Examination Response #2
This June 13, 2025 letter supplies the first portion of Block Transfer's response to an additional staff request dated June 9. It focuses on lost-securityholder searches and the identity-verification and anti-money-laundering methods used when opening and servicing investor accounts.
Topics covered
- Correction and supporting sources for an issuer par-value discrepancy
- Securityholder correspondence, email delivery failures, and account-onboarding messages
- Lost-securityholder search timing, databases, follow-up procedures, and documentation
- Private onboarding records and the relationship between issuer and investor verification
- Identity verification, sanctions screening, periodic monitoring, record retention, and account restrictions