Licensing & Regulatory
Who actually holds the money, and how the regulated pieces work. Last updated July 2026.
Transparency about the regulated parts of the platform matters. This page describes how money movement is provided and our current regulatory posture. It is informational and not legal, tax or financial advice.
1. A technology platform, with a bank behind the money
Digital Treasury is a software platform, operated by Digital Treasury Inc. It is not a bank and does not itself take deposits or transmit money. Regulated money movement is provided by our chartered sponsor-bank partners and their payment rails; Digital Treasury provides the technology, orchestration and ledgering on top of those arrangements.
2. FBO structure
Where customer funds are held, they are held at the sponsor bank in a "for benefit of" (FBO) arrangement and tracked to each business and end user through our double-entry ledger. Funds are not commingled with Digital Treasury's operating funds. Any pass-through deposit insurance is provided by the bank subject to its conditions.
3. Current phase — no live money
The platform is operated in a development phase with simulated bank rails. No live customer money is moved and no funds are held today. Production money movement is enabled per customer only once the applicable banking, compliance and regulatory arrangements are in place under an executed agreement.
4. Compliance program
Money movement is subject to a Bank Secrecy Act / anti-money-laundering (BSA/AML) program, sanctions (OFAC) screening, and customer due diligence (KYB/KYC), performed with and under the oversight of our sponsor bank. See Compliance for more.
5. Money-transmission licensing
Because regulated activity runs through chartered bank partners, Digital Treasury operates under the bank-partnership model rather than as a licensed money transmitter. To the extent any activity would require state money-transmitter licensing or federal registration, we will obtain or operate under the appropriate authority before enabling it. [Specific bank partners, charters and any registrations will be listed here as production arrangements are finalized.]
6. Cards
Card programs, where offered, are issued by a card-issuing bank member of the relevant network through our issuer-processor partners. Cards are subject to network rules and the issuer's terms.
7. Questions
Diligence questions from partners, banks or regulators are welcome through the contact page.