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
| Responsibility | Who Owns It |
|---|
| KYC/AML on the sender | Sender institution + their custodian |
| KYC/AML on the receiver | Receiver institution + their custodian |
| Sanctions screening | Network operator (Musubi) |
| FX rate compliance | You (competitive quoting, documented) |
| Settlement execution | Network 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
| Record | Where | Retention |
|---|
| Every quote you submit (rate, amount, validity, timestamp) | Your database + settlement network | Persistent |
| Quote outcomes (accepted, rejected, expired) | Your database | Persistent |
| Settlement records for won trades | Your database + settlement network | Persistent |
Your market_maker_party_id on settled FXOrders | Sender’s and custodians’ records | Per 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:
| Event | Timestamp | Proof |
|---|
| Quote submitted | submitted_at | Quote contract on your node |
| Quote accepted/rejected | Musubi notification | Quote status update |
| Settlement executed | settled_at | transaction_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.