Compliance
Gray Digital is constantly updating and evolving to remain compliant
Gray Digital Chief Compliance Officer (CCO)
Gray Digital has a dedicated Chief Compliance Officer who oversees the organizations compliance. Taylor Lee is responsible for several functions related to the Gray Digital including Regulatory Expertise, Policy Direction, Employee Training, Oversight and Internal Auditing, Communications, Enforcement, Continuous Enhancement of Documentation and Products, and Risk Management. Taylor Lee serves as the Compliance Officer and is instrumental in ensuring our organization remains aligned with both external regulations and our internal policies. More details about Taylor can be found here:
The Gray Digital TeamGray Digital Legal Team
The Gray Digital, and by extension the Gray Fund— is represented by Perkins Coie LLP. Perkins Coie LLP is an international law firm that has a team who specializes in digital assets, funds, and regulatory structuring. The legal team is focused on obtaining the licenses to better position Gray Digital for when regulation comes, and advising Gray Digital how best to protect investors and their funds.
Here is a list of licenses Gray Digital aims to obtain in the near future:
Money Service Business Registration, Consumer Credit License, Money Transmitter License, Financing Law License, Money Broker License Lender License, Foreign Registrations, Virtual Currency Operator License, Securities Dealer.
More information about Perkins Coie LLP and their services can be found on their website:
Partnership with Chainalysis
Gray Digital has partnered with Chainalysis to help bring the Gray Digital into a more regulatory position as we work towards being compliant with future regulation requirements. Chainalysis is a platform that performs AML checks, company wallet monitoring, user wallet monitoring, malicious transaction detection and various other services, to block and detect participants who are using the platform with malicious intent. Other reasons for working with Chainalysis:
Meet regulatory requirements while staying ahead of financial crimes and avoiding sanctioned entities/persons/wallets.
Protect participating members as well as Gray Digital, increase consumer trust, and maintain brand reputation
You can read more about the services they provide on their website at: https://www.chainalysis.com/
Third Party Audits
CertiK Audit
The Gray Digital + Gray Fund have completely finished a comprehensive audit and KYC with CertiK (https://skynet.certik.com/projects/gray-market). Eight members of or backend and executive team have completed their full KYC and the Gray Digital was awarded with their Gold KYC badge. The Certik audit ensures that the smart contracts utilized by Gray Digital are safe and secure for participating members.
Moore: Blockchain & Digital Assets Gray Fund AUP Completion and Verification of Assets Under Management
This rigorous process has been an important step in our commitment to transparency and due diligence. The report provides a detailed attestation of our total assets under management (AUM), meticulously verified by Moore with the cooperation of esteemed third parties such as Interactive Brokers and JP Morgan, among others.
Moore's independent verification process included a thorough review of our relationships with key financial providers and an analysis of the security infrastructure within the Gray Market ecosystem. They have examined and verified service agreements and contracts with all our third-party vendors, including Fireblocks, Coincover, Kraken, Bloomberg, Chainalysis, Morgan Stanley, and Stripe.
Furthermore, the integrity and compliance of our third-party providers with international security standards have been affirmed through the collection and examination of their SOC reports.
The audit report outlines the Agreed-Upon Procedures (AUP) for asset balance attestation. Moore conducted the AUP in compliance with ISRS 4400 (Revised) and focused on verifying the total Assets under Management (AUM) as of December 31, 2023. They reviewed the Gray Fund's business model, financial technology applications, and diverse investment strategies in traditional and decentralized finance. The AUM was independently verified through documents provided by Interactive Brokers, JP Morgan, and Morgan Stanley. The report includes findings on security measures and Service Agreements with various third-party service providers. Moore's inspection confirmed asset ownership and reconciled AUM balances with the Public Facing AUM/NAV Report. The report emphasizes the Gray Fund's commitment to transparency and security in investment management.
A copy of the Moore audit can be found on the Gray Digital Discord.
Disclosures, Policies & Agreements
Gray Digital has several applicable Disclosures, Policies & Agreements that directly impact and are agreed upon by all Gray Digital participants. More information about these documents can be found here:
Disclosures, Policies & AgreementsLast updated
