Operating model
One interface. Separate balance sheets. Separate legal title.
The app is a distribution layer. Money, crypto and goods each sit with the entity legally permitted to hold them.
Product / service relationshipSecurity / legal-title link
E2
Licensed crypto custodian / asset service provider
Client BTC/ETH (segregated); any Earn if permitted
E4
Commodity / RWA infrastructure & independent verifiers
Document custody, token records, inspection reports
What HDBank could do (conditional)
- • If its proposed VIFC subsidiary is established and licensed, act as E1 for deposits, credit and payments.
- • Contribute banking risk, AML and treasury expertise.
- • Status today: corporate proposal (draft GMS resolution, 26 Mar 2026) — not verified as licensed.
What Galaxy / Commodity Chain could do (conditional)
- • Galaxy ecosystem: potential technology or distribution input — role not defined or agreed.
- • Commodity Chain: potential E4 record-keeping infrastructure, subject to licensing and independent verification.
- • Neither may hold client money or crypto without its own permission.
All roles above are hypotheses for discussion. No party has agreed, and no regulator has approved, any role.