The compliance pack, in public.
Security tokens governed by Swiss law, issued by Flo Global Markets Ltd. (BVI) under a base prospectus approved by the Liechtenstein Financial Market Authority (FMA). Flo Global Markets Ltd. is the sole investor in Flo Capital SPC (Cayman), a bankruptcy-remote Segregated Portfolio Company with an independent director that holds the underlying securities at SEC-registered broker-dealers, one-to-one with tokens outstanding. Forward this page to your compliance team. Most teams sign off after one read.
The one-paragraph version
If your compliance team only reads one page, this is it. The structure, the instrument, and the insolvency-remote design that protects holders.
Token governing law
Switzerland
Swiss-law structured notes
Prospectus
FMA-approved
Liechtenstein · EEA passportable
Issuer
Flo Global Markets Ltd.
BVI · onboards investor · sole investor in SPC
Custody
Flo Capital SPC
Cayman · bankruptcy-remote · independent director
Backing
1:1 at SEC-registered BDs
IB + Alpaca · segregated brokerage accounts
4
Independent audits
Sherlock · Halborn · Cantina · Cyfrin
Daily 00:00 UTC
Merkle-root cadence
Daily Accountable attestation via API
$0.01
Reconciliation tolerance
Zero on unit count
Up to $250K
Bug bounty (critical)
Coordinated disclosure
3 chains
Live deployment
Base · Arbitrum · Ethereum
Flo issues blockchain-based structured notes, on-chain certificates that track publicly traded equities one-to-one. The notes are governed by Swiss law and issued by Flo Global Markets Ltd. (BVI) under a base prospectus filed in Liechtenstein and approved by the Liechtenstein Financial Market Authority (FMA), which is passportable across the EEA under the EU Prospectus Regulation. Flo Global Markets Ltd. is the sole investor in Flo Capital SPC (Cayman), a bankruptcy-remote Segregated Portfolio Company with a trust-like shareholding arrangement and an independent director. Each note is backed 1:1 by the underlying security held by Flo Capital SPC in a segregated institutional brokerage account at a SEC-registered broker-dealer. Both entities sit structurally separate from Flo's operating company. Distribution is B2B to partners, fintechs, exchanges, neobanks, institutional clients, and startups, each of whom completes a one-time business KYC at the Flo Global Markets Ltd. layer and handles jurisdictional compliance and user-level KYC for their own end users.
Go deeper
Three dedicated pages for the evidence behind the claims on this one.
Every line of code, reviewed
Audit history, $250K bug bounty, SOC 2, SSO/MFA, incident response, BCP/DR, ForDefi MPC, vendor risk.
Open security →
Reports & ArtifactsIndependent verification, every day
Daily attestations from Accountable, served via public API. BVI and Cayman legal opinions, trust deed, SOC 2, and DPA. Indexed by artifact ID.
Open reports →
Proof of ReservesOn-chain. Permissionless. Verifiable.
Live reserve status. Self-verify with Merkle proofs. Cross-reference against broker-dealer positions. The math, not the marketing.
Verify reserves →
Entity & Regulatory Structure
BVI issuer · Cayman SPC custodianThree legal layers. Flo Global Markets Ltd. (BVI) issues the structured notes and onboards the investor. It is the sole investor in Flo Capital SPC (Cayman), a bankruptcy-remote Segregated Portfolio Company with an independent director that holds the underlying securities. Flo Finance, Inc. is the operating company, structurally separate from both, providing services under arm's-length agreements.
Token holder
│ Holds blockchain-based structured notes (transferable
│ securities under MiFID II), tradable on-chain.
│
│ Direct contractual entitlement against ↓
│
Flo Global Markets Ltd. (British Virgin Islands)
│ Issuer entity. Issues structured notes under the
│ FMA-approved Liechtenstein Base Prospectus (Swiss-law
│ tokens). Onboards the investor; runs counterparty AML,
│ KYC, and sanctions screening. Sole investor in ↓
│
Flo Capital SPC (Cayman Islands)
│ Bankruptcy-remote Segregated Portfolio Company.
│ Independent director on the board. Trust-like
│ shareholding arrangement. Legal owner of the
│ underlying securities. Beneficial owner of ↓
│
Institutional custody accounts at SEC-registered broker-dealers
· Interactive Brokers LLC (primary)
· Alpaca Securities LLC (secondary, for business continuity)
· SIPC-covered. Customer property held in segregated brokerage
· accounts in the name of Flo Capital SPC.
Flo Finance, Inc. (operating company, Delaware)
· Employees, IP, vendor contracts, technology platform.
· Provides services to Flo Global Markets Ltd. and Flo Capital
· SPC under arm's-length agreements.
· Has no ownership interest in either entity.Flo Global Markets Ltd. (BVI)
Issuer entity. Issues blockchain-based structured notes under the FMA-approved Liechtenstein Base Prospectus (Swiss-law tokens). Onboards the investor and runs counterparty AML, KYC, and sanctions screening. Sole investor in Flo Capital SPC.
