Polygon Corporate Structure: A Public Evidence Map
Analysis date: November 5, 2026
Evidence cutoff: November 5, 2026
Scope: Polygon Foundation and Labs ownership, the POL issuer, service and IP entities, Coinme and BTCD, Sequence, and the economics of Open Money Stack.
Polygon's operating companies, token issuer and blockchain are different parts of the ecosystem. Public records identify several direct ownership links, but do not provide a complete current shareholder register for the group.
Polygon Labs Holdings (Cayman) Ltd is the disclosed parent of the Swiss MiCAR applicant, the BVI POL issuer and the UK subsidiary. Its current ultimate ownership remains unresolved. Polygon's January 2023 announcement described full Foundation ownership; a later lobbying filing disclosed a historical indirect split of 77.24% Polygon Foundation / 22.76% Mihailo Bjelic. Those statements concern different dates and cannot establish today's percentages. Polygon announcement, 2023 LDA disclosure.
Sequence's last federal record also reveals part of its historical ownership during the acquisition period: Peter Kieltyka was the only published individual with significant control, in a 25β50% shares band, while the company was classified as having more than 50 shareholders. This is a historical control disclosure, not a closing cap table or a statement of his payout. Corporations Canada.
This page explains the legal entities and ownership boundaries. The separate Coinme and Sequence acquisition report covers the transactions and operating risks; Open Money Stack covers payments economics and possible POL demand. See also the POL white paper guide and the contract-level POL Authority Map.
Executive Findings
- The core parent chain is documented.
Polygon Labs Holdings (Cayman) Ltdis identified as the parent of the Swiss MiCAR applicant and BVI POL issuer. UK shareholder filings and accounts also place all 100 shares of the UK company under Holdings. - Ultimate ownership remains unresolved. The January 2023 Foundation statement and later LDA percentages do not supply a current Holdings shareholder table.
- Mihailo Bjelic's 2025 departure does not prove a disposal of his historical interest. Leaving a board and day-to-day operations is not a share transfer, redemption, cancellation, or buyback.
- The group separates functions by jurisdiction. BVI houses the token issuer, Switzerland the MiCAR applicant, the UAE important trademark rights, Cayman user interfaces, and Delaware/UK/India/Canada/Spain operating and employment functions.
- Sequence has a documented Canadian corporate history. A federal ownership disclosure, Alberta continuance, February 5 amalgamation and IP assignments identify the predecessor and successor companies. They do not disclose every purchaser, seller or payment.
- The 2022 $450 million financing was a private token sale. Its participants cannot be placed in the Polygon Labs shareholder table without separate equity evidence.
- Coinme's acquisition preserves entity-specific obligations. October completion does not turn its licences into a blanket permission for every Polygon company or product.
- Corporate revenue is not automatically POL-holder revenue. Owning POL does not establish equity ownership in Holdings, Sequence or Coinme, or a right to their profits.
How to Read the Ownership Map
A shareholder filing can establish an ownership link at its stated date. An affiliate notice, shared director, registered address or trademark registration establishes a different relationship. Those records cannot be substituted for one another.
Company announcements describe the parties' position; litigation pleadings describe allegations. Neither is automatically a current cap table or a court finding. Where the legal chain is incomplete, the map leaves that link unresolved.
Reconstructed Corporate Map
Polygon Foundation β Cayman foundation company
ββ [Polygon says it owns the group; current percentage is unresolved]
Polygon Labs Holdings (Cayman) Ltd β reg. 395691
ββ Polygon Labs Services (Switzerland) AG
β ββ Swiss MiCAR applicant
ββ Matic Network (BVI) Ltd β reg. 1993457
β ββ POL issuer
ββ Polygon Labs Services (UK) Ltd β all 100 shares disclosed
ββ Coinme acquisition β completed October 2026
ββ Holdings/Zap merger vehicles and Coinme Holdings named in order;
final post-merger intermediate chain not fully public
Affiliates whose precise ownership path is not public:
ββ Polygon Labs Tokens (Cayman) Ltd
ββ Polygon Labs UI (Cayman) Ltd
ββ Polygon Labs Services (Delaware) Inc
ββ PT Services DMCC β UAE trademark holder
ββ D.N. Researchers FZE LLC β former trademark holder/applicant
ββ Catenable AG
β ββ 100% Uniclau S.L. β this edge is registry-confirmed
ββ PLSI Technology Services (India) LLP
ββ Polygon Labs Services (Canada) Ltd
Acquired or integrated perimeter with incomplete public ownership chains:
ββ Mir team and technology β Polygon Zero
ββ Toposware, Inc
ββ Hermez team and technology β Polygon Hermez / zkEVM
ββ Sequence Platforms ULC / Sequence
ββ February 5, 2026 amalgamation; complete upper chain unavailable
The Swiss, BVI and UK parent edges have direct disclosures. Coinme's order identifies Holdings and acquisition vehicles, while the completion announcement establishes the transaction's later status; it does not publish every surviving intermediate entity. An affiliate, joint controller, trademark owner, product, or shared executive is not automatically a subsidiary.
