified and verified through the same KYC process as individual investors. This includes government-issued ID, residential address, and SSN or passport.
9. AML and OFAC Screening
AML — Dual-Provider Architecture
Empire integrates two independent blockchain analytics providers. The higher score determines disposition.
ProviderCapabilitiesIntegration
Chainalysis KYT
Industry standard. Widest entity coverage. Law enforcement data.
REST API per-wallet
TRM Labs
200+ behavioral features. Strong emerging threat detection.
REST API per-wallet
AML Risk Disposition
ScoreTierOnboardingTradingSAR Trigger
0–30
Low risk
Approved
Transfer Hook approves
No
31–70
Medium risk
Enhanced review (24h)
Approved but flagged — compliance reviews within 24h
If investigation confirms suspicious activity
71–100
High risk
Rejected
Transfer Hook rejects (Error 6006)
Yes — SAR filed if at $5,000 or above
OFAC — Three-Layer Screening
LayerMethodCatches
1: Exact address
Direct Solana wallet match against SDN addresses
Directly sanctioned wallets
2: Fuzzy entity
Entity name and alias matching via Chainalysis entity resolution
Slight name variations ("ACME Corp" versus "ACME Corporation LLC")
3: 2-hop clustering
Transaction graph analysis — wallets within 2 degrees of SDN entities
Proxy wallet strategies, indirect funding paths
Continuous versus Onboarding Screening
CheckpointWhenPerformed By
Onboarding
Once — at initial verification
Empire Stock Transfer
Every transfer
Continuous — on every ST22 transfer
Transfer Hook Controls 8–10 (on-chain)
SDN list refresh
Hourly plus emergency push
Platform OFAC oracle indexer
A wallet that was clean at onboarding but later added to the SDN list is blocked immediately on its next transfer attempt. This continuous re-screening is architecturally impossible in an application-layer compliance system — the Transfer Hook enforces it at the Solana runtime level.
10. Wallet Verification (KYW)
Purpose
Every Solana wallet that will hold ST22 tokens must be cryptographically linked to a verified identity in Empire's Master Securityholder File. Unregistered wallets cannot receive ST22 tokens — the Transfer Hook rejects all transfers to unverified wallets (Control 15).
Verification Process
One Wallet Per Identity
Each verified identity is linked to a specific Solana wallet address. If an investor needs to change wallets (for example, lost key or hardware wallet upgrade), they must re-verify with Empire, and the old wallet is deregistered.
11. Accredited Investor Verification
US Persons — SEC Rule 501
Empire verifies accreditation using one of these qualification paths:
PathThresholdAccepted Documentation
Income
$200,000 individual ($300,000 joint) in each of the 2 most recent years
IRS W-2, 1099, K-1, tax returns
Net worth
$1,000,000 or more excluding primary residence
Broker statements, bank statements, property appraisals
Professional certification
Series 7, 65, or 82 license
FINRA BrokerCheck verification
Entity
$5,000,000 or more in assets, or all equity owners accredited
Audited financials, formation documents
Knowledgeable employee
Of the private fund issuer
Employer certification
Third-party letter
Valid for 90 days
CPA, attorney, registered broker-dealer, or investment adviser letter
Non-US Persons — Reg S
Empire verifies that the investor is not a "U.S. person" per Reg S §230.902(k):
Not a natural person resident in the United States.
Not a partnership or corporation organized under US law.
Not an estate or trust with a US executor, administrator, or trustee.
Transaction occurs in an "offshore transaction."
US Retail — Reg CF
For Reg CF offerings, Empire applies the SEC Rule 100(a)(2) investment-limit determination based on the investor's annual income and net worth, plus the FINRA-registered funding portal's intermediation requirements.
On-Chain Enforcement
Empire's verification determination is reflected on-chain. Transfer Hook Controls 12 through 14 check the investor's status on every transfer. If accreditation lapses or KYC expires, transfers are blocked until re-verification.