Flo Capital SPC (Cayman)
Bankruptcy-remote Segregated Portfolio Company. Independent director on the board. Trust-like shareholding arrangement. Legal owner of the underlying securities, held in segregated brokerage accounts at Interactive Brokers and Alpaca Securities.
Flo Finance, Inc. (operating co)
Delaware corporation. Builds and operates the Flo platform under services agreements with the issuer and the SPC. Structurally separate from both, any operating-company outcome is contained to Flo Finance and leaves the issuer, SPC, and note holders unaffected.
Structured Notes
Blockchain-based certificatesEach Flo token is a blockchain-based structured note issued by Flo Global Markets Ltd. (BVI). The note tracks the economic performance of the underlying equity one-to-one and is fully backed by that same security held by Flo Capital SPC (Cayman) in an institutional custody account at a SEC-registered broker-dealer.
Instrument
Structured noteA blockchain-based structured note, an on-chain certificate issued by Flo Global Markets Ltd. (BVI), representing direct entitlement to the economic performance of one specified underlying security.
Backing
1:1 backedEach note is backed 1:1 by the underlying security held by Flo Capital SPC in a dedicated institutional custody account at a SEC-registered broker-dealer, in the name of the SPC for the benefit of note holders.
Ledger integrity
Audited · On-chainIndependently audited smart contracts record issuance, transfers, and redemptions. The blockchain ledger itself is the authoritative record of ownership; secondary transfers are permissionless on-chain.
Holder rights
Total-returnNote holders have direct contractual entitlement to the total-return performance of the underlying. Cash dividends, coupons, and similar distributions are reinvested into more of the underlying by Flo Capital SPC; token supply stays the same and NAV per token rises. On-chain transfer effects transfer of the note.
Bankruptcy remoteness
SPC · Segregated accountsFlo Capital SPC is structured with a trust-like shareholding arrangement and an independent director on the board. Underlying assets sit in segregated brokerage accounts at the BD in the SPC's name, keeping them separate from both Flo the operating company and the BD's own estate.
One-to-one entitlement
One-to-oneEach note tracks one underlying security, one-to-one. Dividends and corporate actions accrue to note holders directly. This is a straightforward entitlement structure, a clean, single-name certificate rather than a managed or pooled product.
The BVI / Cayman SPC split is the standard institutional pattern for tokenized capital-markets products. The BVI issuer onboards investors and issues the notes; the Cayman SPC, with trust-like shareholding plus an independent director, holds assets bankruptcy-remote from both Flo Finance and the broker-dealer estates.
Custody & Broker-Dealer Chain
Dual-broker redundancyThe underlying security is held in a segregated brokerage account at the broker-dealer. Flo maintains two independent broker relationships, Interactive Brokers as primary and Alpaca as secondary, so the issuance chain remains operational if either relationship becomes unavailable. One broker is always sufficient; the second is there for business continuity.
Interactive Brokers LLC
PrimarySIPC Member
$500K protection
FINRA Member
Full compliance
Publicly Traded
IBKR (Nasdaq)
Client Accounts
2.6M+
Alpaca Securities LLC
SecondarySIPC Member
$500K protection
FINRA Member
Full compliance
Regulator
SEC-registered BD
Fractional Support
Native
Chain of legal title
Note holder → Flo Global Markets Ltd. (BVI)
Direct contractual entitlement to the economic performance of the underlying security, against the BVI issuer entity. Flo Global Markets Ltd. issues the notes under the FMA-approved Liechtenstein Base Prospectus.
Flo Global Markets Ltd. → Flo Capital SPC (Cayman) → underlying at the BD
Flo Global Markets Ltd. is the sole investor in Flo Capital SPC, a bankruptcy-remote Segregated Portfolio Company with an independent director. Flo Capital SPC holds the underlying securities in segregated brokerage accounts at the BD, in the SPC's name, separated from the BD's own property for the benefit of note holders.
On-chain Custody
ForDefi MPCMPC Custody Solution
Threshold signing with hardware-secured shards. No single private key ever exists in full form.
SOC 2 · ISO 27001
ForDefi is SOC 2 Type II and ISO 27001 certified. Independent attestation of custody controls.
Policy engine
Transaction policies with allowlists, co-signing thresholds, and time delays on high-value operations.
Attestation
Independent · DailyDaily independent attestation of backing by Accountable, served via public API. On-chain proof of reserves verifiable against signed custodian records. The closest thing to continuous proof of reserves this asset class permits.
Reserve Attestation
MonthlyIndependent verification that on-chain Flo token supply matches the custodied underlying at Interactive Brokers and Alpaca. Reports total tokens per series, total held per CUSIP, and any delta with explanation.
Proof of Reserves
ContinuousMerkle-tree proof published on-chain. Signed attestations from the custodian are cryptographically verifiable against the on-chain supply.
