✦ Architecture
Software, not custodian.
Perpblock is a SaaS execution layer that does not take custody of client assets. Your client assets remain at the qualified custodian. We connect via a trade-only API to place orders. The architecture is consistent with the SEC's 2023 position on non-custodial software providers and matches the structure 47% of US family offices use to hold digital assets directly.
Client assets
At qualified custodian
Read-only API key
No withdrawal · no transfer
Perpblock execution engine
Order placement only
Settlement
At custodian · not Perpblock
On-chain anchor
Base mainnet · within 15 seconds
At no point does Perpblock take possession of the asset.
✦ The single legal question
The single legal question, answered.
The question every counsel asks first: does this platform have custody of client assets? The answer is no — structurally, by design, at every layer.
Perpblock never holds the asset. Perpblock never holds the private key. Perpblock never holds a withdrawal-capable credential. We hold one thing: a trade-only API key that can place orders against the asset's actual custodian. That key, by the custodian's own permission system, cannot withdraw, cannot transfer between accounts, and cannot access wallet private keys.
Even if Perpblock were compromised tomorrow, the worst-case outcome is unauthorized trade placement on the client's behalf — not asset removal.
The architecture is not "trust-based non-custodial." It is structurally non-custodial. We cannot take custody. The custodian's permission system prevents it.
✦ SEC 2023
Regulatory context.
The SEC's 2023 guidance distinguishes between custodial services (which require registration as a custodian and trigger qualified-custodian rules under the Investment Advisers Act) and non-custodial software providers (which do not, because they do not have access to client assets in a manner that creates custody risk under the Adviser Act's definition).
1. No control over client assets.
The trade-only API does not include withdrawal permissions. Withdrawal capability is the controlling definition of "custody" under most regulatory frameworks. We lack it by design.
2. No discretionary authority to remove or transfer assets.
Perpblock cannot move assets between accounts, into other clients' accounts, or off-platform. The custodian's API scope is the binding constraint.
3. No commingling.
Each client's relationship with the custodian is direct. Perpblock does not pool client assets, does not operate omnibus accounts, and does not net trades across clients.
Custody, under the regulatory definition, requires the ability to control the asset. We don't have it. We can't have it. The architecture forbids it.
No control over client assets
Trade-only API cannot withdraw.
No discretionary transfer authority
Cannot move assets between accounts or off-platform.
No commingling
Each client relationship is direct. No omnibus accounts.
Structurally non-custodial. The architecture forbids it.
What Perpblock is
A SaaS execution platform.
A software-as-a-service vendor to RIAs, family offices, and institutional clients.
A non-discretionary execution engine operating under client-specified parameters.
A reporting and verification surface (on-chain anchoring, quarterly transparency pack).
What Perpblock is not
Not a broker-dealer.
Not a money transmitter.
Not a qualified custodian.
Not a registered investment adviser.
Not an exchange.
Not a fund. No commingled pool.
✦ Regulatory positioning
Plain-language regulatory positioning.
We are software. The legal posture is the posture of software — not the posture of a financial counterparty.
US. Operating as non-custodial software under SEC 2023 guidance. Perpblock does not maintain investment adviser registration because we do not provide investment advice. We provide a software platform that executes per client-specified parameters.
Outside the US. We do not currently maintain regulatory registration in non-US jurisdictions. For institutions operating under MiCA, MAS, ADGM, or other regional frameworks, the question is the regulatory posture of the client's custodian and AIFM, not Perpblock's.
Sanctioned jurisdictions. We do not onboard clients from OFAC-sanctioned jurisdictions. The full restricted list is in the DDQ.
KYC. For institutional onboarding, we conduct enhanced due diligence on the institution. For retail and prosumer onboarding, we rely on the custodian's KYC. We are not the KYC-of-record for any user.
Posture is non-custodial software with US domicile and US-aligned compliance. Anything more nuanced is a conversation with counsel.
✦ Custodians
Who actually holds the assets.
Coinbase / Coinbase Prime
Qualified custodian
Kraken / Kraken Institutional
Qualified custodian
Gemini
Qualified custodian
Binance / Binance Institutional
Exchange custody
Bybit
Exchange custody
OKX
Exchange custody
BloFin / BloFin Institutional
Exchange custody
Fireblocks
Institutional self-custody
Self-custody EVM wallets
DEX execution · client retains seed
Client chooses the custodian relationship. Perpblock executes against whichever custodian the client uses.
✦ Execution flow
What actually happens on a trade.
Strategy identifies execution opportunity per enrolled strategy parameters.
Pre-action sanity check validates against profile, leverage acknowledgement, fee floor, and policy rules.
Execution module submits order via trade-only API to client's custodian.
Custodian executes order against its own order book or the relevant venue.
Fill confirmation returns to Perpblock via the API.
Trade hashed and anchored on-chain (Base mainnet) within 15 seconds.
Audit log records event: timestamp, user attribution, strategy reference, anchor hash.
✦ Segregation
Architectural separation between Perpblock and the asset.
API permission scope
The custodian's API permission system blocks withdrawal, transfer, and wallet-key access regardless of any Perpblock configuration. We could not withdraw assets even if we attempted to.
No omnibus accounts
Each client has a direct relationship with their custodian. We do not operate pooled accounts. Trades are placed on each client's individual account.
No netting
We do not net opposing trades across clients. Each client's trade is independent. Each fill is the custodian's fill, not Perpblock's internalized cross.
No proprietary trading
Perpblock does not operate proprietary trading accounts. We do not trade our own capital alongside or against client capital.
The separations are structural, not policy-based. They follow from the architecture, not from a Perpblock employee handbook.
✦ For counsel
What counsel asks.
✦ Resources
For your counsel.
Institutional DDQ package
Architecture summary memo (PDF)
External counsel regulatory memo (PDF)
SOC 2 Type I report
SOC 2 Type II progress update
Quarterly transparency pack
On-chain anchoring technical documentation
Direct line for counsel-level questions: counsel-relations@perpblock.com
✦ Get started
Request the DDQ.
Institutional access begins with a 30-minute call with the founder. We use the call to determine whether Perpblock fits your structure and to scope the diligence process.