REGULATORY POSITIONING

Regulatory Positioning Note

GlemO should be positioned as infrastructure before it is positioned as a transaction venue.

This note clarifies the intended regulatory posture for the pre-seed diligence stage. It is not legal advice and should be converted into counsel-approved operating policies before launch.

Planned structure: BVI project base and SAFE with a 20% discount. Cayman Islands token structure and token warrant. UAE is the initial market for buyers and sellers. Detailed legal structuring is planned with counsel after pre-seed funding. No signed pilot or institutional contracts as of 23 September 2026. Forecasts and prototype records are illustrative.

Project, Token and Customer Market

BVI is the planned base for the GlemO project and SAFE. The Cayman Islands are the planned jurisdiction for the GO token structure and associated token warrant. The UAE is the first customer market, with both buyers and sellers. These are distinct roles, not alternative domiciles.

Pre-Seed Terms

SAFE (BVI), 20% discount + token warrant (Cayman Islands). The proposed round is US$2M. This describes the intended financing structure, not an executed instrument, legal opinion or statement that entities are already incorporated.

Post-Funding Legal Work

The founder plans to engage qualified counsel after VC investment to finalize the corporate, token and cross-border operating structure. Counsel and investors will settle the entity and documentation needed to receive the investment. Detailed operating permissions, provider responsibilities, data rights and token arrangements must be resolved before the activities that require them. Paid pilots, completed production systems and a completed operating legal framework are funded milestones, not represented as already achieved.

Scope of Review

Counsel will assess BVI project activities, the Cayman Islands token and warrant, and promotion, onboarding, distribution and transactions involving UAE customers. Customer location can create obligations even where the project entity is offshore. The exact instrument, activity and customer segment determine the applicable rules. The plan does not assert a specific licence, exemption, regulator or favourable tax treatment.

RWA Product and GO Token

The platform distributes third-party-issued RWA tokens and does not propose issuing those assets. The planned GO ecosystem token is separate, with its intended structure in the Cayman Islands. No GO launch date, token proceeds or appreciation supports the operating base case. Internal admission controls do not substitute for legal permissions.

Official References

Qualified counsel should use the current rules and the actual activity scope. BVI FSC virtual-asset framework; CIMA virtual-asset resources; VARA; DFSA; ADGM/FSRA. References identify review areas and do not constitute a legal conclusion for GlemO.

English governs this update. 23 September 2026. v2.10.1.