Module 05
Compliance & advisor
29 regulatory gates across Groups A–F. Group A conditions precedent gate issuance entirely.
Total gates
29
Satisfied
0
In progress
0
Blocked
0
Group A · conditions precedent
Issuance blocked — 5 of 5 outstanding
A1
Issuer holds regulatory authorisations…
A2
SSB appointed and structure…
A3
Custody agreement executed and…
A4
Issuer KYC/AML onboarded via…
A5
Data-protection, security and integration…
Group A
Conditions precedent
Clause 4. Issuance is blocked until all five are satisfied.
A1Cl. 4.1· Issuer
Issuer holds regulatory authorisations to issue and distribute
All licences and consents required to issue and distribute Sukuk in the elected jurisdictions.
A2Cl. 4.2· SSB
SSB appointed and structure certified
SSB constituted and has certified the structure and documentation for Series 1.
A3Cl. 4.3· Custodian
Custody agreement executed and first tranche assayed
Custody agreement live; first allocated tranche received and independently assayed.
A4Cl. 4.4· Issuer
Issuer KYC/AML onboarded via DeepZero Gate
Issuer entity fully onboarded through DeepZero Gate (Module B).
A5Cl. 4.5· Technology Provider
Data-protection, security and integration documentation executed
Schedules 2 and 3 executed. Integration accepted.
Group B
Custody and prudential
Clauses 8–9. Allocated, segregated, insured; ≥995.0 fineness.
B1Cl. 8.1· Issuer
Custody jurisdiction elected (FINMA or MAS)
Election recorded; fallback right to switch jurisdiction preserved.
B2Cl. 8.2· Custodian
Accredited custodian appointed
Custodian holds required regulatory authorisations.
B3Cl. 8.3· Custodian
Allocated, segregated and insured holding
Bars ring-fenced; all-risks vault and transit insurance in force.
B4Cl. 9.1· Custodian
Minimum 995.0 fineness / LBMA Good Delivery
All bars meet or exceed LBMA Good Delivery.
B5Cl. 9.2· Custodian
Accredited assay and independent periodic audit
Quarterly independent assay/audit scheduled.
Group C
Shariah
Clauses 7–8, 19. SSB constitution and per-series certification.
C1Cl. 7.1· SSB
Shariah Supervisory Board constituted
SSB appointed with quorum of qualified scholars.
C2Cl. 7.2· SSB
Structure approved (Wakala / Murabaha / Ijara)
Structure and documentation approved for the series.
C3Cl. 7.3· SSB
AAOIFI conformity
Structure conforms to applicable AAOIFI standards.
C4Cl. 8.4· SSB
Avoidance of riba, gharar and maysir
Documented determination on prohibitions.
C5Cl. 19.1· SSB
Per-series certification & ongoing review
Every series individually certified; annual review scheduled.
C6Cl. 19.4· SSB
SNCE remediation and income purification
Shariah Non-Compliance Event playbook defined.
Group D
Financial crime
Clause 15. Anti-bribery, sanctions, AML/CTF.
D1Cl. 15.1· Issuer
Anti-bribery — UK BA 2010 / US FCPA / HK POBO
Policies and adequate procedures in place.
D2Cl. 15.2· Technology Provider
Sanctions screening — UN / EU / OFAC / Switzerland
Multi-list screening at onboarding and continuously.
D3Cl. 15.3· Issuer
Risk-based AML/CTF programme
RBA framework documented and adopted.
D4Cl. 15.4· Technology Provider
Ongoing monitoring
Continuous transaction and counterparty monitoring.
Group E
Data and security
Clause 14. GDPR / FADP / PDPA / PDPO; post-quantum controls.
E1Cl. 14.1· Technology Provider
GDPR / FADP / PDPA / PDPO compliance
Data-protection posture across EU, CH, SG, HK.
E2Cl. 14.2· Technology Provider
Post-quantum controls
CRYSTALS-Kyber & CRYSTALS-Dilithium in the crypto stack.
E3Cl. 14.3· Technology Provider
Incident notification without undue delay
Notification playbook and SLAs.
E4Cl. 14.4· Issuer
KYC record retention
Retention periods per each applicable regime.
Group F
Ongoing
Clauses 16–18, 20. Audit rights, insurance, tax, remediation.
F1Cl. 16.1· Issuer
Audit and inspection rights (max twice yearly)
Right to audit exercised at most twice per year.
F2Cl. 17.1· Custodian
Vault all-risks and transit insurance
Coverage sized to holdings.
F3Cl. 17.2· Technology Provider
Professional indemnity and cyber cover
PI + cyber policies in force.
F4Cl. 18.1· Issuer
Tax gross-up election
Election recorded per Clause 18.
F5Cl. 20.1· Issuer
Regulatory-change remediation
Change-in-law remediation process defined.
AI structuring advisor
Live Q&A
Trained on the executed agreement — Schedule 4 fee arithmetic, custody regimes, Shariah structures, and financial-crime posture.