Vertical — Conduct & Financial-Crime Spine

    The parallel L5 spine.

    The shipped six obligations attest that the token issues, settles, custodies and unwinds correctly. They do not attest that the issuer behaves lawfully toward consumers and the system. Obligations 07–09 close that gap — institution-owned, attested equally for bank and non-bank issuers.

    Cohort B — bank-issued tokenised deposits · TCH H1 2027 · applicable to Cohort A and regulated stablecoins

    Legislative status · verified 26 July 2026

    H.R.3633 (Digital Asset Market Clarity Act) passed the House 294–134 on 17 July 2025 and sits on the Senate Legislative Calendar (General Orders, Calendar No. 423) after the Banking Committee reported a substitute on 1 June 2026. Updated merged Banking/Agriculture text was released on 22 July 2026. Senate leadership expects the pre-recess floor window to be missed, and the draft still requires 60 votes. Cabier plans on the operative regimes — state trust charters and money-transmitter licensing, OCC, FRB and FDIC prudential guidance, and EU MiCA Titles III and IV for cross-border cohorts — binding through at least 2027. Legislation is the label on the control, not the control.

    Source: congress.gov, H.R.3633 (119th Congress) — legislative actions and Senate Legislative Calendar, General Orders No. 423.

    What governs tokenised dollars now

    Two clusters, one platform

    Each obligation carries a cluster attribute — INTEGRITY or CONDUCT. The platform renders the parallel spine today and can flip to a unified 1–9 presentation without a rebuild. The brand of the shipped six is preserved.

    Integrity spine — 01–06

    • 01Issuance integrity
    • 02Custody & segregation
    • 03Settlement assurance
    • 04Disclosure & lineage
    • 05Recovery & wind-down
    • 06Cross-border conduct

    Conduct spine — 07–09 (new)

    • 07Financial-Crime Controls
    • 08Fraud & Illicit-Flow Assurance
    • 09Yield / Product Classification & Consumer Fairness

    The three conduct obligations

    Substantial-Similarity engine

    A shared determination layer expresses each conduct obligation's outcome as functional equivalence to a configurable named-regime baseline. The framing is durable across either CLARITY outcome: same risk, same rule, attested equally — irrespective of whether the issuer is a chartered bank or a digital-asset firm.

    Anchor sets are configurable per jurisdiction and sequenced by regulatory adoption rather than geography. As each named-regime baseline matures — through final rules, licensing regimes, or supervisory guidance — its anchor pack is activated and bound into the determination layer.

    Live and in-flight anchor packs span the major regulated markets — North America (SEC, FINRA, OCC, Federal Reserve, FinCEN, CFTC, NYDFS; OSFI, Bank of Canada, CSA, FINTRAC, Payments Canada), the European Union (ESMA, EBA, ECB, MiCA NCAs, AMLA), the United Kingdom (FCA, PRA, Bank of England, HM Treasury), the Middle East (VARA, ADGM FSRA, DFSA, CBUAE, SAMA, CMA, QFCRA, CBB), Asia-Pacific (MAS, HKMA, SFC, JFSA, ASIC), and adoption-stage packs across the Caribbean, Africa and Latin America. Coverage advances as each regime publishes the rule set the anchor binds to.

    Open the global anchor-pack coverage matrix

    Bindings

    3LOD evidence vault

    All three conduct obligations run on the existing evidence engine and shared vault. No parallel store.

    AI Assurance OS

    Model registry, SR 11-7 workflow and bias audit bind the customer-risk, transaction-monitoring and fraud-detection models.

    Cabier Protocol standards registry

    Yield-guardrail / substantial-similarity standard conformance resolves against a versioned Protocol standard.

    L3 runtime evidence linkage

    Real-time intervention controls link to smart-contract freeze, clawback and pause primitives.

    Phasing

    1. Phase C1 — current

      Obligation 09 (yield classification + guardrail-standard conformance) and the Obligation 07 core AML substantial-similarity engine.

      Rationale — 09 is the single provision blocking the Senate floor vote and carries the highest political and commercial value during the markup-to-floor window.

    2. Phase C2

      Obligation 07 full programme · Obligation 08 fraud and illicit-flow · all AI Assurance OS bindings.

    3. Phase C3

      Regulator surface · multi-jurisdiction anchor packs · publication of the Cabier Protocol yield / substantial-similarity standard via the Foundation.

    Access

    Private-review access only — consistent with the existing module pattern.

    No self-serve sign-up, no public pricing. The shape of the spine is public; the operating disclosure is released under signed terms.

    Request a private review