The MiCAR Core Chain
Polygon Labs Holdings (Cayman) Ltd
The official POL MiCAR page and current v2 XHTML, published September 15, 2026, identify Polygon Labs Holdings (Cayman) Ltd, registration number 395691, as the parent of the Swiss applicant and BVI issuer. The old PDF is marked outdated on the landing page. The GLEIF record, LEI 984500FEC0ADB5Y4A735, records the former name Ptech Holdings (Cayman) Ltd.
GLEIF separates legal-entity status from LEI status. A LAPSED LEI does not mean the company has been dissolved. Its accounting-parent exception is also not a shareholder register.
Polygon Labs Services (Switzerland) AG
Polygon Labs Services (Switzerland) AG, identifier CHE-275.116.509, is the MiCAR applicant seeking admission to trading for POL in the EU. It was formerly Ptech Services (Switzerland) AG; the name history is supported by the Swiss commercial-gazette record.
The Swiss company record shows Marc Palacio Rodriguez in the governing body and Gabriele Pinardi as a signatory. Antoni Martin left the governing perimeter in April 2025. GLEIF provides LEI 9845000C4775C78EDA15, but no public shareholder register.
Matic Network (BVI) Ltd
The MiCAR white paper identifies Matic Network (BVI) Ltd, registration number 1993457, as the POL issuer and a subsidiary of Holdings. It gives an incorporation date of September 26, 2018 and names Claire Abrehart as sole director at the white paper date.
V2 field G.5 discloses 2 billion retained POL. This is a white-paper disclosure, not a wallet-balance reconciliation as of November 5, and does not establish the issuer's ultimate beneficial owner.
The MiCAR Internal Inconsistency
MiCAR sections A.11 and B place Holdings above the Swiss applicant and BVI issuer. Section A.17 instead names Polygon Labs Tokens (Cayman) Ltd as the parent. These are distinct Cayman entities, and the 2023 LDA disclosure separately assigned Tokens Cayman 0% ownership of the Swiss lobbying client.
The September v2 retains this inconsistency; field F.10 also retains January 9, 2026 despite the later publication date on the landing page. Holdings remains the parent named in A.11 and B.9. Tokens Cayman is a distinct entity, registration 395313. A.17 alone cannot establish a different ownership chain.
Ultimate Ownership and Mihailo Bjelic
Historical Ownership Disclosures
Polygon's January 11, 2023 corporate-structure announcement said the Polygon Labs group was entirely Foundation-owned. It described the Foundation as a Cayman memberless foundation company without equity owners.
The 2023 LDA registration for Polygon Labs Services (Switzerland) AG, effective February 15 and signed June 26, disclosed a different structure:
| Disclosed person or entity | Relationship to the Swiss client | Disclosed interest |
|---|---|---|
| Polygon Labs Holdings (Cayman) Ltd | Direct owner | 100% |
| Polygon Foundation | Indirect owner through Holdings | 77.24% |
| Mihailo Bjelic | Indirect owner through Holdings | 22.76% |
| Sanket Shah | Indirect ownership | 0% |
| Jordi Baylina | Indirect ownership | 0% |
| Antoni Martin | Indirect ownership | 0% |
| Polygon Labs Tokens (Cayman) Ltd | Ownership | 0% |
A 2024 LDA registration, effective August 1 and signed October 15, continued to identify Holdings as the Swiss entity's direct owner without a complete ultimate-owner table. A Q2 2025 report reported no relevant foreign-entity additions or removals. Silence does not prove unchanged percentages.
