Disclosures
Compliance
We would rather be plain about where we stand than overstate it. This page sets out our regulatory standing and how we handle money and identity.
Last updated 2026-06-19
Regulatory standing
SHLD is not a bank and is not, at this time, a licensed money transmitter in its own right. We are pursuing the licensing and registrations appropriate to our activity; that work is in progress. We will update this page as our standing changes, and we will not claim a status we do not hold.
Custody through a licensed partner
Fiat funds in a hold are custodied by a licensed partner, not by SHLD directly. Customer funds are held in segregated accounts, separate from SHLD operating funds, and are released only on the conditions set in the signed agreement. This structure lets us offer protected holds while custody sits with a regulated institution.
Stablecoin and on-chain holds settle non-custodially where the rail allows; the underlying assets are not commingled with operating funds.
KYC and AML
Funded holds are subject to identity verification (KYC) and anti-money-laundering (AML) checks, including sanctions and watchlist screening and, where warranted, source-of-funds review. We may decline or unwind a hold that we cannot clear under these checks or that our custody partner cannot support.
Sanctions and restricted use
SHLD does not serve sanctioned persons or jurisdictions and does not support unlawful transactions. Coverage in a given country is confirmed before signing, and the desk will tell you plainly if we cannot serve a particular deal.
Questions
Compliance and licensing questions can be sent to desk@shld.us. This page is a disclosure, not legal advice.
