RCAICO · The Offering

Chapter 05 of 08

The Offering · Vol. 02 No. 01

The Room · 05

September 2026 · London

KYC, the travel rule, and who is actually your customer · Data

Identity data is not a marketing asset

Passports in a Notion board are a breach waiting for a date.

Purchaser KYC data is high-risk personal data. It needs a controller, a purpose, a notice, a vendor with a contract, access control, retention, and a deletion story. It does not need to live next to the claims register. Mixing comms and KYC is how a contractor sees passports. Contractors seeing passports is how you write to a data commissioner as well as a financial one.

Product waitlists collect the minimum. Offering processes, if they exist, collect what the process legally requires, on rails designed for it. Do not pre-collect “so we’re ready.” Readiness is a programme, not a Dropbox.

Next step

Planning a regulated ICO? Same screen as everyone.

Four-step screen. A person replies. Fourteen days to a pack you can take to market. 0% of proceeds.