This page states the regulatory position of Alkaimi.com and of the member financial institutions on whose behalf it is published, and indexes every legal position taken on this site and at pegisai.com. Every other page of this site that refers to the Legal section refers to this page.
This site and its publisher
This site is an institutional communication, published by Pegisai Global Holdings, Inc. on behalf of the member financial institutions of the Alkaimi Ecosystem™ and with their approval, maintained under contract by Pegisai Data Systems, a division of Pegisai USA, Inc., and reviewed by the member financial institutions and their counsel before publication.
This site provides no banking service and carries on no regulated activity. Neither this site nor Pegisai Global Holdings, Inc. is an authorized person under the United Kingdom's Financial Services and Markets Act 2000, a supervised financial institution in any jurisdiction, or an entity that describes itself or holds itself out as authorized, exempt or regulated anywhere. The Alkaimi™ operating license is a contractual authorization from Pegisai Global Holdings, Inc. to a member financial institution; it is not a governmental banking license and confers none.
This site is not a financial promotion, and it contains no invitation and no inducement to deposit, to invest, to borrow, to buy or to enter into any agreement with any person, and it is not directed at any person as a customer. Where a jurisdiction's law treats an institutional communication of this kind as requiring the approval of an authorized person, as section 21 of the Financial Services and Markets Act 2000 does in the United Kingdom, that approval is the member financial institutions' own, given as regulated financial institutions in their own jurisdictions.
The forms on this site and the messages they cause
The member financial institutions of the Alkaimi Ecosystem have contracted Pegisai Data Systems, a division of Pegisai USA, Inc., to conduct gateway and triage services on this site and to collect the information a potential client enters in the two forms on this site, the pre-qualification form and the consumer deployment notice form, for the member financial institutions' use only, to be passed to the member financial institution in the client's region when the members determine it appropriate. Pegisai Data Systems collects that information as the members' contractor and for no purpose of its own.
On the messages this site sends. The CAN-SPAM Act of 2003, 15 U.S.C. 7701 to 7713, defines a commercial electronic mail message by its primary purpose, the advertisement or promotion of a commercial product or service (15 U.S.C. 7702(2)), and excludes from that definition a transactional or relationship message, one whose primary purpose is to facilitate, complete or confirm a transaction the recipient has agreed to enter with the sender (15 U.S.C. 7702(17)); the Federal Trade Commission's rule at 16 CFR 316.3 deems a message transactional or relationship when it consists exclusively of that content. The message that confirms a submission on this site and the message that states the result of screening are transactional or relationship messages under that definition. The consumer deployment notice, sent only to a person who asked to receive it, states the fact the person asked to be told and where the services are offered, and nothing else, and when it is sent carries what the Act requires of any message. On those facts and that law, the messages this site sends comply with the Act.
On the information the forms collect. Regulation (EU) 2016/679, the General Data Protection Regulation, and the United Kingdom General Data Protection Regulation read with the Data Protection Act 2018 reach a controller established outside the European Union and the United Kingdom that offers services to persons there (Article 3(2)). The information those regulations require at collection (Article 13) is given on the Privacy page of this site. The lawful bases are the person's consent (Article 6(1)(a)) and, for the screening of a submission, the legitimate interest in screening submissions and preventing fraud (Article 6(1)(f)). No representative in the European Union or the United Kingdom is required under Article 27, because the exemption in Article 27(2)(a) applies: the processing this site conducts is occasional, includes no special category of data, and is unlikely to result in a risk to the rights and freedoms of natural persons. This site's own processing ends at the form and the reply that answers it; the member financial institution to which a submission is introduced is the controller of what it receives, under its own regulator and its own privacy notice, and every communication after the introduction comes from that member. On those facts and that law, the operation of this site, of Pegisai Data Systems as its operator, and of the two forms complies with those regulations.
The member financial institutions
Every Alkaimi Ecosystem member financial institution is chartered, licensed and supervised under its own regulator in its own jurisdiction. Each member carries, in full and on its own account, the obligations its regulator imposes: prudential supervision, customer due diligence, and the prevention of money laundering and of the financing of terrorism.
Every correspondent relationship on the Alkaimi platform is established and maintained under Recommendation 13 of the Financial Action Task Force and under the correspondent-banking rules of each member financial institution's own jurisdiction, in the United Kingdom under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. No member financial institution may enter or continue a correspondent relationship with a shell bank.