Smart Contract Audits
On-chain + half-yearly retestFour independent audits of all smart contract logic and state transitions, Sherlock, Halborn, Cantina, and Cyfrin. Audits run on every on-chain change and are supplemented by a scheduled half-yearly retest on the full contract surface.
SOC 2 Type II
In progressEnterprise-grade security, availability, and confidentiality controls independently assessed. Year-1 observation window under way; bridge letter available on completion.
Smart Contract Security
Quadruple Audit
Independent audits from Sherlock, Halborn, Cantina, and Cyfrin.
Bug Bounty
Up to $250K for critical vulnerabilities, operated directly by Flo.
Time-Locked Governance
All governance changes subject to a 72-hour delay before execution.
Emergency Pause
Any member of the independent security council can trigger an emergency pause. Unpause requires a higher threshold, 4/7 multisig, so recovery is deliberate and well-reviewed.
Sanctions Enforcement
OFAC-sanctioned addresses are hard-denied at the token contract level.
Security & Operations
SOC 2 in progress · ISO 27001 roadmapProduction access, change management, secrets, monitoring, incident response, business continuity. The operational controls behind the attestations.
Production access
SSO, hardware MFA (WebAuthn only), scoped IAM roles. No shared credentials. No long-lived keys in environments.
Change management
All production changes via PR with two-reviewer approval. CI/CD with signed releases; artifact provenance recorded.
Secrets management
AWS Secrets Manager and Vault. No secrets in code or env files. Rotation enforced on schedule and on departure.
Logging and monitoring
Centralised SIEM with 24/7 on-call rotation. Security alerting pipelines independent from application alerting.
Incident response
Documented runbook, tested quarterly. Material-incident disclosure to partners within 24 hours; full post-mortem within 5 business days.
Business continuity
Multi-region active-passive. RTO 4 hours, RPO 5 minutes for issuance and redemption. Failover tested quarterly.
Penetration testing
Independent third-party pen tests on application and infrastructure scheduled before public launch, then on an annual cadence and after any material architectural change. Executive summaries shareable under NDA.
Vendor risk
Vendor diligence run on any counterparty with access to production data or systems. Annual re-review; SOC 2 / ISO certs required for critical vendors.
Bug bounty
Program operated directly by Flo, covering issuance contracts, the mint/redeem API, and the web surface. Up to $250K for critical.
Jurisdictions, KYC & AML
BVI-level AMLKYC on end users is performed by the partner, fintech, exchange, neobank, institutional client, or startup, to the standard of the user's jurisdiction. Flo Global Markets Ltd. (BVI), as the issuer entity that onboards the investor, runs entity-level AML (business KYC), counterparty diligence, and sanctions screening at the BVI layer.
End-user KYC
Performed by the partner (fintech, exchange, neobank, institutional client, or startup) to the standard of the user's jurisdiction. Flo receives no end-user PII.
Entity-level AML
Counterparty diligence on BDs, partners, and banking relationships run at the BVI issuer layer (Flo Global Markets Ltd.), with AML officer appointments and onboarding KYC for every investor.
Sanctions screening
OFAC, EU, UK, and UN lists. Onboarding plus continuous daily re-screening.
Wallet screening
Chainalysis / address risk screening on every mint and redemption flow.
Contract-level denylist
OFAC-sanctioned addresses hard-blocked at the token contract level. Not just off-chain policy.
Compliance Architecture
The responsibility split between Flo and the partner. Knowing which obligations you inherit, and which you don't, is usually the first thing your compliance team wants clarified.
What Flo Does
- FBVI-issued structured notes (Flo Global Markets Ltd.)
- FCayman SPC custody chain (Flo Capital SPC) into Interactive Brokers and Alpaca
- FOn-chain audit trail and immutable settlement records
- FProof of reserves and daily attestations
- FCollateral enforcement via independent security agent
- FEntity-level AML, KYC, and sanctions screening at the BVI issuer layer
- FContract-level OFAC sanctions enforcement
- FAPI rate limits and operational security
What You Control
- YKYC and AML of your end users
- YGeographic restrictions and allowlisting
- YUser onboarding experience
- YRegulatory licensing in your jurisdiction
- YTax reporting and statements to users
- YUser-facing disclosures and suitability
- YTravel-rule reporting at the user layer
- YUser-relationship-level data controllership
Frequently Asked
The questions compliance teams ask most often on first calls.
What if Flo the company fails?+
Is this a stablecoin or an E-money token under MiCA?+
What happens on a corporate action: dividend, split, M&A?+
Is Flo regulated?+
Can US persons hold the tokens?+
What's the recovery process if a wallet's keys are lost?+
Is there a separate transfer agent?+
Compliance-ready from the first call.
Forward this page to your compliance team. Request the full document pack, legal opinion, SOC 2 status, audit reports, attestations, under NDA. One business day turnaround.