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No custody · No keys · Built for MiCA-licensed firms

The decision layer for digital‑asset transactions.

ALLOW, REVIEW or DENY, with evidence, before an institution credits a deposit, links a wallet or signs a transfer. On top of the screening vendors you already pay for.

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For banks, custodians, EMIs and licensed crypto-asset service providers.

Decision record D-1010 · policy v2
REVIEW
Withdrawal, before the custodian signs $8,000 USDC · fresh address, never seen before

Not signed. Case opened at L2; out-of-band verification with the customer must be recorded first.

Why · 12 rules evaluated, 3 fired

  • R-ATO-301Credentials changed 0.5h ago, then a new deviceREVIEW
  • R-ATO-304Destination added 12 min ago; 60-minute cooling-offREVIEW
  • R-VEL-310Withdrawal 5.3× the 30-day averageREVIEW
evidence · hash-chainedf2f69ad043…
Illustrative scenarios from the Recordal prototype. Vendors simulated.
Recordal prototype: an $8,000 withdrawal held at REVIEW before the custodian signs, with the three rules that fired
Held, not denied. A password reset, a new device and a destination added 12 minutes earlier: signals the bank already had, joined to the signing decision for the first time. Nothing is signed until a compliance officer records an out-of-band verification.

View full screenshot ↗Recordal prototype, October 2026. Vendors and AI output simulated and labelled; the engine, policy versioning, rescoring path and evidence log are real.

Sits above the vendors and systems you already run

  • TRM Labs
  • Chainalysis
  • ComplyAdvantage
  • Notabene
  • Sardine
  • Core KYC & ledger
  • Address book

Connectors stay on your own contracts. Swap a vendor; keep the policy and the history.

01 Why now

Stablecoins are moving onto regulated balance sheets.

The rails are live. The controls behind them still live in vendor dashboards, spreadsheets and screenshots.

Adoption

Consumer apps already move USDC

Block's Cash App sends and receives USDC on Solana, Ethereum, Polygon and Arbitrum: a payments company running four chains under bank-grade compliance obligations.

Risk

Illicit flows moved to stablecoins

FATF's July 2026 update: most illicit on-chain activity now runs through stablecoins, the same assets institutions are adopting.

Regulation

The rulebooks have landed

EU Travel Rule, MiCA licensing, DORA, FinCEN's AML/CFT modernization rule and GENIUS Act stablecoin rules.

Six rulebooks, one demand

Every one of these flows now needs a decision a supervisor can inspect afterwards.

  1. EU Travel Rule (EBA Guidelines)

    Per-transfer data checks at any amount; 3/5/7-working-day escalation; repeat failers reported within 3 months.

  2. DORA

    ICT risk, incident logging and oversight of third-party providers, screening vendors included.

  3. FinCEN AML/CFT program rule

    Effective, risk-based programs with evidence of effectiveness; about 12 months to comply.

  4. MiCA CASP licensing

    Transition periods are over. Licensed entities have supervisors who examine; the first examinations are happening now.

  5. FATF Travel Rule enforcement

    83% of jurisdictions have the law; 60% of those have not enforced it yet. Enforcement is the next wave.

  6. GENIUS Act stablecoin rules

    Issuers must be able to block, freeze and reject; SAR duties in the primary market.

Sources: Cash App stablecoin documentation (2026); FATF Targeted Update on Virtual Assets, Jul 2026; EBA/GL/2024/11; MiCA Art. 143; DORA; FinCEN NPRM fact sheet, Apr 2026; GENIUS Act implementing proposals.

02 The gap

Vendors flag. Nobody decides, and nobody keeps the record.

$40M

NYDFS consent order against Block, Inc., April 2025. Block had screening vendors. It lacked a policy of record: thresholds with a written rationale, decisions with evidence, and a queue that could not silently grow.

  • Alerts fired only above 1% exposure to terrorism-financing sources; blocks only above 10%.
  • Exposure to mixers was rated medium risk.
  • The alert backlog grew from 18,000 (2018) to 169,000 (2020).
  • NYDFS: exposure above 0% without a risk-based analysis “falls short.”

Source: NYDFS Consent Order, In the Matter of Block, Inc., 10 April 2025, paras 19 and 24.

Where the decision lives today

The vendor

A score for an address

TRM, Chainalysis and Elliptic return risk scores and tags. They do not know the licence conditions, the risk appetite or the customer behind the transfer.

The institution

Spreadsheets, tickets, screenshots

Thresholds in a spreadsheet, decisions in tickets and chat, evidence in screenshots: how over 70% of firms still document compliance.

The examiner

“Show me the decision”

Asks for the rule in force that day, the evidence, and who signed off. 90% of regulators now check Travel Rule compliance in examinations.

Source: Notabene, State of Crypto Travel Rule 2025 (91 firms surveyed).

03 The product

One decision at the three moments money moves.

ALLOWREVIEWDENYPENDING

Each with the rules that fired, the signals used and the vendor evidence attached.

