This document describes nimimo's structural design intent and is not legal advice. The claims below are properties of the architecture, not opinions about how any specific law applies in any specific jurisdiction. Readers seeking legal advice should consult qualified counsel in their jurisdiction.
Premise
Most regulatory categories that apply to crypto products attach to a specific operational primitive: holding customer funds, transmitting value on behalf of users, matching trades, issuing securities, or operating accounts. The four-axis separation defined in four-axes.md makes those primitives structurally absent from nimimo. This is not a compliance posture; it is an architectural property.
The Access axis carries no authority. The Ownership axis is cryptographic and lives only on the user's device. The Identity axis is purely referential and never signs. The Recovery axis is user-controlled, encrypted, and never touched by the server. There is no point in the system at which nimimo holds, controls, moves, matches, issues, or invests anything.
The rest of this document walks through specific regulatory categories and explains, for each, the structural reason nimimo does not perform the regulated activity. The point is not "we comply"; the point is "we never do the thing in the first place".
Money transmitter (US state level)
A money transmitter accepts funds from one party and transmits them to another. nimimo never accepts funds. No transaction in the system routes through a nimimo-controlled key, account, or address. When a sender pays a nimimo handle, the sender's wallet signs a direct on-chain transaction to a public address derived from the recipient's own ownership material. nimimo is the resolver, not the carrier.
The Ownership axis is cryptographically isolated from both Access and Identity. Even if every server nimimo operates were compromised, no user funds could be moved, because the keys that authorize movement have never existed off the user's device.
Money Services Business: FinCEN (US federal)
FinCEN registration as an MSB attaches to entities that are money transmitters, currency dealers, check cashers, prepaid access providers, or similar. nimimo is none of these. It does not exchange currency, does not issue prepaid value, does not deal in fiat instruments, and does not transmit value as defined above.
The Identity axis is the only thing nimimo "operates", and identity in nimimo is a name that points at user-owned addresses. Operating a naming resolver is not a money services activity.
Crypto-Asset Service Provider: MiCA (EU)
MiCA's CASP definition is built around custody, exchange, transfer, placement, advice, portfolio management, and similar services performed for or on behalf of clients. nimimo performs none of these. The Ownership axis lives on the user's device; nimimo cannot hold crypto-assets on behalf of clients because it has no mechanism to hold them at all.
Specifically, nimimo does not provide:
- Custody and administration of crypto-assets. Keys are device-local and never transmitted.
- Operation of a trading platform. There is no order book, no matching engine, no venue.
- Exchange of crypto-assets for funds or other crypto-assets. No exchange logic exists in the system.
- Execution of orders, placement, or transfer services. nimimo never executes anything; the user's own wallet executes.
- Reception, transmission, or advice. nimimo offers no advice and receives no orders.
Virtual Asset Service Provider: FATF Recommendation 15
The FATF VASP definition mirrors MiCA's CASP for the purposes of international AML standards. The same structural reasoning applies: nimimo does not exchange, transfer, hold, administer, or participate in the issuance of virtual assets on behalf of users. It resolves a human-readable name to a public address that the user themselves controls.
Payment processor / payment institution
Payment processing requires the operator to sit in the value path. nimimo does not. A payment to @lucky-mountain is an ordinary on-chain transfer from the sender's wallet to the recipient's self-custodied address. nimimo never settles, clears, holds float, issues authorization, or guarantees a transaction. The handle is a lookup; settlement is whatever the underlying chain does.
Exchange / trading venue
An exchange matches buyers and sellers and operates an order book. nimimo has no order book, no quotes, no matching engine, no spread, no fees on transfers, and no concept of "trading pairs". Two users cannot exchange one asset for another inside nimimo, because nimimo has no trade primitive.
Securities issuer / broker-dealer
nimimo has no token. There is no claim, no equity, no governance right, no profit share, no investment contract, and no expectation of return tied to anything nimimo does. The product is a free identity layer. There is nothing to issue, nothing to broker, and nothing to deal.
E-money institution
E-money institutions issue electronic value redeemable at par. nimimo does not issue value of any kind. The chains nimimo resolves to (Bitcoin, Ethereum, Solana) issue their native assets independently; nimimo neither issues nor redeems any of them.
KYC / AML obligated entity
KYC and AML obligations attach to entities performing regulated activities (custody, transmission, exchange, etc.). Because nimimo performs none of those, it is not the obligated entity for those activities. nimimo collects an email at sign-up to enable Access; the email is not tied to any value flow because there is no value flow.
This is not a claim that AML rules are irrelevant in crypto generally. They apply to whoever is actually performing the regulated activity, which in nimimo's case is the wallet the sender already uses, not nimimo.
Banking / deposit-taking
Deposit-taking requires accepting funds from the public on a repayable basis. nimimo accepts no funds. There is nothing to repay because nothing was ever taken.
Investment adviser / portfolio manager
Investment advice involves making personalized recommendations about securities or assets. nimimo makes no recommendations and manages no portfolios. The Identity axis does not constitute advice.
What the four axes guarantee
The structural guarantee is simple and follows directly from the axis separation:
1. Access carries no authority. A compromised access method cannot move funds, change identity, or trigger recovery. 2. Ownership is cryptographic and device-local. nimimo has no mechanism to hold, move, or restore it. 3. Identity is referential. It points at ownership but cannot override it. 4. Recovery is user-initiated, locally encrypted, and access-independent. nimimo cannot generate or apply a recovery artifact.
The full state-space analysis in sixteen-states.md shows why every collapsed state, meaning the states in which one axis acquires authority over another, is exactly the configuration that creates regulated activity. nimimo maintains the only state in which all four axes coexist without collapse: (1,1,1,1), the Separated Full State.
On investigation
If a regulator, auditor, or counterparty examines nimimo, the goal is for the examination to be uneventful. Not because nimimo has hidden anything, but because the architecture was designed so there is nothing to find. The keys are not on the server. The funds are not in nimimo's custody. The orders are not matched in nimimo's backend. The token does not exist. The advice is not given. The deposits are not taken.
This is what a clean separation of concerns looks like applied to a domain that has historically refused to separate them. It is the state crypto identity should have been in from the start.