Operating legally is the architecture, not the addendum.
VPAY Genesis is built so regulators, central banks, and custodians can verify rather than trust. Every attestation, every reserve movement, every admin action is observable on Polygon Mainnet — and the compliance posture is documented, staffed, and aligned to FATF recommendations.
Four interlocking control surfaces — one observable compliance posture.
An on-chain enforcement layer for the WGC mandate.
The World Gold Council's "Gold as a Service" framework calls for institutional-grade gold infrastructure built around verifiable provenance. VPAY Genesis is the on-chain enforcement layer for that mandate — applied first to Ghana's gold export economy.
Provenance
Every kilo's origin is recorded at point of weigh-in by a sealed GSU. Smuggled gold has no attestation. Licensed gold does.
Custody
Launch custody is licensed Ghanaian vaulting, with third-party custodian and insurance engagement in progress. The attestation layer is jurisdiction-agnostic by design — institutional mandates can specify accredited vaulting in any jurisdiction. The token represents the claim, not a synthetic — and it cannot mint without the underlying.
Auditability
Every attestation is on Polygon Mainnet. Public addresses. Source-verified on Polygonscan. Independent block explorers serve as the audit trail. (An independent third-party security audit is queued.)
Accountability
Admin authority sits behind a Gnosis Safe multisig (2-of-3). Founder allocation is in irrevocable vesting. The deployer EOA holds zero admin rights.
Anti-money-laundering programme in place.
VPAY's AML programme is documented, staffed, and aligned with FATF recommendations on virtual asset service providers and physical commodity attestation systems. The programme covers risk assessment, customer due diligence, transaction monitoring, sanctions screening, and suspicious activity reporting.
Documented and reviewed.
Per-customer, per-node-operator, per-jurisdiction, per-product risk scoring. Reviewed quarterly by the CCO against the live regulatory landscape.
Observable on-chain.
Every mint, burn, lend, and admin event is on Polygon Mainnet. Monitoring rules can be applied by us, by integrators, or by regulators independently.
Address-level enforcement.
Sanctions and PEP screening at the bridge. Restricted addresses cannot receive mint output. Updates are admin-controlled via Safe.
Know Your Customer and Know Your Business at every point of friction.
KYC is enforced at three points: at miner registration (entering the supply side, our node operators), at GSU operator licensing (the verification layer), and at institutional onboarding (the demand side, our customers). Individual wallet users are referred to as customers; supply-side participants including refineries, aggregators, and exporters are referred to as node operators.
Node operator KYC (source)
Licensed supply-side node operators — refineries, mining companies, licensed collection cooperatives — verified against PMMC, GoldBod, and Minerals Commission registers. Tied to the SovereignNode operator that fingerprints their lots.
GSU operator KYC
Higher-tier verification for the institutions running attestation hardware. Bonded via GuardianBond. Subject to slashing on misconduct.
Institutional customer KYC
Custodians, exchanges, treasuries onboard via the Institutional API with role-scoped credentials and beneficial-ownership documentation.
Continuous
Periodic reviews, sanction-list refreshes, and customer / node-operator re-verification on material change. Tracked by the CCO.
Ghana's regulatory on-ramp.
Article 114 of the Minerals and Mining Act 2006 (Act 703) and its enabling instruments give Ghanaian gold-sector entities a clear pathway to operate within both domestic and international standards. VPAY's posture is built directly on this — supply-chain formalisation across all licensed source tiers, retention of gold revenues at home, and integrity of export documentation.
The Bank of Ghana's 2025 Financial Statements, published 1 May 2026, document the transition from the Domestic Gold Purchase Programme (DGPP) to GANRAP — the Ghana Accelerated National Reserve Accumulation Programme (passed Parliament February 2025, operational April 2026). GoldBod's CEO publicly disclosed that approximately 104 tonnes of gold were acquired domestically through the DGPP/GoldBod channel in 2025. BoG's stated objective for the GANRAP transition is to "moderate the cost of reserve accumulation". Three of the four cost components named — offtake discount, agent and assay fees, purity/refining loss — are reduced by hardware-attested on-chain verification at the point of weigh-in. The fit is direct.
The verification gap is not solved by paperwork — it is solved by an attestation primitive that paperwork cannot forge. Article 114's mandate names what to do; VPAY ships the mechanism that does it. GANRAP names the cost; VPAY moderates it.
Origin verification at weigh-in.
The system is designed so every PMMC weigh-in can become an on-chain attestation — customs would verify the export against the chain in seconds.
Reserve attestation in continuous time.
BoG's reserve position becomes verifiable in real time, on-chain, by every counterparty — without exposing inventory.
Centralisation with verification at scale.
GoldBod's mandate is centralisation; VPAY's primitive is the verification layer that makes centralisation operationally enforceable.
Every role grant, pause, and parameter change requires a co-signed Safe transaction — verifiable on Polygon by any auditor.
A dedicated Chief Compliance Officer.
VPAY Genesis is operated by EcoVent Africa Limited with a dedicated Chief Compliance Officer in post. The CCO owns the AML programme, KYC framework, regulatory engagement, and internal audit posture.
Ibilola Macaulay
Owns the regulatory posture, AML/KYC framework, and the relationship with Ghanaian and regional authorities. Runs the diligence-grade compliance file. Independent reporting line to the board for material compliance findings. The CCO operates with full independence on all regulatory, AML, KYC, and sanctions matters.
Ano Yoofi Agyei
Holds operational and architectural responsibility. Custodian of the technical posture. Counterpart to the CCO for cross-domain risk and material decisions.
Briefings, filings, and engagement papers.
Selected materials available for partners, regulators, and counterparties. Confidential briefings provided on request under NDA.
GoldBod Briefing
Two-page positioning brief on how VPAY plugs into the GoldBod operational stack.
Source on GitHub
Foundry test suite, deploy scripts, audit broadcasts, and red-team reports — all open.
SOV on Polygonscan
Token contract, source-verified, with full event log and admin role state.
Confidential file
AML programme, KYC procedures, and risk-assessment documents available under NDA on request.
Compliance you can verify.
Not compliance you have to trust.
The AML programme is documented and staffed. The KYC framework is live at three onboarding tiers. Article 114 alignment is the regulatory thesis. Every contract action sits behind the Safe and on the chain. The diligence file is open for any counterparty.