Transactional infrastructure, non-custodial.
GhostPay Mesh provides technology infrastructure for orchestration, ledger, risk controls, reconciliation and transactional continuity. The company does not maintain payment accounts and does not custody user funds. In integrated financial flows, regulated services and monetary movement are executed by authorized partner institutions.
Regulatory positioning: GhostPay Mesh acts as a technology infrastructure provider and does not maintain payment accounts or custody user funds. In integrated flows, regulated financial services and monetary settlement are executed by authorized partner institutions. Regulatory framing depends on activities effectively performed in each operational model.
What we are and what we are not
We are
- Transactional technology infrastructure
- Orchestration and integration software
- Double-entry ledger for transactional states
- Transactional operational continuity
- Technical risk, limits and audit controls
- Integration with regulated institutions and providers
We are not
- A bank
- A financial institution or payment institution
- A custodial wallet or custodian of funds/e-money
- A direct Pix or DICT participant
- An entity offering its own monetary settlement guarantee
Regulatory perimeter and responsibilities
The architecture is designed to separate the technology layer from the execution of regulated financial services. Below is the public split of responsibilities, without license-like language.
- Law and regulation: payment and AML/CFT rules apply according to activities effectively performed by each actor in the chain.
- GhostPayMesh architecture: GhostPay Mesh operates software and transactional infrastructure, with ledger, risk, reconciliation and technical trails, without maintaining payment accounts and without custody of user funds.
- Provider responsibility: in integrated financial flows, regulatory KYC, AML/CFT obligations, monetary execution and settlement remain with authorized partner institutions.
- LGPD: transactional identity is minimized; tax IDs for settlement are collected only when needed and stored with protection controls.
- Pix / DICT: GhostPay Mesh is not a direct participant. Lookup, initiation and monetary movement, when applicable, occur through partner institutions.
Capabilities and operational scope
Institutional view of GhostPay Mesh public capabilities and split of responsibilities with regulated partner institutions.
| Capability | Status |
|---|---|
| Double-entry ledger and AVAILABLE / PROMISED / PENDING / HELD states | ● Implemented |
| Complete transactional continuity lifecycle in ledger (creation, transfer, hold, expiration, cancellation, redemption) | ● Implemented |
| Transactional integrity controls and duplicate-operation protection | ● Implemented |
| Limits, velocity and risk controls | ● Implemented · configurable policies |
| Audit trail and operational controls | ● Implemented |
| Official regulatory reporting | ○ Out of current scope GhostPayMesh provides operational data and audit trails; official regulatory reporting remains with institutions subject to those obligations. |
| Regulatory KYC | ● Via regulated partner GhostPayMesh has its own technical and onboarding controls, while regulatory KYC processes applicable to financial services remain with regulated institutions involved. |
| Pix / DICT | ● Via partner institution GhostPayMesh is not a direct Pix or DICT participant. Lookup, initiation and monetary movement, when applicable, occur through integrated providers/institutions. |
| Custody of funds | ○ Not performed by GhostPayMesh Funds remain in the infrastructure of the regulated institution responsible for the flow. |
AML/CFT and COAF: GhostPayMesh does not present itself as a financial institution or payment institution supervised by the Central Bank. Regulatory obligations applicable to partner institutions remain with those institutions, while GhostPayMesh maintains technical, contractual and legal controls applicable to its own activities.
Technical access
Access-controlled technical content · Request NDA-based release · Authorized access channel
This page is high-level technology and legal positioning. It is not a legal opinion, a Central Bank authorization, or a claim that GhostPay Mesh itself bears the full duties of a payment institution. Financial settlement, when it happens, is performed by the regulated partner.