We are an engineering company. A software vendor cannot hold supervisory compliance — the licence, the permissions and the obligations are yours. What we can do is build the platform so that your supervisor’s questions have answers in the system rather than in someone’s spreadsheet. The platform is built to meet FINMA and MiCA requirements, and is designed so that a licensed operator can satisfy its FINMA and MiCA obligations.
Identity, transaction controls and the audit trail
Run the built-in identity system or connect a provider such as Sumsub: the case queue, the review workflow and the audit record stay the same either way, so changing provider changes your supplier, not your control environment. Transaction controls are configuration rather than custom work — KYT thresholds on withdrawals, address and symbol whitelists, per-level limits, auto-approve ceilings on internal transfers. Every administrative action, balance movement, configuration change and approval decision is attributable to a named operator and exportable. That is where a supervisor and an auditor both start, and it is why role separation is a platform feature here rather than an operating procedure.
Data residency
Deployment in Zurich, Frankfurt or Istanbul, or inside your own facility. Where your data sits is a decision you make, not a consequence of your vendor’s hosting choices. Where it sits and where administrative access to it originates are two different questions, and we answer both.
The Travel Rule
Transfers of crypto-assets between service providers have to carry originator and beneficiary information, and transfers to and from self-hosted addresses need a stated policy. In the EU that arrives with the recast Transfer of Funds Regulation alongside MiCA; in Switzerland it sits inside FINMA’s anti-money-laundering rules; internationally it is the FATF travel-rule standard. In every version the obligation belongs to the licensed operator, and a vendor who tells you their product makes you compliant with it is describing something that does not exist.
What the platform brings to it is architecture: the identity record the rule depends on, the withdrawal path and its KYT threshold, address and whitelist management, the on-chain and off-chain distinction and the exportable audit trail are in one system we wrote. What we will not print is a travel-rule messaging implementation as a shipped feature. Whether that messaging is engineered into the withdrawal path, or connected to the provider your counterparties already expect, is a design decision we work through in Discovery and write down before a contract. Ask us early; the exchange page sets out the full treatment.
Three ways to run it, and who holds administrative access
On-premise: your data centre or your own cloud tenancy, your keys, your data, and no dependency on us to keep trading — where regulated institutions and banks usually land. Platform-as-a-service: we host and operate it across our own cage space in Zurich, Frankfurt and Istanbul. Managed Exchange Operations: you run an exchange without hiring a technical team, because we hold the technical operations while you hold listings, pricing, marketing, compliance decisions and your customers.
The third model changes the access question, and we will not blur it. In our infrastructure services we do not need to see application data, and we do not: the boundary is the platform, not the records on it. Operating a live venue is different — named engineers of ours hold administrative access to the systems carrying your customers’ records and balances, scoped to defined roles, granted to named individuals rather than a team account, reached through multi-factor authentication, logged per action and reviewed on a schedule. Any vendor who offers to operate your exchange and also tells you they never touch your data is telling you one of those two things inaccurately. The full controls, and the split of who does what under each model, are on White Label Crypto Exchange in detail.
How this is priced
We do not publish a figure, and we do explain the model, because a buyer building a business case needs the shape of the bill long before the number. On-premise is a licensed deployment: an implementation engagement, then a licence and support arrangement. Platform-as-a-service and Managed Exchange Operations are subscriptions carrying the platform, the infrastructure and the operational work, with the same implementation engagement in front of them.
What is not in either shape is a third-party meter — no per-verified-user, per-address, per-request or per-monthly-active-user charge — because those components are not somebody else’s software. Bring your own identity or custody provider and that supplier’s meter is yours; we say so during Discovery rather than after signature. Send us a scope and you get an indicative figure in writing within 2 business days, before any call.
