Compliance Framework
Every layer of the Plume stack is designed around regulatory compliance. From onchain KYC/AML hooks to automated market surveillance, Kimber embeds compliance directly into the protocol layer rather than treating it as an afterthought.
FINRA Rule 5310 — Best Execution
Kimber's smart order routing engine performs real-time best execution analysis for every customer order. The system evaluates price, speed, likelihood of execution, and total costs across all compatible venues.
- Multi-venue price comparison for every order
- Execution quality statistics maintained and reviewed
- Regular and rigorous review of execution quality
- Documentation of routing decisions for audit
FINRA Rule 3110 — Supervision
Risk-based supervisory procedures leverage onchain transparency for enhanced monitoring. Automated surveillance systems detect potential market abuse in real-time, with escalation procedures for suspicious activity.
- Onchain market abuse detection models
- Automated alert generation and escalation
- Written supervisory procedures (WSPs)
- Annual supervisory system review and update
Regulation ATS
Plume ATS (Rooster) operates under Regulation ATS with Form ATS-N filed with the SEC. The system implements non-discretionary, automated standards for fair access and transparent operations.
- Form ATS-N filing with SEC
- Fair access standards under Rule 301(b)(5)
- Form ATS-R quarterly operational reports
- FINRA Rule 4552 weekly volume reporting
BSA/AML Compliance
Comprehensive BSA/AML program with onchain identity verification, transaction monitoring, and sanctions screening integrated at the protocol level.
- Customer Identification Program (CIP)
- Ongoing transaction monitoring and screening
- TRM Labs oracle-based sanctions compliance
- Suspicious Activity Report (SAR) filing procedures
SEC Rule 606 — Order Routing
Quarterly public disclosures on order routing practices provide transparency into how customer orders are handled and which venues receive order flow.
- Quarterly public disclosure reports
- Venue-by-venue routing statistics
- Payment for order flow disclosures
- Material aspects of routing relationships
17 CFR § 242.302 — Recordkeeping
The immutable blockchain ledger provides tamper-proof, time-sequenced records that satisfy SEC recordkeeping requirements. All ATS activity is permanently recorded onchain.
- Immutable onchain audit trail
- Time-sequenced transaction records
- Subscriber and order records maintained
- 3-year retention with 2-year immediate access