12. Transfer Hook Integration Map
Every Transfer Hook control that depends on Empire data:
ControlEmpire Data SourceUpdate FrequencyError on Failure
1–6 (Custody)
Ed25519 custody attestation
Every block (~400ms)
6001 / 6002
7 (KYC Status)
Empire verified investor registry
At onboarding plus re-verification
6003
8 (Accreditation)
Empire accreditation determination
At onboarding plus annual refresh
6003
9 (AML)
Chainalysis plus TRM via Empire integration
Per transfer (cached 6h)
6006
10 (Identity)
Empire CIP verification
At onboarding
6003
11 (Jurisdiction)
Empire Reg D / Reg S / Reg CF determination
At onboarding
6003
12 (Age)
Empire DOB verification
At onboarding
6003
13 (Classification)
Empire investor type classification
At onboarding
6003
14 (Expiry)
Empire KYC expiry date
Continuous — blocks expired
6003
15 (Wallet)
Empire MSF wallet registration
At KYW plus wallet changes
6004
24 (Holding Period)
Empire jurisdiction flag (US / Non-US / Reg CF)
Set at onboarding — immutable
6024
30–34 (OFAC)
Empire onboarding plus platform oracle (continuous)
Hourly refresh plus per-transfer
6003–6005
35–38 (Protective Conversion)
Empire custody records plus adverse event triggers
Event-driven
6008
Data Flow Summary
13. Protective Conversion Mechanics
Controls 35 through 38 implement automatic conversion of Common B shares to common stock upon defined adverse events — protecting investors even if the issuer or the platform fails.
Trigger Events
ControlTriggerDetectionAction
PC-35
Issuer bankruptcy filing
EDGAR 8-K detection (Layer 9) plus manual notification
Common B automatically converts to common stock per Certificate of Designation
PC-36
SEC enforcement action or criminal indictment of officer or director
EDGAR 8-K detection plus SEC notification
Same — automatic conversion
PC-37
Loss of Empire Stock Transfer services
Empire notification plus operational detection
Same — custody transfers to successor entity
PC-38
Material breach of tripartite agreement
Determination by the platform plus Empire
Conversion at discretion of non-breaching parties
Conversion Mechanics
Why This Matters
Protective conversion is the safety valve separating Category 1 Model B from Category 2. In a Category 2 architecture, if the platform fails, investors may be left holding tokens with no underlying claim. In Category 1, protective conversion ensures investors retain genuine equity ownership (common stock held at Empire) even if the platform, CEDEX, and the entire Solana blockchain ceased to exist.
14. Tripartite Agreement Structure
Three Parties
PartyResponsibilities
Issuer
Board resolution, Certificate of Designation, share deposit, ongoing SEC reporting, cooperation with regulatory inquiries
Groovy Company, Inc.
Technical infrastructure (ST22 minting, Transfer Hook, CEDEX, oracle relays), platform operations, compliance monitoring
Empire Stock Transfer
Irrevocable custody, investor onboarding (KYC, KYB, AML, OFAC), MSF maintenance, Ed25519 attestation, regulatory compliance
Key Terms
TermDetail
Custody
Irrevocable, perpetual. Empire cannot release shares to issuer.
Attestation
Empire authorizes Ed25519 signing per Solana block
Fee structure
5% of all ST22 transactions (distribution per fee config)
Onboarding authority
Empire is sole investor onboarding authority — non-negotiable
Data handling
Investor PII stays at Empire. The platform receives verification status only.
Termination
Triggers protective conversion (Control 37). No unilateral termination without investor protection.
Dispute resolution
Governed by the State of Wyoming
Duration
Co-terminous with ST22 token existence. No expiration.
15. Conflict of Interest Disclosure
Patrick Mokros serves as both Chief Operating Officer of Groovy Company, Inc. and Founder of Empire Stock Transfer. This dual role is fully disclosed.
