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Digital Assets Risk, Made Clear

You are the one they turn to.

See the legal and regulatory issues before they become business problems.

CLARITY is structured digital-asset regulatory issue intelligence for the lawyers, compliance leaders, advisers, and executives who do not specialize in crypto but are responsible for the decisions it touches. The free CLARITY Assessment shows you which regulatory domains your situation touches.

Start Your Free CLARITY Assessment
Four questions. Three minutes. No account needed.
The CLARITY Briefing · Live
Oct 30
Friday
Your Year-End Readiness Roadmap: A Real Scenario, Mapped Live
Thursdays · Noon ET, one hour
The CLARITY Briefing
As covered in ForbesDr. Evans on digital-asset law and policy
Attorney-designedTwelve-domain sweepMemo-grade PDF
“It is not a generic checklist. It earns the trust of subject-matter experts.”
Devon J. Euring, CAPFC  ·  Founder & CRO, Asterisk Defense  ·  Beta Founder
Specimen Output Snippet/ priority: high
Domain
Securities
Issue
Whether the wrapped instrument retains the classification of its underlying reference asset across the bridge contract.
Questions
  1. Does the wrapper grant economic rights identical to the underlying?
  2. Does redemption mechanics shift the analysis under Howey?
  3. Are secondary venues making a market in the wrapped form?
Mapped by domain. Organized by priority.
Scroll · Method & reviews

Built by Dr. Tonya M. Evans, Esq.·Congressional testimony, House Financial Services Subcommittee on Digital Assets (2023)·External Expert Reviewer, Central Bank of Nigeria VASP Regulations (2025)·Independent Board Member, Digital Currency Group·Author, Digital Money Demystified·Read full bio

What four questions can show you.

Your Clarity Index: how many of twelve regulatory domains your situation touches, which ones, and the question worth asking in each. It won’t tell you which regulators are in play or which issue ranks first. That takes your facts, and that’s what the Issue-Mapping Memorandum is for.

Free resource · One email, two documents

The Clarity Issue-Mapping Starter Kit.

Everything you need to see what CLARITY produces, written for the people accountable for digital asset risk.

  • The Digital Assets Regulatory Issue-Spotting Checklist
    Sections mapping the regulatory perimeter, with diligence questions per domain.
  • A complete Sample Memorandum
    The full output of the engine, so you see exactly what you get before you spend a dollar.
Sent instantly by email

The Starter Kit is sent to your email. Follow-up emails are only sent if you opt in above.

03 · Reviews
“I built a scenario specifically designed to stress-test the tool across its hardest dimensions. It didn't fold. The output held up under expert scrutiny.”
Devon J. Euring, CAPFC  ·  Founder and Chief Risk Officer, Asterisk Defense  ·  Beta Founder
“The future of business requires more than innovation. It requires clarity.”
Adilah Holivay  ·  CEO, Association for Women in Cryptocurrency
“I was impressed with the comprehensive nature of the responses. This would be fantastic for the first stages of analysis of a new idea.”
Rashan Colbert  ·  CEO, Lucrum Verus Capital
Read the founder reviews
01 · The Path

Your Path to Clarity.

  1. 01
    Assessment
    Identify potential regulatory touchpoints. Four questions, three minutes, no account required.
  2. 02
    Findings
    Understand your Clarity Index and the questions requiring examination.
  3. 03
    Activation
    Put CLARITY to work on your own matter.
02 · Method

Guided intake.
Formal output.
No chat.

  1. 01
    Describe the scenario
    Plain language. No tech vocabulary required.
  2. 02
    We map what matters
    A domain-by-domain map of your exposures, organized by priority.
  3. 03
    Take the next step
    A polished memorandum for client, team, or file.
One sweep across twelve regulatory domains
SecuritiesAML / KYC / SanctionsCustody & SafekeepingTaxConsumer ProtectionMarket IntegrityData & PrivacyCybersecurityCommodities & DerivativesBanking & PaymentsCorporate & GovernanceIP & Smart Contracts
Four ways to use CLARITY · by use case

Choose how to use CLARITY.

01Available today
Clarity SOLO™

One scenario, one memorandum. Put CLARITY to work on a single live matter.

02Available today
Clarity EXPLORE™

Ongoing issue mapping for recurring professional matters. 2026 rate, locked.

03Membership open
Clarity CORE™

Institutional regulatory intelligence and strategic reporting, with Monthly Clarity-to-Strategy Intelligence and Strategic Report-Outs.

04By inquiry
Clarity ENCORE™

Customized enterprise positioning, deployed inside your organization.

