Governance & Legal Structure
Version 1.0 — Last Updated: 18-11-2025
This page describes how ChainGuard is organised from a compliance, privacy, and information-security perspective. It explains our key roles, legal entity structure, and how responsibilities are distributed across the organisation.
Table of Contents
- 1. Corporate & Legal Entity
- 2. Governance Model
- 3. Compliance Responsibilities
- 4. Information Security Responsibilities
- 5. Privacy & Data Protection Responsibilities
- 6. Risk Management
- 7. External Audits & Certifications
- 8. Contact
- Related Documentation
1. Corporate & Legal Entity
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Operating entity: Chain-Fi Limited ("Chain-Fi"), registered in England & Wales.
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Product brand: ChainGuard – the security and identity product suite operated by Chain-Fi Limited.
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Development team: Chain-Fi Labs – the research and engineering arm responsible for designing and building the ChainGuard products under Chain-Fi Limited.
Legal Details:
- Registration Number: 15507356
- VAT Number: GB461989346
- Registered Office: 128 City Road, London, EC1V 2NX, United Kingdom
Unless otherwise stated, all references to "ChainGuard", "Chain-Fi" or "the Company" in this Compliance Center refer to Chain-Fi Limited, including activities performed by its Chain-Fi Labs team.
ChainGuard provides technology and infrastructure services for digital asset security and identity; it does not hold client funds or operate as a custodial exchange. Our services are designed as a non-custodial security and identity layer that enables compliance for regulated entities and dApps.
2. Governance Model
ChainGuard operates under a governance structure that ensures clear accountability for compliance, privacy, and security across the organisation.
Board & CEO – Dennis Reckermann
- Set overall risk appetite, approve policies, and ensure resources for compliance, security, and privacy.
- Provide executive sponsorship for the compliance programme and DPO function.
- Provide executive oversight and strategic direction for regulatory compliance.
Contact: dennis@chain-fi.io (strategic and partnership inquiries)
Security Engineering Lead – Mathias Pellegrin
- Designs and maintains the security architecture for ChainGuard products.
- Implements technical controls required by security and compliance policies.
- Owns secure development practices and infrastructure security.
Contact: mathias@chain-fi.io
Product & Engineering
- Implement privacy-by-design, secure development, and logging/audit requirements defined by Compliance and Security.
- Execute product features in alignment with compliance and security guidance.
Operations & Support
- Ensure day-to-day adherence to onboarding, monitoring, incident-response, and KYC/AML procedures.
- Maintain operational compliance with established policies and procedures.
3. Roles & Responsibilities (Detailed)
Compliance Officer / MLRO
Responsible for:
- Sanctions monitoring
- Restricted user audits
- AML oversight
- Regulatory updates
- Enterprise partner compliance
Contact: privacy@chain-fi.io
Data Protection Lead (DPL)
Responsible for:
- GDPR & privacy compliance
- Data processing controls
- Sub-processor assessments
- Handling privacy requests
Contact: privacy@chain-fi.io
Security Engineering Lead
Responsible for:
- Vault infrastructure
- Encryption
- Access controls
- Log integrity
Contact: mathias@chain-fi.io
5. Record Retention Policy
| Category | Retention | Justification |
|---|---|---|
| Tax & billing info | 6–7 years | UK & EU tax law |
| AML logs | 5 years | AML directives |
| General logs | 6–36 months | Security & debugging |
| Contract & enterprise agreements | 7+ years | Legal obligations |
| KYC data (if used) | Based on provider | You do not store raw KYC |
6. Audit Logs & Operational Traceability
ChainGuard automatically logs:
- Vault interactions
- Wallet binding
- Device verification
- Relayer transactions
- Gasless operations
- Subscription events
- API usage
Logs are:
- Immutable
- Timestamped
- Tied to identity + wallet
- Stored securely
- Accessible for audits
7. Access Controls
- Production access limited to authorized personnel
- Principle of least privilege
- MFA required
- Annual access reviews
- Role-based permissions
8. Key Policies & Documentation
Public summaries of important policies:
- Data Protection & Privacy – Summary of GDPR approach, DPIAs, RoPA, vendor checks
- VAT & AML – Tax and billing compliance, AML overview
- Sanctions & Restricted Use – Summary of how sanctions screening is handled
- Governance, Oversight & Record-Keeping – Retention principles and auditability (this page)
- Security Framework – High-level description of security controls and frameworks
- Project Architecture – Technical documentation and system architecture
9. Oversight & Review
These documents are reviewed annually or when:
- Regulations change
- New services are added
- New jurisdictions added
10. Forward-Looking Statements
If ChainGuard introduces:
- Custody features
- On/off-ramping
- Asset management
- Regulated financial activities
→ Additional licensing may become required.
This will be handled under a separate regulated entity.
11. ISO 27001 Requirements
Yes — and here is the quick breakdown:
| Document | Required for ISO 27001? | Notes |
|---|---|---|
| Data Protection & Privacy | ✔ REQUIRED | ISO Annex A.18 ("Compliance with legal and contractual requirements") |
| Sanctions & Restricted Use | ✔ Strongly Recommended | Falls under A.5.7 & A.6.1.3 (screening, compliance, prohibited usage) |
| Governance & Record-Keeping | ✔ REQUIRED | ISO requires evidence of governance, logs, retention, roles & responsibilities (A.5, A.6, A.8, A.12) |
So yes — these 3 documents help significantly with ISO certification.
Combined with:
- Security policies
- Access control policies
- Incident response
- Development standards
12. Versioning & Change Log
| Version | Date | Change |
|---|---|---|
| 1.0.0 | 18-11-2025 | Initial publication of governance section. |
Related Documentation
- Data Protection - Privacy and GDPR compliance
- VAT & AML - Tax and billing compliance
- Sanctions - Restricted use and OFAC compliance
- Global Compliance Overview - Overall compliance framework
- Project Architecture - Technical documentation and system architecture
Next: Review Sanctions & Restrictions or explore jurisdiction-specific compliance.