Regulatory Compliance
Effective Date: 08.05.2024
Version RCV-1
Licensing Structure
AMBO (Asset-Backed Mining Blockchain Offering) is a marketplace platform created in Monaco by Joris Puslys. As a private individual, Joris Puslys retains ownership of the AMBO platform’s intellectual property and rents its operational rights to Ambo Holdings LTD, a company registered in Ireland. The technical and financial operations of the platform are conducted by the operator, Ambo Holdings LTD, under a rental rights agreement.
No Financial Transactions Handled by the AMBO Platform
AMBO does not hold, manage, or move client funds. Upon winning bids on assets, buyers are assisted in creating a legal entity to hold the purchased asset. All payments for assets are made directly to the buyer’s collective entity account, which subsequently remits payment to the seller to finalize the asset purchase. By ensuring that no financial transactions occur on the platform itself, AMBO operates independently of financial licensing requirements.
Licensing and Regulatory Compliance
As of 01.07.2024, AMBO operates in accordance with the regulatory frameworks of Monaco and Ireland, relying on the following principles:
1. No Financial Services Provided:
AMBO does not engage in regulated financial activities such as:
- Portfolio management.
- Custody or movement of client funds.
- Direct financial transactions.
The platform operates solely as a marketplace and administrative support service, which allows it to remain outside the scope of financial services licensing requirements.
2. Exemptions for Advisory Services
Advisory services (if applicable) provided through AMBO are offered under legally permitted exemptions for licensed professionals:
- Joris Puslys’ Credentials:
Joris Puslys holds a Professional Bachelor’s Degree in Economics with a specialization in Banking from Lithuania (Diploma No. SLK Nr. 001254)
- Exemptions for Financial Licensing:
Regulatory frameworks in both Monaco and Ireland provide exemptions for individuals who hold recognized degrees in finance, allowing them to provide certain financial advisory services without additional licensing requirements.
- MiFID II Exemptions:
As per the Markets in Financial Instruments Directive II (Directive 2014/65/EU), Article 3(1) allows individuals or entities to provide ancillary advisory services without requiring full financial licensing.
- Key Reference: MiFID II (2014) official text can be found here: EUR-Lex MiFID II Directive.
3. Irish Regulatory Framework
Ambo Holdings LTD, the technical operator of the platform, adheres to Irish regulations. The Central Bank of Ireland outlines that technical service providers not involved in direct financial services or fund management are exempt from financial licensing.
- Key Reference: See the Central Bank of Ireland’s financial services guidelines: Central Bank of Ireland.
4. Monaco Regulatory Framework
The Commission de Contrôle des Activités Financières (CCAF) in Monaco exempts entities from licensing if they do not handle client funds or engage in financial transactions directly.
- Key Reference: CCAF’s official guidelines can be reviewed here: Monaco CCAF Overview.
Revenue Model
AMBO generates revenue through multiple streams:
1. Asset-Holding Company Creation: Assisting buyers in setting up legal entities to hold purchased assets.
2. Annual Management Fees: Covering ongoing administrative and operational support for these entities.
3. AMBO Utility Token: AMBO’s profitability is further supported by the anticipated increase in the value of its proprietary AMBO Utility Token.
4. Educational Content: AMBO also offers premium educational content covering topics such as asset management, blockchain, and financial strategies. This provides value to users and serves as an additional revenue source.
Regulatory Considerations for Educational Content
Educational content provided by AMBO is:
- For informational purposes only.
- It does not include personalized financial advice or recommendations tailored to individuals.
AMBO Utility Token
The AMBO Utility Token is designed as a core component of the AMBO ecosystem, providing utility to users, incentivizing platform participation, and driving long-term engagement alongside traditional fiat currencies. A central part of the AMBO platform is the progressive enhancement of the token’s intrinsic value by linking it to tangible, real-world assets.
This is achieved through a reinvestment model, where profits generated from the token’s value growth are utilized to acquire real-world assets. Over time, these assets will gradually back the token, creating a direct relationship between the token’s value and a diversified AMBO portfolio of tangible holdings. This strategy not only reinforces the token’s stability but also positions it as an evolving financial instrument, bridging the gap between utility tokens and asset-backed securities.
Key Features of the Token Strategy:
Using the token’s value appreciation to fund the acquisition of assets managed within the AMBO ecosystem.
Gradually aligning the token’s valuation with the performance of the underlying asset portfolio.
Ensuring compliance with security regulations in relevant jurisdictions as the token transitions toward a hybrid financial model.
By integrating this reinvestment strategy, AMBO aims to create a robust and forward-thinking ecosystem where the AMBO Token evolves into a trusted and stable asset-backed instrument while maintaining its utility within the platform.
Legal References
1. Markets in Financial Instruments Directive II (MiFID II), Directive 2014/65/EU: Provides exemptions for certain advisory activities under Article 3(1). Read more here.
2. Monaco Commission de Contrôle des Activités Financières (CCAF): Licensing exemptions for non-financial services platforms. Read more here.
3. Irish Central Bank Regulations: Exemptions for technical service providers not involved in fund management. Read more here.
For inquiries or further information on regulatory compliance, please contact: contact@amboinvest.com
