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Token administration
Aligning records of rights and administration with the development project.
Post-issuance controls
| Control | Approach |
|---|---|
| Transfers | Check KYC validity, offering jurisdictions, investor categories, holding limits, lock-ups and freezes. Issuance, forced transfers and recovery require their own approvals and limits, in addition to checks on ordinary transfers. |
| Distribution records | Record the reference date, distribution ID, eligible units, contractual recipients and payment status. Manage rounding, deadlines, unpaid amounts, withholding and retries. On-chain records alone do not establish that funds have arrived in a bank account. |
| Loss and inheritance | Transfer to a new wallet after renewed identity verification, confirmation of legal grounds and multiple approvals. Invalidate the old balance at the same time to prevent duplicate holdings and distributions. Do not reissue on the basis of an anonymous claim. |
| Suspension and recovery | Allow immediate emergency suspension through limited authority. Require multiple approvals for resumption, forced transfers, issuance and cancellation, and record the reasons, timing, effects and recovery outcome. |
| Blockchain and keys | Limit the initial design to one blockchain without a bridge. Apply multiple approvals and separation of authority to issuer-controlled keys. An embedded managed wallet is the initial option under consideration, subject to selection of the provider, custody responsibilities and costs. |
| Data | Consider balances, transfers, minimal eligibility proofs and references to public documents for on-chain records. Keep identity-verification originals, personal data, banking information and individual tax documents off-chain with access controls. |
Technology selection
Permissioned token standards supporting identity eligibility, transfer controls, suspension and recovery are under consideration. ERC-3643 is one reference specification. Blockchain, wallet, custody and payment arrangements and responsibilities will be selected through technical assessment and contractual review.
Assess eligibility, approval and holding limits separately for ordinary transfers, issuance, forced transfers, recovery and cancellation. Manage technical conformance separately from the legal requirements for offering and operating the project.
Administrative controls
The proposed approach separates authority and requires multiple approvals for fund movements, issuance, register corrections and key operations. Establish operating logs, reconciliation, backups, emergency suspension and recovery procedures, and disclose audit scope, periods, results and outstanding findings.
MARAVION Realty Token · 2026.10.28