Compare every tier side by side
See plans and pricing →·2026 founding rates end December 31.
“I built a scenario specifically designed to stress-test the tool across its hardest dimensions. It didn’t fold. The output held up under expert scrutiny.”
Devon J. Euring, CAPFC  ·  Founder and Chief Risk Officer, Asterisk Defense  ·  Beta Founder
Guided intake
Plain-language prompts walk you through the details that matter, asset, transaction, parties, touchpoints, so nothing relevant slips by.
Every domain mapped
Securities, AML, custody, tax, market integrity, data, governance: CLARITY maps your scenario across every relevant regulatory domain and organizes the findings by priority, so you know exactly where to focus next.
A memo you can hand off
A polished memorandum, domain, headline, diligence questions, why each one matters, and priority, ready to share with your team, your client, or your file.
Made for working professionals
Counsel, compliance and risk leaders, executives, and policymakers. Substance over jargon. Built so the tool meets you where you are.
The actual output

What an Issue-Mapping Memorandum Looks Like.

Explore a sample CLARITY memorandum generated from a fictional digital-asset scenario and subsequently reviewed for legal accuracy. See how the report identifies factual gaps, organizes regulatory questions, and prepares professionals for further analysis.

Issue-Mapping Memorandum · Sample · Fictional scenario

Offshore token issuer with U.S. users after the stalled market structure bill

October 8, 2026
Revised October 13, 2026
File W3RC-000E3F40
8 issues mapped
A Real CLARITY Output. Fictional Scenario. Human-Vetted Sample.
Plain-language brief

Your business operates through three connected entities: a foundation in the Cayman Islands that holds the project's token reserves, a development company in the United States that keeps building the technology, and an operating company in the British Virgin Islands that runs the trading platform. U.S. customers have been able to use the platform, which creates a significant risk that U.S. regulators will claim authority over relevant activities and demand that you register, qualify for an exemption, or shut down U.S. access.

Intake consistency notes
  • Entity status is marked Active, which may not capture the paused staking rewards program and the paused U.S. market entry initiative. Confirm whether those paused activities create continuing obligations.
  • Parties include the Foundation / SPV and the Custodian / Wallet provider but do not identify the U.S. development company, even though the narrative describes it as a key actor continuing roadmap work. Confirm its legal status and role.
  • Jurisdictional touchpoints include the European Union, but the narrative describes no EU-specific activity or user targeting. Confirm whether EU users access the platform and whether any entity is established or solicits in the EU.
  • MiCA's transitional period has ended, so any existing EU-facing activity should be assessed under the currently applicable authorization and conduct framework.
Eight prioritized regulatory issues
01

Securities

High priority

Investment contract status under the March 2026 SEC framework.

Regulatory touchpointsSEC (US)
Diligence questions
  • Is the token subject to an investment contract today under the March 2026 SEC interpretation, given ongoing U.S. development-company efforts?
  • Has the token separated from the issuer's promises of essential managerial efforts, or do roadmap work and treasury-funded activities travel with it in secondary trading?
  • If staking resumes, does it fit the SEC's protocol-staking treatment, or do enhanced or provider-determined rewards require a separate investment-contract analysis?
Why it matters

Whether transactions in the token remain subject to an investment contract determines whether U.S. securities registration or an exemption is required for continued U.S. access. The August 18, 2026 Regulation Crypto Assets proposal would add a conditional safe harbor, but it is not current law and comments are due October 20, 2026.

02

Securities

High priority

Exchange and intermediary registration given U.S. user participation.

Regulatory touchpointsSEC (US)
Diligence questions
  • Does the BVI operating company's venue constitute a national securities exchange, alternative trading system, or broker-dealer under U.S. law?
  • Could failure to register or claim an exemption expose the foundation, the U.S. development company, or affiliates to secondary liability?
  • If the token has separated from the investment contract, does the venue remain subject to SEC antifraud jurisdiction?
Why it matters

Operating a platform that facilitates domestic transactions in securities or investment contracts can trigger Exchange Act registration. The analysis turns on whether the relevant transactions are domestic under Morrison, not merely whether offshore activity has U.S. effects.

03

AML / KYC / Sanctions

High priority

Money services business and money transmission obligations across the structure.

Regulatory touchpointsFinCEN (US)FATF (International)
Diligence questions
  • Does the BVI operating company engage in money transmission under FinCEN's 2019 CVC guidance, requiring MSB registration?
  • Does the custodian or wallet provider require separate FinCEN registration and an AML program under 31 CFR 1022.210?
  • Where transactions cross borders, does the platform transmit originator and beneficiary information consistent with the FATF Travel Rule?
Why it matters

Operating a covered CVC exchange without required FinCEN registration can bring civil penalties under 31 U.S.C. 5330, and separate criminal exposure under 18 U.S.C. 1960. An offshore structure does not exempt activity where the U.S. statutory nexus is satisfied.

