Resources
Legal Framework
How memento operates within regulatory boundaries while delivering innovative DeFi services.
Overview
memento is designed from the ground up to operate in compliance with applicable regulations while maximizing user privacy and autonomy. This page explains the legal framework that enables our services and the measures we take to ensure sustainable operations.
Regulatory Classification
Understanding how our services fit within existing regulatory frameworks is essential for both users and the platform itself.
Vaults: Non-Custodial Structure
memento Vaults operate as non-custodial Solana programs. Users retain full control of their assets at all times through their own wallets. This structure is significant because:
- Users interact directly with on-chain programs, not a centralized entity
- Withdrawals can be initiated at any time without permission
- No single party holds custody of user funds
- Programs are deployed on Solana and verifiable on-chain
Yield Aggregator: Information Service
The Yield Aggregator functions as an information aggregation and curation service. It does not:
- Hold or manage user funds
- Execute trades on behalf of users
- Provide personalized investment advice
- Guarantee any returns or outcomes
Users make their own decisions about which opportunities to pursue and execute transactions through their own wallets on external protocols.
memento Alphas: Research Publication
Alpha reports are published research content, similar to financial newsletters or research publications. Key distinctions:
- Reports are general educational content, not personalized advice
- No fiduciary relationship is established with readers
- Users are responsible for their own investment decisions
- All reports include appropriate disclaimers
Jurisdictional Approach
memento takes a thoughtful approach to jurisdictional considerations:
Permissionless Access
As a decentralized protocol on Solana, memento programs are accessible to anyone with a Solana wallet. The protocol itself does not perform geographic restrictions at the program level.
Frontend Compliance
The memento.money frontend may implement geographic restrictions for users in certain jurisdictions where regulatory clarity is lacking. Users in restricted regions can still interact directly with the on-chain programs if they choose to do so.
User Responsibility
Users are responsible for ensuring their use of memento complies with the laws and regulations of their jurisdiction. This includes tax obligations, reporting requirements, and any restrictions on DeFi participation.
$MM Token Classification
The $MM token is designed as a governance and utility token with the following characteristics:
| Characteristic | Description | Regulatory Implication |
|---|---|---|
| Governance Rights | Vote on protocol parameters and upgrades | Utility function, not profit expectation |
| Fee Discounts | Reduced fees for token holders | Consumptive use case |
| No Dividends | No passive income distribution | Not a security characteristic |
| Deflationary Mechanics | Buyback and burn from fees | Value accrual through utility, not profit sharing |
Not Investment Advice
Program Security
Security is foundational to legal compliance. Poorly secured protocols expose users to unnecessary risk and potential regulatory scrutiny.
Audit Status
All memento Solana programs undergo security audits before deployment. Audit reports are published publicly for transparency.
Bug Bounty Program
We maintain an active bug bounty program to incentivize responsible disclosure of vulnerabilities. Rewards are commensurate with severity.
Upgrade Mechanisms
Critical programs are non-upgradeable to prevent unauthorized changes. Upgradeable components use time-locked governance to ensure community oversight.
x402 Payment Compliance
The x402 protocol enables compliant micropayments for digital services:
Payment for Services
x402 payments are straightforward purchases of access to digital services. This is analogous to paying for a subscription or API access with cryptocurrency.
USDC Settlement
All x402 payments settle in USDC, a regulated stablecoin issued by Circle with full reserve backing and regular attestations. This provides clarity on the value exchanged.
On-chain Records
All payments are recorded on-chain, providing immutable audit trails for accounting and compliance purposes.
Risk Disclosures
Transparency about risks is both a legal requirement and ethical obligation:
Material Risks
- Program Risk: Despite audits, Solana programs may contain undiscovered vulnerabilities that could result in loss of funds.
- Market Risk: Cryptocurrency markets are volatile. The value of deposited assets and earned rewards can fluctuate significantly.
- Regulatory Risk: Regulatory changes could affect the availability or legality of DeFi services in certain jurisdictions.
- Protocol Risk: Third-party protocols integrated with memento carry their own risks that may affect user funds.
- Stablecoin Risk: Stablecoins may experience depegging events that affect the value of deposits and rewards.
Important
Data and Privacy
memento is designed with privacy as a core principle:
No KYC Required
Basic vault access requires only a wallet connection. No identity verification for standard features.
Minimal Data Collection
The frontend collects only essential analytics. No personal data is stored or sold.
On-chain Privacy
Users can use fresh addresses for enhanced privacy. We recommend this for privacy-conscious users.
No Data Sharing
User activity data is not shared with third parties for marketing or profiling purposes.
Legal Documents
For complete legal terms governing the use of memento:
Questions?