The Q1 2026 and Q2 2026 reports also provide no replacement ultimate-owner table. The January 2023 statement and later disclosure concern different dates; an intervening change is possible but not documented by these sources. Neither establishes today's percentages.
The 2024 registration was submitted by a different lobbying registrant, Squire Patton Boggs, from the 2023 Subject Matter registration. It should not be described as a demonstrated amendment of the same registration.
The Cayman Beneficial Ownership Transparency Act, 2026 Revision, sections 3β4, applies to foundation companies. It uses a 25% ownership/voting threshold alongside separate control tests; a memberless company can therefore still have a person exercising control. Where no registrable beneficial owner or trustee is identified, a senior managing official is recorded as the contact person. That does not make the official an economic owner. A beneficial-owner record is not a full shareholder register: the historical 22.76% alone is below the ownership threshold.
Departure Is Not Divestment
Mihailo Bjelic left the Polygon Foundation board and day-to-day work at Polygon Labs in May 2025. That establishes an operational departure, not a transfer of the historical 22.76% indirect interest.
A share transfer, redemption, cancellation, buyback or updated Holdings register would be needed to establish what happened to that interest. The public documents cited here support this narrower conclusion:
22.76%is a historical regulatory disclosure. Mihailo Bjelic's current economic interest, if any, is unknown.
Both unconditional claims β βhe still owns exactly 22.76%β and βhe left, so the interest no longer existsβ β go beyond the evidence.
Operating, Employment, and IP Entities
The Polygon candidate privacy notice, last updated in 2023, identifies Delaware, UAE, UK, Swiss, Spanish, Canadian and Indian entities as affiliates or joint controllers. These are employment and data-protection relationships, not a current group cap table.
| Entity | Jurisdiction / identifier | Publicly documented role | Main unresolved point |
|---|---|---|---|
| Polygon Foundation | Cayman | Claimed owner and strategic controller of the group | Current percentage in Holdings and governing documents |
| Polygon Labs Holdings (Cayman) Ltd | Cayman, reg. 395691 | Parent of Swiss applicant and BVI issuer | Shareholders and beneficial owners |
| Polygon Labs Services (Switzerland) AG | Switzerland, CHE-275.116.509 | MiCAR applicant and service entity | Full shareholder register |
| Matic Network (BVI) Ltd | BVI, reg. 1993457 | POL issuer | Full shareholder/director and treasury-wallet records |
| Polygon Labs Tokens (Cayman) Ltd | Cayman, LEI 984500E2FDFCE92FDX25 | Separate entity named in MiCAR and LDA | Exact position in the group |
| Polygon Labs UI (Cayman) Ltd | Cayman | Website and interface operator under Terms of Use and sPOL terms | Direct ownership chain |
| Polygon Labs Services (Delaware) Inc | Delaware | US service entity and OMS contractual technology operator; formerly Polygon Studios Labs Inc | Shareholder list and current consolidated financials |
| PT Services DMCC | UAE | Operating affiliate and trademark holder | Shareholders and licence arrangements |
| D.N. Researchers FZE LLC | UAE | Affiliate and former trademark applicant/owner | Current status and ownership |
| Polygon Labs Services (UK) Ltd | UK, company 14444411 | All 100 shares disclosed under Holdings; dormant in 2024 accounts | Current activity after the reported accounting period |
| Catenable AG | Switzerland, CHE-414.037.572 | IT company and affiliate; owns Uniclau | Catenable's own shareholder |
| Uniclau S.L. | Spain | Engineering affiliate, 100% owned by Catenable | Higher ownership path |
| PLSI Technology Services (India) LLP | India, ACC-8216 | Indian service entity | Partner economics and direct group edge |
| Polygon Labs Services (Canada) Ltd | Canada / QuΓ©bec | Canadian service affiliate | Full official extract and ownership |
United Kingdom
Polygon Labs Services (UK) Ltd, company number 14444411, is active, incorporated on October 26, 2022, and was formerly Ptech Group Services UK Ltd.
The PSC page contains an active no-registrable-PSC statement. This does not prove an absence of control; a foreign foundation or company can sit outside the information conveyed by that statement.
The incorporation document shows PTECH FOUNDATION subscribing for all 100 initial shares. The 2023 confirmation statement, page 2, records Polygon Foundation transferring all 100 ordinary shares on December 31, 2022 and Holdings holding all 100 at the October 25, 2023 confirmation date. The 2024 and 2025 confirmations report no updates.
