On 27 October 2025, CurioInvest's post about launching a digital asset in 25Q4 went up. The post distilled the most common onboarding conversation into a checklist. Here's the expanded version — with the questions no vendor wants you to ask.
The base checklist (from the post)
1. Issuer entity — Swiss AG recommended; FINMA licensing flows through parent 2. Asset class — receivables, equity, debt, real estate each have different tax treatment 3. Investor base — qualified investors, professional clients, or both 4. Distribution — direct, through your own portal, or through a partner 5. Token standard — CMTAT v3.0.0 is the modern default; ERC-3643 if you need EVM-native 6. Chain — Polygon for EVM-native, TON via Jamton for distribution 7. Custody — CurioInvest-hosted multisig, or your own qualified custodian 8. Settlement — bank API oracle, or manual 9. Audit — Wake Arena for the framework, your own auditor for the rule 10. Compliance — FINMA-licensed parent for the institution, FinSA Art. 4 for the exemption
The questions no vendor wants you to ask
Q1. Where is the audit on the rule I'll be deploying? If the vendor says "our team's internal review," walk away. You need an independent audit with a published report.
Q2. What happens to my investors' tax position when the token is retired? Most vendors don't have an answer. The legal opinion is in the implementing ordinance of the DLT Act.
Q3. Who has admin rights on the CMTAT contract, and what's the multisig threshold? The answer should be: 2-of-3 CurioInvest, no single-signature admin, and admin actions on-chain.
Q4. What data leaves the Swiss data residency? It should be nothing. The dashboard, the AI extraction, the CMTAT — all in Switzerland or on-chain. The bank API and the oracle are the only third-party surfaces.
Q5. Can I export the full transfer log for my auditor? Yes — and the vendor should be able to demonstrate it in a 5-minute demo.
Q6. What's the impact on my existing credit facility covenants? A CMTAT is a receivable, not a sale, so it shouldn't trigger change-of-control clauses. But check with your bank.
Q7. How is the settlement-frozen state reflected in my accounting system? The CMTAT emits TransferWithData events. Your accounting system can subscribe via webhook.
Q8. What happens in a default scenario? The token is frozen (no transfer). The underlying claim is in the bankruptcy estate per the DLT Act 2026. The investor's claim is a secured creditor claim with the same priority as a paper-based receivable.
The expanded 25Q4 checklist
Beyond the 10 base items, in 25Q4 you should also confirm:
- A specific, named officer at the vendor for the integration (not a sales generalist)
- A written commitment that the audit + DP + rule sources are available on request
- A timeline for the Swiss DLT Act 2026 compliance update (which most vendors are still working on)
- A process for adding the CFOs existing legal counsel to the vendor's counsel network (so the legal review doesn't gate the project)
When 25Q4 is the right time
If you're in the 25Q4 window, the right approach is: 8-week pilot with one of your largest, simplest receivables. Get the CMTAT deployed, get one investor subscribed, get one settlement cycle completed. The 26Q1 DLT-Act amendment then lets you scale to 10+ receivables at a known cost.
If you're not in the 25Q4 window, the right move is to wait for 26Q2 and use the institutional experience that's accumulating in the meantime. The market is moving from exploration to implementation; that doesn't mean you have to.