CIRO Custody Framework
Three-entity separation, Tier-2 target. The custody entity is structured from day one to meet the framework published by CIRO in February 2026, HoldCo / OpCo / CustodyCo with independent governance.
4orm Finance is structured against the CIRO Digital Asset Custody Framework from inception, independently governed, separately incorporated, and aligned with the federal and provincial regulators that supervise Canadian capital markets. The corporate structure is operationalized as HoldCo / OpCo / CustodyCo from day one.
Six concurrent regulatory tracks. Three are active today; three are on a pathway with defined milestones; one architecture is fully verified by the Bank of Canada via Project Samara.
Three-entity separation, Tier-2 target. The custody entity is structured from day one to meet the framework published by CIRO in February 2026, HoldCo / OpCo / CustodyCo with independent governance.
Sandbox application Q3 2026. Coordinated regulatory engagement across federal banking, securities, and AML/ATF supervisors. Concurrent pre-engagement under way today.
Financial Innovation Act and Bill 13. Calgary HQ. Canada's first regulatory sandbox for digital asset infrastructure. Engagement with the Alberta Securities Commission and Treasury Board.
Reference architecture validated by Bank of Canada with RBC, TD, EDC, March 2026. The model 4orm builds against. Full regulatory sign-off from OSC, AMF, and CIRO on the pilot.
National regulatory initiative launched Q2 2026. The market-structure standard 4orm is engaging with as it is written. Participation in working groups and consultations.
Embedded sanctions, PEP and watchlist screening. Large-transaction reporting at the C$10,000 threshold. Source-of-funds attestation on institutional onboarding.
The CIRO Digital Asset Custody Framework requires three independently governed entities. 4orm Finance is incorporated to that pattern from inception, not retrofit after the fact.
The published milestones and target dates that anchor 4orm Finance's path from pre-seed to production.
The framework establishing the three-entity separation model that 4orm is incorporated against from inception.
DoneThe architecture reference. $100M tokenized bond trial with RBC, TD, EDC. Full regulatory sign-off from OSC, AMF, CIRO.
DoneCapital close and formal application to the Alberta Financial Innovation Act sandbox. Calgary HQ confirmed.
ActiveCoordinated regulatory engagement application. Pre-meetings with federal supervisors and provincial regulators in operating jurisdictions.
NextThe three-entity structure operationalized, independent boards seated, audit and risk committees stood up.
NextFirst end-to-end pilot transactions with named institutional counterparties under sandbox supervision.
NextCIRO marketplace and dealer authorization. CustodyCo Tier-2 authorization. Production rollout window opens.
TargetCompliance is embedded in the platform, not bolted on after the fact. Every transaction passes pre-trade checks before it reaches the order book.
Institutional onboarding produces a reusable credential. Beneficial owners, jurisdiction, accreditation status. KYC compounds across the network instead of repeating per relationship.
Sanctions, politically exposed persons, and watchlist screening on every counterparty and every transaction. Explainable risk scoring with audit trail. FINTRAC large-transaction reporting at $10,000.
Accreditation (NI 45-106), jurisdiction, and counterparty whitelist checks happen before the order hits the book. Non-compliant orders are blocked at the protocol level.