What this site does not do
No deposit, account, loan, investment, custody arrangement or other product or service is offered, sold or applied for on this site. The qualification path described at To qualify and engage is a screening for a possible introduction to one member financial institution, which decides for itself whether to engage; a submission creates no account, no contract and no entitlement. Every product or service a member financial institution provides is provided by that member, in its own name, under its own regulator, on its own terms, and not on or through this site. This site's own processing of a submission ends at the form and the reply that answers it; the member financial institution to which a submission is introduced is the controller of what it receives, under its own regulator.
Value held in custody on the Alkaimi Ecosystem's ledger is not a deposit at any financial institution and is not insured by the Federal Deposit Insurance Corporation, by any other deposit insurance or deposit guarantee scheme, or by any government. Ordinary currency deposits taken by a member financial institution are insured or guaranteed as that member's own deposit insurance regime provides, and by no one else. Nothing on this site states or implies that value held in custody is a deposit or is insured as one.
No central bank, supervisor, government or other authority has reviewed, approved or endorsed Alkaimi, the Alkaimi Ecosystem, any member financial institution's participation in it, or this site. Where this site states that the Digitized Tangible Asset™ meets a published standard, the statement is the ecosystem's own and is made by no authority.
The positions taken on this site
The member financial institutions take the following positions on this site, each on the page named.
- A deposit is a claim on a financial institution, paid in a currency that is a claim on the nation; value held in custody on the Alkaimi Ecosystem's ledger is a claim on no one. Stated at Claims versus value.
- Cryptocurrencies, stablecoins and the narrow bank were examined on the three tests a regulator applies and rejected on the record. Stated at Rejected alternatives.
- The 100% Whole Reserve™ model operates inside the charters the members already hold: under the national bank chartering rule, 12 CFR 5.20; under the Federal Reserve's reserve requirement ratios, at zero percent since 26 March 2020; under the Bank Holding Company Act, 12 U.S.C. 1841; and under the credit-institution definition of the Capital Requirements Regulation, Article 4(1)(1). Stated at The whole reserve model.
- Consumer credit may be funded by a term advance from a member's own central bank, secured on rented Digitized Tangible Assets as collateral that central bank accepts, under each central bank's existing rules on collateral, and such an advance carries no deposit insurance assessment and no liquidity buffer under the Basel III Liquidity Coverage Ratio; whether to fund a loan that way is each member's decision and whether to extend the advance is its central bank's. Stated at The whole reserve model and Future operations.
- Liquidity is created on the Alkaimi Ecosystem's ledger by recognizing value onto it, and needs no central bank; settlement between member financial institutions on the ledger uses no central bank account, so no central bank's discretion over account access, as exercised under the Board's account access guidelines of August 2022 and upheld by the United States Court of Appeals for the Tenth Circuit on 31 October 2025, can reach it. Stated at Current operations.
- A claim from a financial institution that is not a member settles in central bank money before anything is released, and is exchanged for whole value only on the client's instruction at the member's desk. Stated at From claims to whole settlement.
- A member financial institution in retail operation is not a narrow bank, on three points of construction, each answering one of the Board's stated concerns of 2019. Stated at Future operations.
- Every member financial institution complies with every lawful sanction of every nation in which it operates, in the United States under the International Emergency Economic Powers Act, 50 U.S.C. 1701 to 1708. Stated at Sanctions.
- The issue of a nation's currency is the sovereign's right; the Digitized Tangible Asset is not a currency and is never offered as one. Stated at Rejected alternatives and The Digitized Tangible Asset notices.
The positions stated in full at pegisai.com
The legal positions of the Digitized Tangible Asset, of underwriting on the platform and of the platform are published by Pegisai Global Holdings, Inc., each with the test stated from the statute, treaty or standard that sets it and the facts applied to that test: the legal position of the Digitized Tangible Asset (property under the Property (Digital Assets etc) Act 2025, the UNIDROIT Principles and Uniform Commercial Code Article 12; not a security; the rent agreement; not a crypto-asset under MiCA and the Basel standard; the FATF position; not a derivative; not electronic money; not a deposit); the legal position of underwriting on the platform (suretyship, subrogation, the liquidation regime, cross-border authorization, the rent agreement as custody, the commons, the sovereign underwriter, anti-money laundering); and the legal position of the platform. The in-depth pages behind each are linked from those positions.
Notices
The operator of this site, Pegisai Data Systems, a division of Pegisai USA, Inc., the channel for notice to it and the law governing its terms, the law of England and Wales, are stated at Contact and at Terms of use.
Last updated 24 September 2026.