1. Purpose
This Regulatory Boundary Statement explains the role of Matrex.
Matrex is a technology platform for token management, investor administration, compliance workflows, document management, transfer controls, and transaction recordkeeping.
Matrex is not, unless expressly stated in a separate written agreement and supported by applicable authorisation, acting as an issuer, broker, dealer, investment adviser, financial adviser, exchange, alternative trading system, clearing agency, custodian, trustee, supervisor, fund manager, managed investment scheme manager, underwriter, placement agent, market maker, payment provider, bank, wallet custodian, or legal adviser.
2. No securities offer by Matrex
Matrex does not itself offer, sell, issue, underwrite, promote, recommend, or solicit investments unless expressly identified as the issuer in the relevant offering documents.
Any offer or sale of tokens, securities, financial products, investment contracts, shares, units, notes, interests, or other instruments is made only by the relevant issuer or offeror.
Investors must rely only on the definitive offer documents, subscription documents, constitutional documents, risk disclosures, and legal terms issued by the relevant issuer or offeror.
3. Issuer responsibility
Each issuer or project sponsor is responsible for determining whether its token, asset, share, unit, interest, note, contract, or other instrument is a security, financial product, managed investment product, derivative, investment contract, debt instrument, equity instrument, or other regulated product.
Each issuer or project sponsor is responsible for complying with all applicable laws, including securities laws, financial markets laws, private placement rules, Reg D, Reg S, accredited investor rules, wholesale investor rules, managed investment scheme rules, AML/CFT rules, sanctions rules, tax laws, privacy laws, fair dealing rules, advertising rules, and consumer protection laws.
Matrex may provide workflow tools, but Matrex does not determine whether an offer is lawful.
4. United States regulatory boundary
For United States users and projects, Matrex does not provide broker-dealer, exchange, alternative trading system, clearing, custody, investment adviser, transfer agent, underwriting, or placement agent services unless expressly stated in a separate written agreement and supported by applicable registration, exemption, or authorised third-party arrangement.
Matrex does not recommend that any person buy, hold, sell, redeem, transfer, or exchange any token or investment product.
Matrex does not receive transaction-based compensation for securities transactions unless expressly permitted by applicable law.
Any project relying on Regulation D, Regulation S, or another exemption is responsible for investor eligibility, resale restrictions, transfer restrictions, legends, subscription documentation, filings, and ongoing compliance.
Tokens may be restricted securities or otherwise subject to significant resale limitations.
5. New Zealand regulatory boundary
For New Zealand users and projects, Matrex does not provide a financial advice service, discretionary investment management service, licensed market service, managed investment scheme management service, crowdfunding service, peer-to-peer lending service, derivatives issuer service, supervisor service, custody service, or other regulated financial service unless expressly stated in a separate written agreement and supported by applicable registration, licence, exemption, or authorised third-party arrangement.
Any New Zealand issuer or project sponsor is responsible for determining whether an offer involves a financial product, managed investment product, debt security, equity security, derivative, or other regulated product.
Any New Zealand issuer or project sponsor is responsible for complying with wholesale investor rules, Schedule 1 exclusions, fair dealing requirements, financial service provider registration requirements, AML/CFT requirements, disclosure requirements, and other applicable obligations.
6. No custody
Matrex does not provide custody of money, securities, tokens, crypto-assets, private keys, wallets, or client assets unless expressly agreed under a separate authorised custody arrangement.
Users are responsible for their own wallets, private keys, seed phrases, devices, blockchain approvals, and signing decisions.
Where Matrex integrates with third-party custodians, wallets, payment providers, escrow providers, or settlement providers, those providers are responsible for their own services.
7. No exchange or trading venue
Matrex does not operate a securities exchange, crypto exchange, alternative trading system, licensed market, or public trading venue unless expressly stated under a separate authorised arrangement.
Any buyer-seller matching, transfer request, bulletin board, approval queue, or transfer workflow is provided for private administration, compliance, and issuer-controlled transfer management.
Matrex does not guarantee liquidity, market depth, pricing, execution, settlement, transfer approval, buyer demand, or secondary market availability.
8. No investment advice
Matrex does not assess the suitability of any investment for any person.
Matrex does not provide investment recommendations, financial advice, legal advice, tax advice, accounting advice, valuation advice, or risk-rating advice.
Users must obtain independent advice before participating in any project.
9. No guarantee
Matrex does not guarantee any token value, asset value, preferred return, distribution, repayment, redemption, listing, liquidity event, transfer approval, tax outcome, legal outcome, or regulatory treatment.
Real-world asset tokenisation involves significant legal, regulatory, market, operational, technology, cybersecurity, liquidity, and project-specific risks.
10. Compliance records and monitoring
Matrex may collect and retain identity information, investor eligibility information, transaction records, wallet addresses, IP addresses, operating system information, device information, geolocation signals, audit logs, and other information for anti-fraud, cybersecurity, AML/CFT, sanctions, compliance, legal, and platform-integrity purposes.
Matrex may restrict or suspend access or activity where required or reasonably appropriate for compliance, fraud prevention, cybersecurity, issuer instructions, service provider requirements, regulatory requests, or legal obligations.
11. Contact
Questions about this Regulatory Boundary Statement should be sent to:
This document is published by Matrex. It may be updated from time to time — the effective date at the top of this page reflects the current version.
