Chapter 07 of 08
The Offering · Vol. 02 No. 01
The Room · 07
September 2026 · London
KYC, the travel rule, and who is actually your customer · Venue
Do not become an exchange by accident
Matching, taking orders, operating a book, holding both sides — those are other licences.
Issuers who add a “launch UI” sometimes discover they have built a venue: a place where people send value and receive an asset, with the issuer in the middle. That can be a regulated activity in multiple markets. It is always a different business from communications. RCA Pad will not help you sketch that UI. Other firms might. They will need licences, or they will need luck.
Secondary-trading talk is also a venue-adjacent claim. “Will be listed on —” is a listing hope. “Trade now in our app” is a product that needs its own perimeter. Keep secondary out of the offering hero unless the product exists and counsel has the perimeter on file.