Issuer Responsibilities

Issuer Responsibilities Using Investhub Technology

Preparation and Setup

1. Get Insurance if required

2. KYC Contract Deployment:

   • Deploy on Testnet.

   • Follow the checklist and test each function as required.

3. System Configuration:

   • Setup Mailgun.

   • Setup CNAME.

   • Ensure all API keys for production are created at different service providers.

   • Activate 2FA for all admins.

   • Properly introduce all employees handling the system.

   • Verify all settings align with the prospectus and your AML policy.

4. Security and Monitoring:

   • Regularly check the logs page for inconsistencies (/admin/log-event).

   • Ensure GMG/Acronis is backing up each entry.

   • Obtain a written statement checklist from GMG/Acronis.

   • If using own API keys for Onfido/Idnow, ensure verification goes into your account and test the API keys.

   • Confirm Mailgun settings are correct and all emails are set up properly (issuer should receive a copy of all emails).

   • Monitor for any suspicious activity:

     • Acronis Monitoring.

     • Tenant logs.

     • Tenant traffic.

     • DDOS attacks via Cloudflare.

   • Verify pricing is correct.

   • Ensure KYC levels align with your AML policy.

5. Integration and Backup:

   • If deploying with Cashlink, check backup wallets (Cashlink API Docs).

   • Check any test transactions on the production system and cancel them.

   • Retest export scenarios:

     • Customer is approved but has not placed a transaction yet.

     • Each KYC change triggers a document update using the Acronis revision feature.

Token Sale and Contract Management

1. Token Exchange Rate:

   • Ensure the token exchange rate is properly added based on the prospectus.

2. Sale Modes:

   • Verify you are in the correct sale mode (private sale or public sale).

3. Transaction Limits:

   • Set and test transaction limits in the backend.

4. Platform and Smart Contracts:

   • Regularly check the platform.

   • Confirm smart contracts are deployed and follow the checklist.

   • Conduct a re-audit of smart contracts.

   • Ensure TVTG registration is done.

   • Update AML policy as needed.

   • Verify bank details for FIAT transfers are correctly added.

   • Confirm the minimum subscription matches the prospectus.

   • Ensure all outsourcing contracts are available.

   • Create and track changes with IKS.

5. Business Continuity and Compliance:

   • Implement Business Continuity Management.

   • Register for FIU.

   • Register for go AML.

   • Register for eID Liechtenstein.

   • Ensure reports for the previous year are submitted in March if subject to SPG.

   • Hire an Investigation Officer to check yearly progress.

6. Prospectus and Communication:

   • If a prospectus is required, ensure the summary is translated and notify it via EU Passporting to other jurisdictions.

   • Update the bank about your progress.

   • Complete the dataroom with prospectus data or link to Google Drive and Dropbox for document versioning:

     • Mark invalid prospectuses with "NOT VALID" on top of the PDF without changing the URL.