Disclosure Framework
AspectHandling
Public disclosure
Disclosed in all SEC filings (10-K, 10-Q, 8-K), whitepaper, pitch deck, and legal documents
Related party transactions
All transactions between Groovy Company, Inc. and Empire Stock Transfer automatically classified as related party transactions
Approval requirement
Material Empire-related decisions require Audit Committee review per the platform's Related Party Policy
Fee arrangements
Standard custody and onboarding fees — modified fee arrangements require CEO and Compliance Officer approval
Equity or partnership arrangements
Require full Board approval
Why the Dual Role Exists
The dual role provides an operational advantage: direct coordination between platform operations and custody / onboarding operations without inter-company communication latency. For a platform that requires per-block custody attestation (~400ms), this tight integration is architecturally valuable.
The conflict is managed through disclosure, governance controls, and the structural independence of Empire's §17A regulatory obligations — Empire's regulatory duties to its registered companies exist independently of any relationship with Groovy Company, Inc.
16. Empire Operational Continuity
What Happens If Empire Services Are Disrupted?
ScenarioImpactResolution
Empire API temporary outage
Custody relay stops updating → oracle stales → Error 6002 after 1 slot
Transfers halt automatically. Resume when API recovers.
Empire API extended outage (over 24h)
All ST22 transfers halted
P0 incident. Direct Empire coordination. Backup attestation from quarterly audit data.
Empire business disruption
Control 37 trigger — protective conversion
Common B converts to common stock. Investors hold equity at successor entity.
Empire regulatory action
Control 36 trigger — protective conversion
Same — conversion protects investors.
Empire key compromise
False attestations possible
Immediate Control 42 freeze. Empire revokes key. New key registered. 2-of-3 consensus before resume.
Successor Custodian
If Empire Stock Transfer ceases operations or loses §17A registration, the tripartite agreement requires designation of a successor transfer agent and custodian. Common B shares transfer to the successor, and the MSF transfers with them. Investors retain equity ownership throughout the transition.
The protective conversion mechanism (Control 37) activates automatically, converting tokenized Common B shares to standard common stock — ensuring investor rights are protected even during the transition period when no custody attestation is available.
17. Module-Aware Custody Coverage
Empire's role is identical in structure across the three RWA Tokens production modules — every module uses Common Class B custody, Ed25519 attestation, KYC / KYB / AML / OFAC onboarding, and the same MSF data architecture. The module-specific differences sit at the asset-class layer, not the custody layer.
17.1 Module 1 — Equities
Asset class. Public-company equity securities sourced from OTC microcap, NASDAQ, AMEX, TSX, and other global exchanges.
Empire's specific role. Empire holds the issuer's Common Class B shares per the tripartite agreement, assigns the CUSIP, performs standard accreditation verification, and signs custody attestations every Solana block.
Module-specific onboarding considerations. Standard accreditation paths (Reg D income, net worth, professional certification, entity tests; Reg S non-US person determination; Reg CF eligibility for retail offerings).
MSF metadata. CUSIP, issuer name, share class, accreditation tier, jurisdiction.
Custody attestation cadence. Every block (~400ms), identical to all other modules.
17.2 Module 2 — Real Estate
Asset class. Tokenized real-property assets held via single-asset entities.
Empire's specific role. Empire holds the Common Class B shares of the single-asset entity (the entity that holds title to the real-property asset). The economic exposure is to the single-asset entity's equity, which in turn holds the property.
Single-asset entity structure. Each Module 2 issuance corresponds to one single-asset entity (typically a Nevada corporation or comparable structure). The Certificate of Designation authorizes the Common Class B share class. Empire's custody is of the entity's equity, not of the property itself; the property is held by the entity per its title documentation.
Module-specific onboarding considerations. Standard accreditation paths apply. Module 2 issuances typically pair with a property identifier and appraisal-cycle metadata in the MSF.
MSF metadata. Property identifier, jurisdiction of the single-asset entity, share class, accreditation tier, current NAV reference, last appraisal date.