  1. Control point 1

    Before credit

    An inbound transfer seen by the institution's chain watcher. Source exposure, Travel Rule data and customer risk are decided before the ledger credits.

  2. Control point 2

    Before wallet link

    A customer adds a withdrawal address. Ownership proof (the EU self-hosted wallet rule), sanctions and exposure are decided before it is whitelisted.

  3. Control point 3

    Before signing

    An outbound transfer. Account-takeover signals, limits and counterparty checks are decided before the custodian signs.

Recordal holds no keys and no funds. It returns the decision, the reasons and the evidence; your ledger or custodian executes.

04 How it works

One API call at each control point.

Your vendors' answers become one canonical signal set. Your rules decide. Your systems execute.

  1. 01Signals

    TRM Labs or Chainalysis, ComplyAdvantage, core KYC and ledger, Sardine, the address book, Notabene.

  2. 02Adapters

    Each vendor's answer mapped to one canonical signal; the raw field kept beside it. Swap TRM for Chainalysis without touching a rule.

  3. 03Policy engine

    Your rules, versioned and hashed. Every applicable rule runs.

  4. 04Decision + evidence

    ALLOW, REVIEW, DENY or PENDING, with reasons, signals and vendor reports.

  5. 05Ledger / custodian

    Executes the decision. Recordal never touches funds or keys.

Tiered review queue

L1 analystL2 compliance officerL3 MLRO

Hard rules cannot be overridden at any tier. Account-takeover cases need an out-of-band verification recorded first. Every action is logged.

Exam pack

  • Policy version in force
  • Rules that fired
  • Vendor evidence
  • Reviewer and timestamps

For any decision, everything an examiner asks for, in one export.

05 System of record

A record an examiner accepts.

Built so the answer stays right when the facts change, and so you can prove how you got there.

Never a silent ALLOW

A missing input holds the request and retries. What happens next (hold, review or a low-value degraded mode) is a policy choice, recorded as a rule, never as a default.

Every rule runs

No short-circuits. Every applicable rule evaluates and records its result, so the audit record is complete. Hard rules cannot be overridden by anyone.

Policy of record

Rules are versioned and hashed. Changes are simulated against history and need dual approval before they go live.

Replay and rescoring

New intelligence, a vendor coming back or a new policy version re-runs every decision it touches. The original stays; the rescored one supersedes it, with a case if the answer changed.

Tamper-evident

Every decision and every review action lands in a hash-chained evidence log. Records can be added, never rewritten.

Vendor-neutral

TRM or Chainalysis, ComplyAdvantage, Sardine, Notabene and your own systems, normalized into one signal set. Swap a vendor; keep the policy and the history.

06 Where AI fits

It writes, explains and integrates. It never decides.

AI writes

Adapters from a sample payload. Policy changes from plain English. Case briefs, examiner explanations, SAR narrative drafts. A person approves every one.

The engine decides

Every ALLOW, REVIEW and DENY comes from fixed rules under a versioned policy. No model in the decision path, so every decision replays exactly.

The record proves it

Every decision, approval and accepted AI draft is hash-chained in the evidence log. An examiner sees who accepted what, and when.

Integration

Reads a sample from your custody or ledger system, maps each field to a signal, writes and tests the adapter; an engineer approves.

Weeks of integration work

Policy authoring

“Review any deposit with 10% or more mixer exposure” becomes a drafted rule change, with what it would have changed on the ledger.

Engineering tickets for every threshold change

Case brief

What happened, key facts, similar past decisions, the next step and a drafted analyst note.

Analyst minutes per case

Examiner explanation

The decision record in plain English, every sentence from a stored field; plus a SAR narrative draft.

Days rebuilding the answer by hand

Regulation watch

Reads new rules and memos, says whether they touch your policy, and drafts the change.

Missed changes between reviews

07 Who it's for

Built for institutions that will be examined.

A

Licensed CASPs and EMIs in the EU

Now supervised under MiCA and examined on Travel Rule and screening. Built to help you pass the first examination.

B

Banks adding stablecoin rails

Custody, payments and deposits in stablecoins. The decision belongs inside your existing risk framework, not in a vendor dashboard.

C

US bank stablecoin subsidiaries

Under the GENIUS Act rules from January 2027, block, freeze, reject and report capabilities become table stakes.

08 Getting started

Land on one flow. Expand by control point.

  1. 01

    Two-week policy spike

    One real flow (inbound stablecoin deposits), your own vendors, your thresholds written as rules.

  2. 02

    The exam pack is the demo

    We show the artifact an examiner will ask for, generated from your own decisions.

  3. 03

    Go live behind the ledger

    Decision before credit first; then wallet link and outbound signing.

  4. 04

    Expand

    More chains, vendors and entities as your book grows.

Every stablecoin a regulated institution touches will need a decision of record.

No custody. No keys. One answer, with the evidence attached, that stays right when the facts change.

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