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As a market maker on Musubi, you are a liquidity provider — not a payment originator or beneficiary. This shapes your compliance obligations and what data you handle.

Your Regulatory Position

ResponsibilityWho Owns It
KYC/AML on the senderSender institution + their custodian
KYC/AML on the receiverReceiver institution + their custodian
Sanctions screeningNetwork operator (Musubi)
FX rate complianceYou (competitive quoting, documented)
Settlement executionNetwork operator (atomic DvP)
You do not handle, process, or store any personally identifiable information (PII) about senders or receivers. The anonymized RFQ model means this data is never transmitted to your systems.

What’s Recorded About You

RecordWhereRetention
Every quote you submit (rate, amount, validity, timestamp)Your database + settlement networkPersistent
Quote outcomes (accepted, rejected, expired)Your databasePersistent
Settlement records for won tradesYour database + settlement networkPersistent
Your market_maker_party_id on settled FXOrdersSender’s and custodians’ recordsPer their retention policy
Your quote history and settlement records form a complete audit trail of your market-making activity.

Privacy Guarantees

The anonymized RFQ model protects both you and the institutions: What institutions don’t know about you (until your quote wins):
  • Your identity is not revealed to institutions during the quoting phase
  • Only the winning MM’s market_maker_party_id appears on the settled order
What you don’t know about institutions (ever):
  • Sender identity, receiver identity, custodian identities
  • Jurisdiction codes, compliance references
  • Intent signatures, contract identifiers
This bidirectional anonymity during quoting ensures that pricing is based on market conditions, not relationship. It supports the institution’s best execution obligations — they can demonstrate that market makers competed on price alone.

Best Execution Support

Your participation supports the institution’s best execution documentation:
  • Multiple MMs receive the same anonymized RFQ simultaneously
  • Each MM submits quotes independently
  • The institution selects the best quote with a documented audit trail
  • All quotes (winning and losing) are timestamped and recorded
This competitive RFQ process gives the institution’s compliance team evidence that they achieved best execution — and your participation as a competitive bidder is part of that record.

Audit Trail

Every action you take is timestamped on the settlement network:
EventTimestampProof
Quote submittedsubmitted_atQuote contract on your node
Quote accepted/rejectedMusubi notificationQuote status update
Settlement executedsettled_attransaction_hash covering all 4 legs
For won trades, the transaction_hash is the definitive settlement proof — a single cryptographic hash covering the complete atomic DvP. Store this for your own regulatory reporting and reconciliation.