GLEMO - Legal / Compliance Summary
Important: this document is a diligence summary and not legal advice. It must be reviewed and supported by qualified counsel before close, TGE, public distribution, or investor reliance.
Core Compliance Position
Glemo's RWA model should be presented as a service / representation layer. Glemo does not claim to issue, tokenize, custody, distribute, or guarantee yield from real-world assets unless a specific regulated provider structure and legal memo support that activity.
The GO token should be positioned as an ecosystem utility and incentive layer, not as a claim on RWA cash flows.
Approved Language
Use:
- "Glemo provides a service / representation layer for regulated RWA access."
- "GO is an ecosystem incentive, governance, and developer/community utility token."
- "RWA access is subject to KYC, geofencing, and jurisdictional restrictions."
- "The GO token does not capture economic value from the RWA layer."
- "Glemo does not distribute yield or guarantee returns."
Avoid:
- "Token holders receive yield."
- "GO captures RWA revenue."
- "RWA returns flow to token holders."
- "Guaranteed yield."
- "Universal access."
- "Bank-backed yield."
Entity Structure - Working Assumption
| Entity / Jurisdiction | Intended Role | Open Questions |
|---|---|---|
| BVI | Token issuer / token framework | Counsel confirmation required |
| Delaware / US | Marketplace or international operating company | Counsel confirmation required |
| Brazil | Real estate ops, partner relationships, local RWA pathway | Brazil counsel required |
| Regulated providers | Bank, custodian, trustee, FIDC/securitization, KYC/geofencing, payments | Provider shortlist required |
Key Legal Questions For Counsel
- Can GO be structured as a utility/incentive token without creating a securities claim?
- What restrictions are required for US persons?
- What restrictions are required for Brazil-based users?
- What jurisdictions should be excluded at TGE?
- Can a BVI issuer support the intended token launch?
- What claims can be made in the deck, website, whitepaper, and data room?
- What legal structure is required for RWA representation without yield capture?
- What KYC/geofencing controls are required?
- What disclosures are required for a SAFE + token warrant?
- What restrictions are required for airdrop recipients?
Pre-Close Deliverables
| Deliverable | Owner | Priority | Status |
|---|---|---|---|
| External legal memo: BVI / US / Brazil | Legal counsel | High | To prepare |
| RWA process map | Founder + counsel | High | To prepare |
| Token risk factors | Counsel | High | To prepare |
| KYC/geofencing vendor shortlist | Ops / legal | Medium-high | To source |
| Communications guidelines | Counsel | High | To prepare |
| SAFE + token warrant review | Counsel | High | To prepare |
Legal Diligence Message
The token is not designed to capture RWA economics. The RWA layer is service/representation-based, jurisdiction-restricted, and dependent on regulated rails. Final implementation will be counsel-led and gated by legal memo, KYC/geofencing, and provider agreements.