A Swiss operation, deliberately so.

The platform is operated by Einzelfirma Salamandre David Nataf, a sole proprietorship under Swiss law, with its seat in the canton of Zug. The beneficial owner is David Nataf. The same natural person is the sole signatory and the editorial authority for the site and the certificates issued.

Switzerland's Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology ("DLT Act"), in force since 1 August 2021 (with the trading-venue chapter from 1 August 2021 and the insolvency-segregation provisions since 1 February 2021), creates the dedicated legal concept of ledger-based uncertificated rights (Art. 973d Code of Obligations).

The Carat certificate, in its Phase 2 form, is recorded on a distributed ledger (Polygon) as a non-transferable (soulbound) ERC-721 token. It is issued for the purpose of identification and provenance tracking of a specific physical stone. It confers no right to a payment, a cash flow, a profit share, or a recurring distribution. It is not a security under Art. 2 lit. b FinSA.

FINMA's Guidelines for enquiries regarding the regulatory framework for initial coin offerings (ICOs) of 16 February 2018, expanded in the Guidance 02/2019 and the supplement of 11 September 2019, distinguishes three token categories:

• Payment tokens — intended as a means of payment. Not applicable to Carat.
• Utility tokens — intended to provide access digitally to an application or service. Closest classification for the Carat token, in the limited sense that it provides on-chain verification of a physical identification record.
• Asset tokens — represent assets such as a debt or equity claim, or a participation in real assets. Not applicable. The Carat token is technically non-transferable and represents no financial claim.

We deliberately use a soulbound architecture (the ERC-721 _update() hook reverts all transfers) so that the token cannot be traded on a secondary market, which removes a major axis along which asset-token characteristics could otherwise be argued.

Swiss Federal Act on Combating Money Laundering and Terrorist Financing (AMLA / GwG, RS 955.0) imposes due-diligence obligations on financial intermediaries and on dealers of precious metals and stones above defined thresholds.

Salamandre · Carat does not trade in gems, does not hold client gems on its own balance sheet, does not act as custodian, does not buy or sell on behalf of clients, and does not handle client funds. The activity is the issuance of identification reports for stones owned by third parties. As such, the operator is not currently a financial intermediary within the meaning of AMLA Art. 2 para. 3, nor a precious-stones dealer in the cash-transaction sense of Art. 8a.

If the activity scope ever expands into custody, brokerage, or cash-handled transactions above the statutory thresholds, the operator commits to either affiliating with a FINMA-recognized Self-Regulatory Organization (SRO) or seeking direct supervision, prior to any such activity.

Personal data submitted via the Telegram bot @GemCaratBot (Telegram user id, contact context) is processed under the revised Swiss Federal Act on Data Protection (FADP, in force since 1 September 2023) and, where applicable to data subjects in the EU/EEA, under the GDPR. See our privacy notice.

Crucially: no personally identifying information is published on-chain. The blockchain record contains a gem_id, a SHA-256 of the certificate payload, and an optional IPFS pointer to a redacted PDF. The submitter remains identifiable only inside our internal registry — and can request deletion of identifying records at any time.

• We do not offer investment advice, portfolio management, or financial recommendations.
• We do not solicit, take, or hold client funds.
• We do not trade gemstones on a principal basis or as a broker.
• We do not act as custodian for client stones.
• We do not issue any asset-backed token, security token, or fractional ownership instrument.
• We do not appraise market value or guarantee future appreciation.
• We do not make claims about authenticity for trading or insurance purposes — only identification within the limits of the issued report.

The operator maintains pre-onboarding relationships with FINMA-licensed Swiss institutions active in the digital-asset space (notably the original pre-boarding cohort at Sygnum Bank since October 2019). This is for operational banking and custody optionality for the operator's own treasury, not for the issuance of any product on behalf of third parties.

We welcome enquiries from regulators, professional counterparties and counsel at david@nataf.com.