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Legal posture / Architecture

Non-custodial by architecture, not by policy.

A custodian is a service that takes possession or control of customer funds and promises to return them later. OpenSettle does neither. Funds settle wallet-to-wallet on the blockchain; OpenSettle observes the chain, records the confirmation, and emits a signed webhook. This is the architecture of the system, not a configurable policy — there is nothing to flip in a settings panel that would make OpenSettle custodial.

The flow

How a payment moves through the system.

  1. 1Merchant creates a payment intent via the OpenSettle API or dashboard. The intent is a row in the OpenSettle database; it carries the amount, token, chain, and the merchant’s own destination wallet address. The intent is not a fund movement.
  2. 2Customer authorises the transfer in their own wallet (MetaMask, Phantom, Coinbase Wallet, WalletConnect-compatible mobile wallet, etc.). The wallet signs the transaction with the customer’s private key and broadcasts it directly to the chain’s public network of nodes. OpenSettle does not sign, co-sign, or relay this transaction.
  3. 3The chain settles the transaction according to its own consensus. Funds move from the customer’s wallet to the merchant’s wallet in the same block. OpenSettle is not a counterparty.
  4. 4OpenSettle observes the chain via public RPC endpoints, matches the on-chain transfer to the open payment intent by amount and destination, recomputes the confirmation count, and emits a signed webhook to the merchant’s configured endpoint. Everything OpenSettle does in this step is read-only.
Posture

What OpenSettle is — and what it is not.

OpenSettle is
  • Software-as-a-service that helps a business create stablecoin payment links and observe on-chain settlement to that business's own wallet.
  • A set of typed SDKs (Node, Python, Go, Rust), a hosted checkout page, and a developer API.
  • A read-only on-chain observer that records confirmations and emits signed webhooks.
OpenSettle is not
  • A money transmitter
  • A money-services business (MSB)
  • A bank or trust company
  • A custodian or qualified custodian
  • A fiduciary
  • A broker-dealer
  • An exchange
  • An investment adviser
  • A commodities intermediary

This list mirrors clause 10 of the Terms of Service. Use of OpenSettle does not constitute use of a regulated payment service.

Verifiable claims

Don’t take our word. Verify.

OpenSettle does not custody, control, or have signing authority over any user's digital assets.

The server has no merchant or customer private keys. Settlement transactions are signed by the payer's wallet (MetaMask, Phantom, Coinbase Wallet, WalletConnect, etc.) and broadcast directly from the payer's browser. The funds path is payer wallet → on-chain → merchant wallet. OpenSettle is not in that path.

OpenSettle does not move funds.

There is no smart contract or escrow with OpenSettle-controlled upgrade keys in the settlement path. There is no FBO account, omnibus account, or pooled reserve. There is no off-ramp or on-ramp operated by OpenSettle.

OpenSettle cannot freeze, reverse, or reroute a payment.

The wallet that signed the transaction is the only entity that can authorise the transfer. Once broadcast, the network — not OpenSettle — confirms or rejects it. Refunds are merchant-to-customer transactions; OpenSettle facilitates the request but never executes it.

OpenSettle does not perform exchange, conversion, or off-ramp services.

The token a customer sends is the token a merchant receives. No fiat is touched. No conversion is performed. Sanctions screening of on-chain addresses is performed in-house against the OFAC SDN list as a refusal-to-process gate — not as a settlement service.

The summary your procurement officer will paste.

OpenSettle is software-as-a-service. We never take possession or control of funds. All payments settle peer-to-peer on the blockchain. We are not a money transmitter, money-services business, bank, trust company, custodian, fiduciary, broker-dealer, exchange, investment adviser, or commodities intermediary. Use of OpenSettle does not constitute use of a regulated payment service. Merchants are responsible for their own tax, AML, sanctions, and licensing obligations under the Terms of Service.

Counsel review of OpenSettle’s compliance allocation is in progress. The architectural facts on this page do not change with that review; the legal characterisation of those facts may be refined. Material changes will be announced here.