04

AML / KYC / Sanctions

High priority

Customer identification, sanctions screening, and AML program sufficiency.

Regulatory touchpointsFinCEN (US)OFAC (US)BVI FSC (BVI)
Diligence questions
  • Does the venue perform customer identification consistent with BVI law and the reach of U.S. sanctions authorities where U.S. persons are involved?
  • Does the platform screen users and transactions against OFAC lists and keep records sufficient to demonstrate compliance?
  • Does the AML program designate a compliance officer, provide training, and include independent review?
Why it matters

An inadequate AML program or sanctions screening can bring enforcement by FinCEN, OFAC, or the BVI Financial Services Commission, with penalties scaled to conduct and volume.

05

Market Integrity

Medium

Market manipulation and trading practices given a multi-jurisdiction user base.

Regulatory touchpointsSEC (US)CFTC (US)BVI FSC (BVI)ESMA (EU)
Diligence questions
  • Does the venue maintain surveillance adequate to detect manipulation, wash trading, or other prohibited practices across applicable jurisdictions?
  • Where the foundation holds significant reserves, does potential influence over supply create insider-trading or market-manipulation exposure?
  • Do order-matching or affiliate trading activities create conflicts of interest or front-running exposure requiring disclosure?
Why it matters

Manipulation and fraud prohibitions can apply even where the asset is not a security in every jurisdiction. With MiCA's transitional period ended, the current EU market-conduct framework is directly relevant to any EU-facing operations.

06

Tax

High priority

Staking rewards characterization and withholding obligations.

Regulatory touchpointsIRS (US)
Diligence questions
  • If staking resumes, how would the IRS characterize rewards, and does Revenue Ruling 2023-14 determine when they are gross income?
  • For U.S. recipients, do information-reporting (IRC 6041) and backup-withholding (IRC 3406) obligations apply?
  • Where rewards are paid to non-U.S. persons, do Chapter 3 withholding provisions apply, and is W-8 documentation or treaty relief needed?
Why it matters

Revenue Ruling 2023-14 provides that staking rewards are generally gross income when the taxpayer obtains dominion and control. Failure to meet reporting or withholding obligations can bring penalties to the payor and separate exposure for recipients.

07

Custody / Safekeeping

Medium

Custody obligations for the foundation treasury and user-held assets.

Regulatory touchpointsCIMA (Cayman Islands)BVI FSC (BVI)SEC (US)
Diligence questions
  • Does the foundation act as a custodian under Cayman law, and does it meet the Virtual Asset (Service Providers) Act safeguarding obligations?
  • Do user-asset arrangements meet BVI custody and segregation requirements under SIBA 2010 and the VASP Act 2022?
  • Does the arrangement satisfy SEC custody rules if U.S. securities characterization applies, and does it qualify for an exemption?
Why it matters

Custody failures can bring loss of user assets, sanctions, and civil liability. Multi-jurisdiction access may require satisfying the Cayman, BVI, U.S., and EU custody frameworks simultaneously, or demonstrating that particular frameworks do not apply.

08

Corporate / Governance

Medium

Affiliate-transaction scrutiny and common control across the three entities.

Regulatory touchpointsSEC (US)CIMA (Cayman Islands)BVI FSC (BVI)
Diligence questions
  • Do the foundation, the U.S. development company, and the BVI operating company constitute affiliates under common control, and how does that affect characterization?
  • Does the foundation's governance and its relationship with the development company create fiduciary duties or disclosure obligations to token holders?
  • Do foundation-funded roadmap payments constitute self-dealing or related-party transactions requiring board approval or independent review?
Why it matters

Where a treasury, a developer, and a venue are under common control, regulators and courts may examine the substance of the integrated arrangement rather than treating each entity in isolation.

