Compliance responsibility
Who owns each control. The bank keeps its own obligations.
| Control | The bank | The domain operator | JIL |
|---|---|---|---|
| Customer due diligence (KYC and KYB) | Performs it for its own customers under its law. | Sets the identity levels each act requires. | The attester signs the stored result into an on-chain identity record. |
| Sanctions | Screens under its own program. | Pins the sanctions lists for the domain. | ATCE denies on the attested sanctions flag inside consensus. The screen against live lists runs off chain in the attester, and its result is signed into the identity record. |
| Transaction monitoring | Runs its own monitoring. | Chooses the screening provider for the domain. | Adapters for blockchain-analytics screening providers exist. JIL does not publish a provider relationship. |
| Travel rule | Meets its own obligation. | Sets the threshold and required fields per zone. | A per-zone travel rule check exists in the settlement service. |
Custody
| Item | Answer |
|---|---|
| Keys | Validator and default service keys are held by JIL; issuer mint keys by the issuer. See control and custody. |
| Escrow | A corridor hop holds the gross and the fee in escrow on the ledger until the ruling. A denied hop releases the escrow and settles no fee. |
| Reserves | JIL does not hold a domain's reserves. |
| Key recovery | Recovery follows a structured ceremony. A briefing walks through it. |
Settlement and FX
| Item | Answer |
|---|---|
| Settlement | Gross, leg by leg. There is no netting. |
| FX rate | The cross-rate is checked against bands the domain sets. The rate source is set by the domain. |
| Intraday liquidity | No liquidity model is published. |
| Failure handling | A denied act settles nothing. Multi-hop unwind is part of the InterOp design (Designed). |
| Prudential treatment | JIL has not assessed Basel treatment of exposures. The bank's own prudential treatment applies. |
Integration
| Interface | Status |
|---|---|
| ISO 20022 message gateway (pain, pacs, camt message sets) | In the codebase. Rail connections are Designed. |
| FedNow, SWIFT, ACH, SEPA, RTP connectors | Designed. No rail is connected. |
| Ethereum bridge | Deposit Live. Withdrawal Designed, awaiting a key ceremony. |
| Hosting | Hosted on validators JIL operates. A customer-hosted cell runbook exists (Designed). |
Vendor risk
| Item | Answer |
|---|---|
| Assurance | Johanson Group LLP is examining SOC 2 Type 1, SOC 2 Type 2, and HIPAA. No report has been issued. HITRUST: a separate firm is being engaged. |
| Penetration test | No independent penetration test report is published. |
| Concentration | One operator and one hosting provider for all ten validators. |
| Business continuity and disaster recovery | Not published. Provided in briefings. |
| Vulnerability reports | Contact in security.txt. |
All-in fee
Setup $100,000 one time, an annual floor of $250,000, credited against JIL's share of collected transport fees, and a toll of at least 5 basis points per hop. A three-hop corridor route of $400,000,000 pays $600,000. The worked example is on fees.
Request a bank briefing
A principal and an engineer attend. An NDA can be in place before documents are shared.