The 2024 accounts, filed October 9, 2025, independently identify Holdings as immediate parent. They describe the UK company as dormant since incorporation, with no income or expenditure and Β£1 cash/shareholders' funds at December 31, 2024. These accounts do not value the whole group or establish inactivity throughout 2026. Note 4 refers separately to group accounts prepared for Holdings.
Switzerland and Spain: Catenable to Uniclau
Catenable AG, CHE-414.037.572, is an active Swiss company formed in 2018 with CHF 100,000 share capital. Marc Palacio Rodriguez is shown as sole board member. Polygon's candidate notice places it in the affiliate perimeter.
Spain's official corporate gazette documents the CatenableβUniclau relationship:
- the 2012 formation record named Jordi Baylina sole administrator of Uniclau S.L.;
- a 2020 record appointed Catenable AG sole administrator, represented by Marc Palacio;
- a 2024 record made Catenable AG the sole shareholder of Uniclau;
- later 2025 and 2026 records document authority and address changes.
Catenable AG β 100% Uniclau S.L. is therefore confirmed. Polygon Foundation/Holdings β Catenable AG is not: affiliate wording and shared managers do not replace Catenable's shareholder register.
UAE Trademark and IP Control
A Canadian trademark record shows Polygon trademark rights moving from D.N. Researchers FZE LLC to PT Services DMCC on May 25, 2023. A later Hong Kong IP publication also identifies PT Services DMCC as owner.
PT Services DMCC is therefore a documented brand/IP holder, not merely a payroll affiliate. A US trademark litigation docket also shows the Delaware company and PT Services DMCC acting in the same dispute. Trademark ownership does not reveal the shareholder of the DMCC entity or the terms of intra-group IP licences.
Delaware and the Polygon Studios Lineage
A public California business-record mirror records the September 20, 2023 name change from Polygon Studios Labs Inc to Polygon Labs Services (Delaware) Inc. Marc Boiron is listed as CEO, secretary, and director; Joe Hamade as CFO.
A 2022 federal litigation record reported P.S. Labs FZE LLC as the parent of Polygon Studios Labs Inc. P.S. Labs FZE is absent from the later candidate notice; its current status and transition into the reorganized structure were not established.
Legacy Matic Entities
Matic Network Pte Ltd
The Singapore company record shows Matic Network Pte Ltd, UEN 201825664W, incorporated July 27, 2018, as a live exempt private company limited by shares with SGD 100 paid-up capital.
Some historical investment materials called this entity βMatic Foundationβ or a non-profit. Its registered legal form is a private company limited by shares. The public record does not explain how its shares or assets moved into the later Cayman/BVI structure.
An official Singapore first strike-off notice, first published September 17, 2026, lists the same UEN on page 3, item 70. Its 60-day objection period had not elapsed by November 5. This is a pending strike-off notice, not an established dissolution or insolvency finding.
Matic Network India LLP
Indian corporate-data mirrors Zauba and Tofler show Matic Network India LLP, LLPIN AAM-7783, incorporated June 5, 2018, as active.
Leaving day-to-day work does not by itself remove someone from an older LLP record. The cited mirrors do not establish the current partnership agreement or profit-sharing rights.
PLSI Technology Services (India) LLP, LLPIN ACC-8216, is a separate, newer Indian entity formed in 2023. Its GLEIF record and Polygon's candidate notice support its existence and operational relationship, but not its economics.
Acquisitions
| Transaction | Public evidence | Status and limitation |
|---|---|---|
| Hermez, 2021 | Polygon and Hermez announced a merger, team and technology integration, and maximum consideration of 250 million MATIC | Business/protocol integration is clear; exact buyer and surviving corporate chain are not |
| Mir, 2021 | Polygon announced the acquisition, with up to $100 million plus 190 million MATIC; the team became Polygon Zero | Team integration is public; the complete purchaser and present corporate chain are not |
| Toposware, 2024 | Polygon Labs announced the acquisition and team integration | Acquisition is confirmed; exact purchaser and current chain are not published |
| Sequence, 2026 | Investment Canada Act case 00037790, Alberta Gazette, and CIPO trademark 2031910 | Sequence BuyCo ULC and Sequence Platforms Inc. amalgamated as Sequence Platforms ULC on February 5, 2026; complete upper ownership chain not published |
| Coinme, 2026 | Polygon completion announcement, October 14, following the October 7 multistate order | Completed acquisition; order names Holdings, Zap merger vehicles and Coinme Holdings, and imposes continuing compliance and kiosk-exit obligations |
Sequence's Last Federal Ownership Disclosure
The Corporations Canada record for Sequence Platforms Inc., corporation 1054673-9, identifies Piotr (Peter) Kieltyka as its only published individual with significant control. The ISC section was last updated or confirmed on January 19, 2026. It records shares held directly and individually, in the band at least 25% and up to 50%.
