DMaple Non-Custodial Statement

Draft v0.1
Issued by:
DMaple Inc.
Ontario Corporation No. 1606272-5

Date:
7 JUNE 2025

1. Purpose of the Statement

This document is issued to formally clarify the nature of services provided by DMaple — a platform operated by SDMaple Inc., a corporation registered in Ontario, Canada.

The purpose of this statement is to confirm that DMaple is a fully non-custodial platform and does not provide cryptocurrency custody or operate as a traditional exchange. This clarification is intended for users, regulators, financial institutions, and payment service providers who may require formal recognition of our operational model.

2. Regulatory Scope and MSB Activities

Certain regulated services are provided under DMaple’s Money Services Business (MSB) registration. These services may include facilitation of digital asset transactions and fiat settlement through regulated banking and payment partners, subject to applicable AML/KYC requirements and transaction monitoring.

These activities are conducted separately from DMaple’s non-custodial platform functionality and do not involve the custody or control of customer assets.

3. Nature of Services Provided

DMaple allows users to send and receive cryptocurrency payments via email through a simplified and user-friendly interface.

The platform provides:
- generation of blockchain wallet addresses upon user request;
- password-protected delivery of private keys to the user (DMaple does not store these keys);
- local transaction signing by the user;
- broadcasting of signed transactions to the blockchain network through node infrastructure.

At no point does DMaple possess, store, or control users’ private keys or access credentials. DMaple acts solely as an interface and transmission tool, with all critical security and authorization actions performed on the user’s device.

4. User Autonomy and Control

Users retain exclusive control over their digital assets at all times. Private keys are created securely on demand and transmitted to the user as encrypted files, accessible only via a password known solely to the user.

DMaple does not have the technical capability to:
- initiate transactions on behalf of the user;
- access or recover private keys;
- alter, reverse, or block any transaction.

All signed transactions are submitted by the user’s device. DMaple plays no role in storing, holding, or securing user funds.

While transactional metadata (e.g., amount, timestamp, transaction hash) may be recorded for analytics, performance monitoring, and accounting features, no sensitive financial data or control mechanisms are retained.

5. Absence of Custodial Risk

DMaple does not offer custodial wallets, escrow services, or intermediary control over assets. At no time does DMaple take possession of or retain access to user funds.

As such:
- DMaple cannot freeze, delay, or intervene in any transaction;
- DMaple is not responsible for lost private keys, password mismanagement, or user error;
- DMaple is not subject to obligations or liabilities typically associated with financial custodians or traditional custodial intermediaries.

This non-custodial architecture significantly reduces counterparty risk and eliminates the concentration of assets within a centralized service provider.

6. Legal Positioning

Under applicable Canadian regulatory guidance and FATF recommendations, DMaple operates a non-custodial technology platform and does not custody or control customer digital assets.

Certain regulated activities are conducted by DMaple under its Money Services Business (MSB) registration, including the facilitation of digital asset-related transactions and fiat settlement through regulated banking and payment partners, subject to applicable AML/KYC requirements and transaction monitoring.

DMaple maintains and periodically reviews its compliance framework aligned with FINTRAC requirements as its services evolve, including support for fiat settlement through regulated partners.

Jurisdictional access is monitored, and the company reserves the right to restrict access from high-risk regions in accordance with FATF recommendations and local laws.

7. Conclusion

DMaple is a non-custodial technology platform and does not engage in cryptocurrency custody or operate as a traditional exchange. Users retain full control of their digital assets at all times.

Regulated transaction facilitation and fiat settlement services, where applicable, are conducted under DMaple’s MSB framework through regulated partners.

This statement is issued to provide clarity and assurance to users, partners, and institutions. It may be shared with financial entities or regulatory advisors in connection with due diligence or onboarding processes.