Legal · Plain English
No-custody statement
The single most important thing to understand about how money moves through Dealium: it doesn't. Here is exactly what that means — in plain language, with nothing hidden in the fine print.
Last reviewed 11 July 2026 · Applies to the Dealium platform and app at app.dealium-ai.com
Plain-English summary
This page explains our non-custodial model in everyday words so it's easy to understand. It is a summary, not a contract — the binding terms are in the Terms of Service. If anything here appears to differ from the Terms, the Terms govern.
In one sentence
Dealium is a software provider. We build the workspace where a cross-border commodity deal is structured, verified, tracked, and settled. On the current pilot, custody is switched off: there is no deposit or release path in the product, so Dealium holds and moves nothing. In the model being built, a licensed third-party payment provider moves the money and Dealium only ever sends an instruction to release once you have approved it and the deal's conditions have been met. No provider is contracted, credentialled or live, and how each provider's collection account is structured — including whether it is segregated per deal — is not yet settled.
That single design decision is why Dealium is not a bank, not an e-money institution, not a money transmitter, and not an escrow agent. We do not take custody of client funds, so those roles do not apply to us.
What Dealium does — and never does
It helps to separate the two jobs in any trade: running the deal and moving the money. Dealium does the first. Licensed payment providers do the second.
- We do not hold your funds. Custody is switched off on the current pilot, so no deposit, release or balance exists in the product. Before any payment rail is enabled we will publish how that provider's collection account is structured, including whether it is segregated per deal.
- We do not transmit your funds. The payment provider, not Dealium, receives and pays out the money. Today there is no enabled provider, so parties settle directly with each other and record the evidence in the deal.
- We never convert your funds. Any currency exchange is performed by the payment provider, under their own terms and their rates — not by us.
- We do not move money. On the current pilot there is no release path at all. In the model being built, a release would require the deal conditions to be met and a Dealium operator to authorise it; your organisation has no approval step in that control today.
Who actually moves the money
In the model being built, every payment is executed by a licensed third-party payment provider rather than by Dealium. We do not name one here: none is contracted, credentialled or live, and whether Dealium or the client holds that contract is not yet settled. Your relationship for the money movement is with that provider and is governed by their terms and their regulatory permissions. Dealium speaks to payment providers through a single internal adapter. The supported list is one we maintain rather than a rail you bring, and no provider is contracted, credentialled or live on the current pilot.
In the model being built, the payment provider would receive, hold and pay out the funds, so the regulated activity — safeguarding, transmission, currency conversion — would sit with it. How its collection account is structured is not yet settled. Dealium sits alongside as the software that coordinates the deal.
When — and only when — Dealium acts on money
In the model being built, Dealium's role in a payment is limited to issuing a release instruction to the payment provider. There is no release path on the current pilot. A release instruction would be issued only when both of the following are true:
- A Dealium operator authorises it. Releases are authorised by Dealium operators, not by your organisation, subject to the second-operator control below.
- The deal conditions are met. The terms both sides accepted — proof of quality, shipping documents, milestones, and similar — have been satisfied and recorded.
To reduce the risk of error or fraud, a release instruction above a configured amount must be approved by a second Dealium operator: the operator who prepares it cannot be the one who approves it. This is a control inside Dealium's own operations — your organisation has no approval step in it today, and the threshold is counted per deposit record, so instructions split into smaller tranches are each assessed on their own. Every deposit, hold, and release is written to an append-only ledger, so there is always a clear, tamper-evident record of what happened and who authorised it.
What we mean by "escrow orchestration"
You'll see us use the word escrow orchestration. Because "escrow" carries a specific legal meaning, here is precisely what we mean — and what we do not mean.
| Legal escrow (what Dealium is not) | Escrow orchestration (what Dealium does) |
|---|---|
| A licensed escrow agent receives and holds the money in its own account until conditions are met. | Dealium does not receive or hold the money. On the current pilot it stays with the parties and their banks throughout. |
| The escrow agent is a custodian of client funds and is regulated as one. | Dealium is a software coordinator. It tracks the conditions and, once they are met and a Dealium operator authorises the release, would tell the payment provider to release. |
| Money moves because the agent decides the conditions are met. | Money would move when the recorded conditions are met and a Dealium operator authorises the release — the provider executes. No release path exists on the current pilot. |
In other words, "escrow orchestration" describes the coordination of a conditional payment — checking that the agreed conditions are satisfied and routing an authorised release instruction to the payment rail — without Dealium taking custody of the funds. It delivers the safety people want from escrow (money moves only when the deal is right) without Dealium becoming an escrow custodian.
Why this is good for you
Not holding your money isn't a limitation we work around — it's the point. It means:
- No custody risk on the pilot. With custody switched off, your funds are not exposed to Dealium's balance sheet or solvency. How any future provider's collection account is structured will be published before a rail is enabled.
- Banks move the money. On the current pilot that is the parties' own banks, under their own terms.
- You keep the record. Every term, document and payment confirmation is recorded on the deal, with a verifiable history of each step.
The short version
Dealium is software for running commodity deals. We do not hold, transmit, or convert your funds. On the current pilot the parties pay each other through their own banks and record the evidence in the deal. That is why we are not a bank, an e-money institution, a money transmitter, or an escrow agent — and why "escrow orchestration" means coordination, never custody.
Questions about how this applies to your deals? Talk to us, read the full security model, or review the binding Terms of Service.
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