The same federal record lists Piotr Kieltyka, Todd Finch and Brett Gibson as directors. Its annual-filings panel classifies the company as a non-distributing corporation with more than 50 shareholders. That category does not identify every shareholder or seller. The ISC confirmation date applies to that section, not automatically to every other field.
Under the official ISC rules, significant shares can be measured by voting rights or fair market value. The disclosed band therefore does not establish a fully diluted economic percentage or Kieltyka's proceeds. It is the last federal disclosure before continuance into Alberta, not the current ULC shareholder register.
Sequence's Purchaser and Successor Companies
The December 15, 2025 Alberta notice records Sequence Buyco ULC, 2027628326, and Sequence Callco ULC, 2027628169, incorporated on November 10. Corporations Canada and the February 28, 2026 Alberta notice record the target's January 20 continuance into Alberta as Sequence Platforms Inc., 2027813928.
Buyco and the target amalgamated on February 5, 2026 into Sequence Platforms ULC, 2027871710. CIPO records the same effective date for assignment of the SEQUENCE trademark to the ULC. These are dates of reorganisation and IP succession; they do not establish the precise purchase closing or payment date. Alberta amalgamation notice.
The notices do not disclose Buyco's or Callco's shareholders. Callco's name alone does not establish its place in the chain or an exchangeable-share arrangement. The complete link from these vehicles to a particular Polygon parent remains unresolved.
The ICA acquisition record names Sequence BuyCo ULC and reports India as the country of ultimate control. The official form guidance permits control through a controlling shareholder, group or, in specified circumstances, a board. It does not identify one person's percentage. Under the publication rules, March publication of the notification is not its closing date.
Polygon Was Already an Investor
Horizon's October 4, 2022 Series A announcement names Polygon among the participants in the US$40 million round. That is the round's total, not Polygon's cheque. The announcement does not identify the subscribing Polygon legal entity, its stake or whether it retained that interest through the acquisition.
A prior investment could affect the amount paid to outside holders. Without the closing cap table and funds flow, it cannot establish a payment back to Polygon, a particular acquisition discount or the recipients' cash/equity proceeds. The more than US$250 million announcement covers Coinme and Sequence together; it does not establish Sequence's separate price or an all-cash exit. See the acquisition report for the sellers, earlier Xerial/Light transactions and price claims.
Coinme's Change of Control
The October 7, 2026 multistate order names Polygon Labs Holdings, Zap acquisition vehicles and Coinme Holdings. Polygon's October 14 completion announcement establishes the later transaction status. Neither source publishes every surviving intermediate ownership link.
The order attaches continuing compliance and kiosk-exit obligations to the regulated business. It does not give every Polygon entity a money-transmitter licence. Coinme's licences, remediation, BTCD-related accounting and current service changes are covered in the Coinme and Sequence acquisition report.
Investors and Corporate Value Capture
Polygon's 2022 US$450 million financing was a private sale of MATIC tokens. The named participants, including Sequoia Capital India, SoftBank Vision Fund 2, Galaxy and Tiger Global, are token-round backers. That announcement does not make them confirmed shareholders of Holdings.
Corporate contracts also identify specific entities. The OMS terms, version 1.3 dated August 3, 2026, name Polygon Labs Services (Delaware) Inc. as technology operator and distinguish regulated providers, bank services and platform fees. This identifies an operating role, not the Delaware company's shareholders or consolidated profit.
POL ownership is different from company ownership. MiCAR v2, section G.1 states that the token does not carry legally enforceable rights against its issuer. Private-company revenue does not automatically become a dividend or other entitlement for POL holders. Any connection through network fees, staking, burns or token purchases requires its own evidence. The OMS report examines those mechanisms and their limits; the POL white paper guide explains the token disclosures.
