SOLC Regulatory & Compliance Addendum
Last Updated: September 29, 2025 • Contact: solstaff@soundoflife.media
1) Regulatory Posture (Utility-Only; Non-Custodial)
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Utility token. SOLC is designed and marketed solely for access, participation, and rewards within SOL (e.g., token-gated content, discounts, allowlists, perks). No equity, dividends, revenue share, or profit rights; no promises or expectations of price appreciation. We avoid marketing suggesting profits “from the efforts of others,” consistent with the SEC’s Howey framework for digital assets. (SEC)
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No brokerage/exchange/custody. SOL does not provide order routing, order books, brokerage, dealing, custodial wallets, or exchange services. Users connect self-custody wallets to interact directly with third-party protocols (e.g., Uniswap) at their own discretion.
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Not a money transmitter. SOL does not accept and transmit “currency, funds, or other value that substitutes for currency” for the public; we do not take possession of user funds or keys. Accordingly, based on FinCEN’s CVC guidance and the BSA definition, SOL is not operating as an “administrator or exchanger” MSB. If our activities change to include acceptance/transmission or hosted custody, we will register as an MSB and implement a full BSA program. (FinCEN.gov)
2) AML/CFT & Sanctions
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Sanctions compliance. SOL blocks or will block access by sanctioned persons and comprehensively embargoed regions and will screen transactions that involve our brands, commerce, or reward fulfillment against U.S. sanctions lists (e.g., OFAC SDN). Strict-liability sanctions apply to U.S. persons; we maintain procedures for screening, blocking, recordkeeping, and (where required) reporting. (OFAC)
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Jurisdiction restrictions (examples, updated with law): Cuba, Iran, DPRK, Syria, Russia-occupied Ukrainian regions (including Crimea, Donetsk, Luhansk, Zaporizhzhia, Kherson), and any region later designated.
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Risk-based AML. Although SOL is not acting as a money transmitter, we operate a risk-based AML/CFT program proportionate to our activities: (i) fraud/abuse monitoring, (ii) sanctions screening, (iii) event-driven ID verification (e.g., high-value prize fulfillment), (iv) recordkeeping, (v) escalation & law-enforcement cooperation. We track updates to FATF Recommendation 15 and the Virtual Asset/ VASP standards (including Travel Rule expectations for VASPs; if we ever become a VASP, we will implement Travel Rule compliance). (FATF)
3) Market Conduct & Communications
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No investment marketing. We don’t portray SOLC as an investment, don’t discuss price targets, and don’t induce trading volume. Content focuses on utility access and community participation.
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Airdrops/giveaways. Programs use “no purchase necessary” AMOE, equal odds, eligibility checks, and tax compliance. Rewards/NFTs have no cash value and confer no financial rights.
4) Operational Controls (implemented or scheduled)
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Geo/IP and wallet gating for sanctioned locations/persons; periodic list updates.
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No custody: no private-key handling; no “send us funds” flows; no hosted wallets.
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DEX disclaimers: clear that swaps occur via third-party protocols; SOL is not an exchange.
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Risk monitoring: anomaly flags for sybil/bot activity, mixer/bridge risk (screen public addresses before reward fulfillment).
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Event-driven KYC: only when legally required (e.g., high-value prizes/shipments or fraud red flags).
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Recordkeeping: retain sanctions checks, eligibility determinations, and giveaway logs per jurisdictional law.
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Communications QA: approve public posts to avoid investment language.
Paste-ins for your existing docs
A) Terms of Use — Compliance Clauses
Add under “Compliance; Export; Sanctions” and “Wallets; On-Chain Activity”:
Regulatory Posture. SOL provides software, content, and membership utilities. SOL does not provide brokerage, exchange, order routing, or custodial services and does not accept or transmit funds or other value for the public. You interact with third-party protocols at your discretion using self-custody wallets. SOLC is a utility token; it does not grant equity, dividends, revenue share, or profit rights, and SOL makes no promises or expectations of price appreciation. (SEC)
Sanctions & Prohibited Use. You represent and warrant you are not on any U.S. sanctions list and are notlocated in a comprehensively embargoed jurisdiction. SOL may geoblock, decline, or reverse access, rewards, or shipments to comply with sanctions laws and may retain records of screening activities. (OFAC)
No Money Transmission. SOL does not accept or transmit “currency, funds, or other value that substitutes for currency” for any user and does not control user private keys. If SOL’s activities were to change such that FinCEN deems them money transmission, SOL will register and comply with MSB/BSA obligations before commencing such activities. (Legal Information Institute)
Airdrops/Rewards. Rewards (including NFTs) are promotional utilities with no cash value and are subject to the Official Giveaway Rules (AMOE; equal odds; verification; taxes). Participation is optional and void where prohibited.
Market Conduct. You agree not to engage in market manipulation or deceptive practices; SOL does not promote trading or price expectations and does not provide financial advice.
(Keep email: solstaff@soundoflife.media)
B) Privacy Policy — Minimal Compliance Additions
Add under “How We Use Information” and “Sharing”:
Sanctions & Compliance Checks. To comply with sanctions laws and protect platform integrity, we may screen user-provided details and public wallet information against sanctions lists and risk indicators and retain related logs for compliance purposes. (OFAC)
Not a VASP/MSB (current posture). We do not provide custodial services or accept/transmit funds for users. If our activities change such that applicable law treats us as a VASP/MSB, we will update this Policy and implement the required identity, Travel-Rule, and recordkeeping controls before such features go live. (FATF)