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Security Token Compliance Checklist

A practical compliance checklist for security token offerings — covering Reg D, Reg A+, KYC/AML, accreditation verification, investment limits, and audit-trail requirements.

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Key takeaways

  • Map your offering to a specific securities exemption before drafting documents.
  • Run KYC/AML, accreditation, and sanctions screening in a single, logged workflow.
  • Encode transfer restrictions in smart contracts and operational policy alike.
  • Treat the audit trail as a product surface, not a back-office artifact.

Show me the regulation

The exact citation, snapshot fields, retention period, and OMINEX events that satisfy each rule covered in this guide.

Each panel below is the full structured detail for a regulation referenced in this guide — drawn from the OMINEX regulation registry. Expand any one to see the citation, what it requires in plain language, what fields the examiner reads from the snapshot, the retention period, and the specific OMINEX event types that produce the evidence.

Why this checklist exists

Launching a security token offering requires careful attention to legal and regulatory compliance. This checklist covers the key steps to ensure your offering meets all applicable requirements across pre-offering structuring, investor verification, transfer enforcement, and ongoing reporting.

This checklist is for informational purposes only and does not constitute legal advice. Consult qualified securities counsel to ensure compliance with all applicable laws and regulations.

Checklist sections

Pre-offering legal and structural requirements

Establish the legal foundation before tokens or interests are issued.

Documents

  • Determine applicable securities laws and exemptions (Reg D, Reg A+, etc.)
  • Structure the offering to comply with the chosen exemption
  • Draft offering documents (PPM, offering circular, etc.)
  • Establish transfer restrictions and compliance procedures
  • Set up escrow or custody for investor funds
  • Obtain legal opinions on securities-law compliance

KYC/AML and accreditation verification

Verify investor eligibility and BSA/AML status before accepting funds.

Documents

  • Implement KYC/AML procedures for investor onboarding
  • Verify investor identity and accreditation status
  • Comply with CIP/CDD requirements
  • Screen against OFAC and sanctions lists
  • Monitor transactions for suspicious activity
  • File SARs as needed

Investment limits and transfer restrictions

Enforce regulatory limits and transfer constraints in operations and at the smart-contract layer.

Documents

  • Enforce investment limits based on investor accreditation
  • Implement transfer restrictions to prevent unregistered sales
  • Use smart contracts to automate transfer compliance
  • Maintain records of all token transfers
  • Provide disclosures on transfer restrictions to investors

Ongoing reporting and audit trail

Keep the operating record clean for examiners and counterparties.

Documents

  • Maintain accurate records of token issuance and transfers
  • Comply with ongoing reporting requirements (e.g., Form D)
  • Establish an audit trail for compliance verification
  • Implement data security and privacy measures
  • Prepare for potential regulatory audits

Related guides

Resource

BSA/AML and KYC compliance guide

Full BSA/FinCEN/AML requirements for security token platforms

Read guide

Resource

Regulation D 506(c) guide

Accredited investor verification and reasonable-steps requirements

Read guide

From rule to operating fit

This rule is one part of the broader digital asset compliance picture your team still has to prove in front of buyers, auditors, and regulators.

The mandate map shows where verification and recordkeeping requirements already apply across digital assets, tokenized capital markets, and related infrastructure. The business case explains how OMINEX helps teams reduce manual proof gathering, answer diligence faster, and move deals forward with less operational drag.

Request a demoRead the business case

Originally published October 2024 · Last reviewed December 2024