Which regulator, at which stage

Under the emerging U.S. Clarity Act framework, Triangle's carbon credits are treated as digital commodities, which places them under CFTC oversight rather than SEC securities regulation.

The Act defines a digital commodity as a fungible digital asset that confers no rights to profits, liquidation proceeds or governance, a definition carbon credits satisfy. Triangle tokens confer no equity, profit-sharing or governance rights, which is the distinction that matters to banks and asset managers operating under securities law constraints.

As digital commodities they sit with the regulator that oversees oil, gold and agricultural futures, a familiar framework for institutional participants, and the combination with BMA regulation satisfies both offshore and U.S. institutional compliance requirements.

Classification under the Clarity Act depends on final rulemaking and on the facts of each issuance. Nothing here is legal advice, and counsel should confirm treatment before an institution relies on it.

Two ways across

Triangle supports minting digital assets from credits that originate in external registries such as Verra, Gold Standard or ACR. Two pathways are available depending on the client's needs.

Mirrored assets are Triangle tokens representing credits held in external registries. They work the way American Depositary Receipts do: an instrument listed on one venue representing ownership of a holding on another. No assets are allocated or distributed to clients until title transfers to the Triangle FBO account or the underlying asset is received.

DABA and DAIA

The BMA distinguishes between two frameworks governing digital asset activity, and the distinction matters to anyone engaging with Triangle's minting and registry operations.

Under the Digital Asset Issuance Act 2020, the BMA regulates minting or offering a new digital asset to the public as a regulated issuance event. An issuance document, prospectus in style, discloses technical standards, the smart contract, the hard cap and the rights attached to the asset.

The infrastructure used to facilitate minting and listing sits under DABA 2018. Operating a platform to onboard users, process subscriptions or facilitate minting, for yourself or others, is digital asset business; Triangle holds a Class M licence. Clients can use qualified custodians, self-custody or Triangle's own arrangements.

The BMA takes a substance-over-form approach. If staging for minting looks like a public offering, it is regulated under DAIA. Triangle, licensed under DABA, provides the platform that mints tokens for the clients it advises.

Regulated registry, traditional registry

Both hold a record. Only one produces something a bank can hold.