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DBIS

Counsel

Counsel sign-off status

Signed by P.C. Walker, Esq., Chief Legal and Compliance Officer. Engineering readiness tracks are separate from statutory registrations — operator execution gates (live bank confirm, executed FI contracts) may still apply where noted below.

Summary

Counsel sign-offs
Complete
Track A
Signed2026-06-17
Retail e-money / wallets
blocked

Machine-readable: counsel-signoff-status.json · Full register (proxmox)

Legal tracks

Track A — Order capacity

Counsel signed — checklist A–I

Does SMOM have capacity to charter under Order law?

International legal personality, GUOSMM Tier 1 acts, prohibited-claims register.

Documentation →

Track B — Operational transactability

WP-1–5 signed (sovereign governmental scope)

Can entities operate and settle in external jurisdictions?

Banking, AML, correspondent, Indonesia perimeter, US-CO-OMNL matrices.

Documentation →

Track B work packages

  • WP-1US Colorado OMNL banking transactabilitySigned (2026-06-17)
  • WP-2Indonesia BI/OJK matrix validationSigned (2026-06-17)
  • WP-3Cross-border institutional settlement (Rail + ISO)Signed (2026-06-17)
  • WP-4AML / FATF / travel rule (institutional)Signed (2026-06-17)
  • WP-5EU/UK EMI and MiCADeferred

Jurisdiction cards

  • IndonesiaCounsel signed — Scenario A

    Technology provider + licensed partners; BNI live contract operator-gated

  • US Colorado — OMNL head officeCounsel signed — institutional scope

    WP-1 complete (10/10 rows); MSB not required for current institutional scope; live correspondent/FI contracts operator-gated

  • US Colorado — UCC Article 9Pilot ready

    Secured-transactions filing evidence lane

Counsel contact

← Compliance program hub