Networks, Tokens and Companies
Polygon PoS, Polygon zkEVM, Agglayer, Polygon CDK, POL, Community Treasury, Protocol Council, Polygon Studios, Polygon Zero and Open Money Stack are networks, tokens, governance bodies, products or brands. A distinct legal entity must be identified before any of them is placed in a shareholder tree.
Unresolved Ownership Links
The public map leaves several material questions open:
- Holdings' current shareholders and the Foundation's appointment and control powers;
- the disposition, if any, of Bjelic's historical interest;
- the full ownership paths of the operating and IP affiliates;
- Sequence's closing shareholders, Buyco/Callco parentage and cash/equity allocation;
- the complete surviving Coinme intermediate chain and consolidated group accounts.
A company can belong to the operating or IP perimeter without a publicly established ownership path. The map preserves that distinction.
Frequently asked questions
Who owns Polygon Labs?
Holdings is the disclosed parent of several core companies. Its current ultimate ownership is unresolved: Polygon described full Foundation ownership in January 2023, while a later filing disclosed a historical 77.24%/22.76% FoundationβBjelic split. Neither supplies a current cap table. 2023 LDA filing.
Does a memberless Foundation have no controlling person?
Memberless describes the absence of members or equity owners. It does not rule out control through governing powers. Cayman law separately tests ownership and effective control; a senior official listed only as contact person is not thereby an economic owner. Cayman BOTA, sections 3β4.
Does Mihailo Bjelic still own 22.76%?
That is a historical indirect-interest disclosure in the 2023 lobbying registration. His departure from operational and board roles does not establish a sale or cancellation, and the later filings do not provide replacement percentages. His current interest is unresolved. Historical disclosure.
Which legal entity issues POL?
The current MiCAR white paper identifies Matic Network (BVI) Ltd, registration 1993457, as the issuer and Holdings as its parent. The Swiss company is the applicant for admission to trading. MiCAR v2.
Is Tokens Cayman the same company as Holdings?
They have different registration numbers: Tokens is 395313 and Holdings is 395691. MiCAR A.17 names Tokens as parent in its financial description, while A.11 and B.9 name Holdings. The inconsistent wording does not establish that Tokens owns Holdings. MiCAR v2.
Is the UK company owned by Holdings?
The 2023 confirmation statement records Holdings holding all 100 ordinary shares, and the 2024 accounts identify it as immediate parent. The UK company's Β£1 dormant balance is not the value of the group. Shareholder statement.
Which company operates Polygon's interfaces and OMS technology?
The general interface terms name Polygon Labs UI (Cayman) Ltd; the OMS terms name Polygon Labs Services (Delaware) Inc. for technology services. Regulated payment services involve separately identified providers. These roles do not establish the operators' shareholders. Interface terms, OMS terms.
What is public about Sequence's shareholders?
Its last federal ISC disclosure, confirmed January 19, 2026, lists Peter Kieltyka in a direct, individual 25β50% shares band. The company is separately classified as having more than 50 shareholders. Neither field is a complete closing register or a statement of acquisition payouts. Corporations Canada.
Did Sequence's purchase close on February 5, 2026?
February 5 is the documented amalgamation and effective trademark-assignment date. It is not a disclosed receipt for the purchase closing or seller payments; the purchase could have preceded that reorganisation. Alberta notice, CIPO.
Was Polygon already an investor in Sequence?
Yes. Horizon's 2022 Series A announcement names Polygon among the participants. It does not disclose the subscribing legal entity, Polygon's cheque or its percentage. The US$40 million figure covers the whole round. Horizon announcement.
Who owns Sequence Buyco and Callco?
The Alberta notices establish their incorporation and Buyco's later amalgamation with the target. They do not name their shareholders or prove Callco's position in the ownership chain. Their similar names are not enough to assign a parent or rollover structure. Incorporation notice.
Has Polygon completed the Coinme acquisition?
Polygon announced completion on October 14, 2026. The regulator order names Holdings and merger vehicles and imposes continuing obligations on the regulated business. Completion does not make Coinme's licences a group-wide permission. Completion announcement, multistate order.
Do POL holders own these companies or receive their profits?
Holding POL does not establish corporate equity in Holdings, Coinme or Sequence. The white paper grants no legally enforceable rights against the issuer, and corporate payments revenue has no automatic distribution to token holders. Specific network or purchase mechanisms must be assessed separately. MiCAR G.1, OMS analysis.