Chapter 07 of 10
The Offering · Vol. 02 No. 01
The Statute · 07
September 2026 · London
Pathways that exist, pathways that are proposed, pathways that are folklore · Intermediaries
Pads, agents, KOLs, and the arranging problem
If someone is paid to find buyers, you may have built a distribution chain. Chains have laws.
2017 outsourced distribution to pads, bounty hunters and influencers. 2026 still tries. The legal problem is not aesthetic. Paying a person a success fee, a token kickback, or a “listing support” invoice to introduce purchasers can look like brokerage, arranging, or a promotions breach, depending on the market. This house will not be that person. We will also not design your campaign as if those people were a free resource.
If you use a platform that takes assets, allocates tokens, or runs a sale UI, that platform is part of the offering machinery. Their terms, their licence, their KYC, their jurisdiction mix become your facts. “The pad handles it” is not a pathway. It is a delegation you may not be able to make.
Creators are channels. Market makers are counterparties. Exchange BD is a counterparty conversation, not a marketing claim. Keep them in the partner map and the register. Do not keep them in the hero as “partners” if the partnership is a hope.