Denaro Pay is a financial technology company that provides a software platform enabling users to hold, send, receive, and earn yield on USDC, and to access a Visa debit card issued by Marqeta and automated trading services via CREST AI. Denaro Pay is not a broker-dealer, investment adviser, or registered investment company.
Issuer: USDC (USD Coin) is a stablecoin issued by Circle Internet Financial, LLC, a registered Money Services Business under FinCEN. Circle is not affiliated with Denaro Pay.
Backing: USDC is intended to be redeemable one-to-one with U.S. dollars. Circle represents that each USDC is backed by U.S. dollar reserves or short-duration U.S. Treasury instruments held in regulated U.S. financial institutions. Circle publishes monthly attestations of these reserves conducted by Grant Thornton LLP. Denaro Pay does not independently verify the composition or adequacy of Circle's reserves.
Risks: USDC may lose its peg in extreme market conditions. Circle's banking relationships, while currently with regulated U.S. institutions, may be disrupted. Denaro Pay does not guarantee the redeemability of USDC and is not liable for losses arising from USDC depeg events or Circle operational failures.
Custody: Your USDC is held in your individual Circle Programmable Wallet on Coinbase Base, custodied at Coinbase Prime. Your balance is segregated from Denaro Pay's balance sheet and from other users' balances. In the event of Denaro Pay's insolvency, your USDC should not constitute property of Denaro Pay's estate; however, the legal treatment of digital assets in insolvency proceedings remains evolving.
CREST AI is not investment advice. CREST AI is an automated execution tool. It does not constitute a managed investment service, broker-dealer activity, registered investment advisory service, or investment advice under the Investment Advisers Act of 1940. Denaro Pay is not registered as an investment adviser with the SEC or any state securities regulator.
Performance Fee Disclosure: The 10% performance fee charged by Denaro Pay on net trading profits applies exclusively to United States residents operating funded prop firm accounts connected via Tradovate or Rithmic OAuth. International clients and live capital clients retain 100% of their trading profits. The performance fee is not charged on losing trades or unrealized gains.
Denaro Pay Incorporated operates as a Money Services Business (MSB) registered with the Financial Crimes Enforcement Network (FinCEN), an agency of the United States Department of the Treasury. As an MSB, Denaro Pay maintains a written Bank Secrecy Act (BSA) compliance program that includes:
Know Your Customer (KYC) Program: All customers are required to complete identity verification via government-issued photo ID and liveness check through Persona before accessing the platform. Customer identification information is collected, verified, and retained in compliance with FinCEN Customer Identification Program requirements.
Anti-Money Laundering (AML) Program: Denaro Pay monitors all transactions for suspicious activity using Chainalysis blockchain analytics and Sardine behavioral AI. Suspicious activity is reported to FinCEN via Suspicious Activity Reports (SARs) as required by the BSA. Currency transaction reports (CTRs) are filed for applicable cash-equivalent transactions.
OFAC Sanctions Compliance: Denaro Pay screens all customers and transactions against the OFAC Specially Designated Nationals (SDN) list, the Consolidated Sanctions List, and other applicable watchlists. Accounts matching sanctions designations are blocked automatically without notice, as required by applicable law. Denaro Pay does not provide services to residents of OFAC-sanctioned jurisdictions.
The 5.20% APY yield offered through Denaro Pay is generated by routing USDC into Morpho Blue permissionless lending markets on Coinbase Base. This yield is variable and is determined by market supply and demand conditions in the Morpho Blue protocol. The yield rate may increase or decrease at any time without notice.
Participation in the yield program carries risks, including: smart contract risk in the Morpho Blue protocol; liquidity risk in extreme market conditions; and the risk that borrowers may be liquidated in ways that temporarily affect available liquidity. Denaro Pay does not guarantee any yield rate or guarantee the return of principal.
Denaro Pay does not provide services to individuals located in, or residents of, the following jurisdictions: Cuba, Iran, North Korea, Syria, Russia, Belarus, and any other jurisdiction subject to comprehensive U.S. sanctions. Additional jurisdictions may be blocked based on applicable law and regulatory guidance. Denaro Pay reserves the right to add or remove supported jurisdictions at any time.
Regulatory inquiries should be directed to: Jeffrey Terranova, Founder, Denaro Pay Incorporated, New York, NY. Email: Jeffrey@denaropay.com.