Regulatory Status
FinCEN registration, partner licensing, and jurisdiction compliance information for iCloser
Regulatory Status
Our Regulatory Commitment
iCloser Ltd. operates in compliance with applicable financial regulations and maintains active registrations with federal regulatory authorities. We implement robust compliance programs to protect our users and the integrity of the financial system.
Regulatory Registrations
FinCEN Money Services Business
Active- Dealer in Foreign Exchange
- Money Transmitter
- Prepaid Access Seller
FinCEN MSB registration is not a recommendation, certification of legitimacy, or endorsement by any government agency.
STATUTORY MSB DISCLAIMER:
Registration as a Money Services Business (MSB) with FinCEN (U.S. Department of the Treasury) and FINTRAC (Government of Canada) is a statutory reporting requirement under applicable anti-money laundering regulations. Registration does NOT indicate, imply, or constitute any endorsement, licensing, business verification, or guarantee of financial solvency and consumer safety by FinCEN, the U.S. Department of the Treasury, FINTRAC, or any governmental agency.
SEC Exempt Reporting Adviser
Active⚠ IMPORTANT NOTICE & SCOPE OF REGULATION:
I CLOSER LTD. reports to the U.S. Securities and Exchange Commission (SEC) as an Exempt Reporting Adviser (ERA) pursuant to Rule 203(m)-1 under the Investment Advisers Act of 1940 (CRD Number: 338976; SEC File Number: 802-134747).
An Exempt Reporting Adviser is exempt from SEC registration requirements and is permitted solely to advise qualifying private funds. Reporting to or filing Form ADV with the SEC does not constitute registration, licensing, nor does it imply any level of skill, endorsement, verification, or approval by the SEC or any U.S. federal regulatory authority.
The iCloser consumer mobile application, non-custodial digital wallet, USD virtual account access, Visa card services, and KernelHub software are strictly technology products and do NOT provide investment advice. These products and services are outside the scope of this ERA filing and are NOT subject to or protected by the Investment Advisers Act of 1940.
FINTRAC Money Services Business
Registered- Foreign Exchange Dealing
- Remitting or Transmitting Funds
- Dealing in Virtual Currency
- Payment Service Provider
Registration with FINTRAC does not constitute endorsement, approval, or licensing by FINTRAC or the Government of Canada.
STATUTORY MSB DISCLAIMER:
Registration as a Money Services Business (MSB) with FinCEN (U.S. Department of the Treasury) and FINTRAC (Government of Canada) is a statutory reporting requirement under applicable anti-money laundering regulations. Registration does NOT indicate, imply, or constitute any endorsement, licensing, business verification, or guarantee of financial solvency and consumer safety by FinCEN, the U.S. Department of the Treasury, FINTRAC, or any governmental agency.
MSB Compliance Obligations
As a registered Money Services Business, iCloser complies with:
- Bank Secrecy Act (BSA) requirements
- Anti-Money Laundering (AML) program implementation
- Know Your Customer (KYC) procedures
- Suspicious Activity Reporting (SAR)
- Currency Transaction Reporting (CTR)
- OFAC sanctions screening and compliance
- Record keeping and reporting requirements
ERA Compliance Obligations
As an Exempt Reporting Adviser, iCloser complies with:
- Investment Advisers Act of 1940 (Exempt Reporting)
- Fiduciary duty to clients
- Form ADV disclosure requirements
- Compliance program and policies
- Books and records requirements
- Code of ethics and personal trading rules
Colorado ERA Requirements
In addition to federal SEC ERA filing, we comply with Colorado Division of Securities requirements:
- ERA Filing: Annual ERA filing maintained with SEC and notice filing with Colorado
- Compliance Program: Maintained in accordance with Colorado Rule 51-4.12(IA)
- Net Worth: Minimum liquid net worth of $35,000 maintained for custody activities
- Annual Fees: Current with all Colorado Division of Securities registration fees
Data Protection Compliance
Colorado Privacy Act (CPA)
As a Colorado-based company, iCloser complies with the Colorado Privacy Act, providing Colorado residents with rights to:
- Access personal data
- Correct inaccuracies
- Delete personal data
- Opt out of targeted advertising and profiling
- Data portability
GDPR Compliance
iCloser complies with the European Union's General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA).
Important Disclaimers
BANKING SERVICES & FDIC PASS-THROUGH INSURANCE:
iCloser Ltd. is a financial technology platform, NOT a bank or insured depository institution.
USD virtual accounts, payment routing, and Visa-branded cards are issued and facilitated strictly through authorized, licensed banking partners and regulated payment institutions. Eligible fiat balances deposited in partner bank accounts may qualify for pass-through FDIC insurance, subject to statutory limits, terms, and individual bank conditions.
FDIC pass-through insurance applies exclusively to lawful fiat currency deposits held at the partner bank. FDIC insurance does NOT apply to, protect, or cover any cryptocurrencies, stablecoins, digital assets, or balances maintained within non-custodial wallets.
Registration Does Not Imply Endorsement: Registration with FinCEN, the SEC, or FINTRAC does not constitute an endorsement of iCloser by these agencies, nor does it imply a certain level of skill or training. Registration with FINTRAC does not constitute endorsement, approval, or licensing by FINTRAC or the Government of Canada.
Black-Gold Visa Services: Visa® is a registered trademark of Visa Inc. All Visa-branded services are provided by authorized partners, not directly by iCloser Ltd.
Software & AI Execution Boundary
SOFTWARE & AI EXECUTION BOUNDARY (KERNELHUB):
KernelHub is an AI workflow, permission management, and execution software platform provided solely as a technology tool. KernelHub is not an investment adviser, financial planner, broker-dealer, money transmitter, or asset custodian.
Any regulatory registrations or filings maintained by iCloser Ltd. apply exclusively to their specific statutory legal scopes and do not extend to, regulate, or imply government oversight, vetting, or approval of the KernelHub software itself.
Territorial Exclusions & Sanctions Compliance
TERRITORIAL EXCLUSIONS & SANCTIONS COMPLIANCE:
iCloser strictly enforces automated geofencing and comprehensive compliance screening. Services are strictly prohibited and unavailable to:
- Residents of mainland China;
- Individuals, companies, or organizations located in or organized under the laws of jurisdictions subject to comprehensive OFAC sanctions (including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine);
- Any individual or entity designated on the U.S. Department of the Treasury's Specially Designated Nationals (SDN) list or other international sanctions screening databases.
Contact Regulatory Affairs
For regulatory or compliance inquiries:
Compliance Contact: privacy@icloser.xyz
Address: iCloser Ltd., 1580 N Logan St, Suite 660 #30327, Denver, CO 80203, USA
Governing Law: State of Colorado, United States