Domains not surfaced
  • Consumer Protection. No retail-facing marketing claims, product disclosures, or complaint mechanisms were described that would generate standalone issues beyond Securities and Market Integrity.
  • Data & Privacy. The scenario does not describe personal-data processing in enough detail to generate privacy-specific questions, though obligations arise if the platform collects KYC data.
  • Cybersecurity. No facts on controls, incident response, or breaches were provided; critical operationally, but not a discrete regulatory issue without more facts.
  • Commodities / Derivatives. The token is described as a native protocol token, with no indication it is a futures contract, swap, or derivative triggering standalone CFTC obligations beyond antifraud authority.
  • Banking & Payments. No fiat on-ramps, off-ramps, or banking relationships were described beyond the MSB issues already covered under AML / KYC / Sanctions.
  • IP / Smart Contract. No facts on smart-contract code, open-source licensing, IP ownership, or audit history were provided to generate standalone issues.
Selected regulatory and legal sources
  • Application of the Federal Securities Laws to Certain Crypto Assets, Release Nos. 33-11412; 34-105020 (March 17, 2026)
  • Regulation Crypto Assets, Release Nos. 33-11434; 34-106150 (proposed Aug. 18, 2026; comments due Oct. 20, 2026)
  • SEC v. W.J. Howey Co., 328 U.S. 293 (1946)
  • Morrison v. National Australia Bank Ltd., 561 U.S. 247 (2010)
  • SEC v. Telegram Group Inc., No. 19-cv-09439 (S.D.N.Y.)
  • Digital Asset Market Clarity Act of 2025, H.R. 3633 (Senate cloture not invoked, Sept. 15, 2026)
  • FIN-2019-G001, FinCEN convertible-virtual-currency guidance (May 9, 2019)
  • 31 U.S.C. 5330; 31 CFR 1022.210, 1022.380 (MSB registration and AML programs)
  • 18 U.S.C. 1960 (unlicensed money transmitting businesses)
  • FATF Recommendation 16 (Travel Rule)
  • Revenue Ruling 2023-14; IRC Sections 6041, 3406, and 1441-1446
  • Virtual Asset (Service Providers) Act, 2020 (Cayman Islands, as amended)
  • Virtual Assets Service Providers Act, 2022; Securities and Investment Business Act, 2010 (BVI)
  • Regulation (EU) 2023/1114 (MiCA); Regulation (EU) 2023/1113 (transfers of funds)
Open the full sample (PDF) Get the full sample memorandumSent as a PDF with the Clarity Issue-Mapping Starter Kit.
02a · The Category

Not research. Not a feed. Not a chatbot. Regulatory intelligence.

Professionals evaluating CLARITY often compare it to tools built for different jobs. Here is the distinction that matters.

General legal AI platforms01 / 04

Built to research and draft across every practice area. CLARITY does one thing those platforms do not: it takes your specific digital asset scenario through a structured intake and returns a prioritized map of the regulatory issues it triggers, across twelve domains, before any drafting begins.

Regulatory intelligence feeds02 / 04

Horizon-scanning tools tell you what rules changed this week. CLARITY tells you which issues your specific matter raises. A feed is a firehose. CLARITY is a targeted memo, organized by domain and priority, ready for your file.

Blockchain analytics platforms03 / 04

Transaction monitoring and wallet screening review activity after it happens. CLARITY maps regulatory exposure before you act: the questions to resolve while the structure, the product, or the deal is still on the whiteboard.

General-purpose chatbots04 / 04

A blank prompt returns an improvised answer. CLARITY runs a guided intake built by a recognized digital assets law authority, sweeps twelve regulatory domains in one pass, and returns a structured, memo-grade PDF organized by domain and priority. No freeform prompting, and no chat.

A structured issue map before the first billable hour.

CLARITY runs your specific scenario through a structured, multi-domain intake: it identifies the regulatory issues your facts raise and organizes them by priority, so you walk into the conversation with counsel already knowing where to focus. CLARITY identifies issues for examination. It does not provide legal conclusions, and your counsel stays the decision-maker. Equipped, not exposed.

Compare tiers
03a · Learn first

Not ready to run a scenario? Start with the free resources.

Two ways to get value from CLARITY before you buy anything. Both are free, and neither requires an account.

The Starter Kit

Clarity Issue-Mapping Starter Kit

The Digital Assets Regulatory Issue-Spotting Checklist and the full human-vetted sample memorandum, sent as PDFs you can keep and share.

Get the Starter Kit
The CLARITY Briefing

Live sessions and free replays

A weekly working session on the digital-asset rules that actually move. Register for the next live briefing or watch the available replays.

The CLARITY Briefing · Live
Oct 30
Friday
Your Year-End Readiness Roadmap: A Real Scenario, Mapped Live
Thursdays · Noon ET, one hour
Register for the next briefing
See sessions and free replays
04 · Get started

Start Where You Are.
Build The Clarity You Need.

Most people start with the free assessment and the sample memorandum, then run their own matter when the timing is right. Wherever you are in that arc, there is a next step here.
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Web3 Ready CLARITY
Digital assets risk, made clear.
Resources
CLARITY AssessmentThe CLARITY Briefing (Free)Clarity Issue-Mapping Starter KitPricingPartnershipsFAQPrivacy & Data UseContact & EnterpriseSign In
The Deliverable
Your scenario mapped across the relevant legal and regulatory domains, organized by priority. A structured issue map that prepares you for the conversation with outside counsel.
Built For
Anyone accountable for digital asset risk: counsel, compliance and risk leaders, and executives at VASPs, banks, fintechs, and funds, plus the regulators and policymakers who shape the rules.
NoticeThis tool is for educational and issue-identification purposes only. It does not constitute legal advice and does not create an attorney-client relationship.