Custody attestation cadence. Every block (~400ms), identical to all other modules. The Module 2 NAV oracle is a separate per-mint oracle that exists alongside Empire's custody attestation — the NAV oracle reports appraised value; Empire's custody attestation continues to report 1:1 backing of Common B shares.
17.3 Module 3 — CORECM
Asset class. Tokenization of US strategic minerals supply chain. CORECM means Carbon Ore, Rare Earth, and Critical Minerals. Frameworks include the USGS Critical Minerals List, the DOE Critical Materials Strategy, Section 232 of the Trade Expansion Act of 1962, Title III of the Defense Production Act, the Inflation Reduction Act critical-minerals provisions, Executive Order 14017, and the Energy Act of 2020. Carbon Ore covers DOE coal-derived rare-earth element recovery.
Empire's specific role. Empire holds the Common Class B shares of the basin-asset entity (the entity that holds the mineral basin or mining concession). As with Module 2, custody is of the entity's equity, not of the underlying physical asset.
Module-specific onboarding considerations. Empire applies enhanced KYC depth for Module 3 issuances. Enhanced depth includes verification of any federal-program eligibility constraints applicable to the basin (such as DOE coal-derived REE recovery program participation), confirmation of the investor's eligibility under any applicable export-control regime, and additional review for entity-investor UBO chains where federal counter-party diligence is appropriate.
MSF metadata. Basin identifier, USGS classification, mineral class, jurisdiction of the basin-asset entity, share class, accreditation tier, federal-action status.
Custody attestation cadence. Every block (~400ms), identical to all other modules. The Module 3 Classification oracle is a separate per-mint oracle that exists alongside Empire's custody attestation — the Classification oracle reports federal classification status; Empire's custody attestation continues to report 1:1 backing of Common B shares.
Federal-action coordination. Empire is a coordinating party in the Module 3 federal-action freeze runbook (Incident Response Playbook Section 13). When a federal action is issued affecting a basin asset, Empire is notified within the 15-minute response SLA and participates in the protective response.
17.4 Cross-Module Custody Properties
Identical across modules:
Irrevocable, perpetual Common Class B custody at Empire.
Per-block Ed25519 custody attestation.
1:1 backing invariant enforced by Transfer Hook Control 1.
KYC, KYB, AML, OFAC, and KYW onboarding authority resides solely with Empire.
MSF as the legal record of ownership; blockchain as notification layer.
Tripartite agreement structure (Issuer, Groovy Company, Inc., Empire).
Protective conversion mechanics (Controls 35 through 38).
Successor-custodian provisions for operational continuity.
The platform's structural guarantee — that no investor depends on the platform's solvency or operational continuity for their underlying equity claim — applies identically across all three modules because Empire's role applies identically.
Related Documentation
Solana Blockchain Foundation — Why Solana, Token-2022, Transfer Hook, module-specific foundations
Architecture Decisions — ADR-001 through ADR-012, with ADR-012 specifically covering Empire as sole onboarding authority
Security Model — Threat model, key management, formal verification, module-specific threat surfaces, bug bounty
Infrastructure Overview — Cloud architecture, environment separation, blockchain infrastructure
Network Configuration — Program addresses, RPC endpoints, oracle PDAs, multi-signature addresses, production parameters
Deployment Guide — Build, deploy, verify, upgrade, rollback procedures including Empire integration steps in module-specific initialization
Incident Response Playbook — P0 through P3 runbooks; Empire coordination explicit in custody discrepancy and federal-action freeze runbooks
Oracle Integration Guide — Ed25519 relay service implementation, custody oracle architecture, fail-safe cascade
Issuer Onboarding Guide — Customer-facing nine-stage process including Empire custody and share deposit
Compliance Integration Guide — BSA / AML program, OFAC sanctions, regulatory mapping, federal-action coordination
Smart Contract Reference — CustodyOracle account schema, Control 1 implementation
Whitepaper Section 6 — Oracle Network architecture
RWA Tokens · Empire Stock Transfer Integration · Groovy Company, Inc.
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