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Wat is Attrace from a legal perspective

Legally the Attrace ecosystem is perceived as follows:

  • Attrace offers a decentralised affiliate marketing platform by means of its native blockchain (Attrace Network), bringing together parties who publish marketing communications/advertisements (Publishers) and parties who offer products or services (Merchants).
  • Such Publishers and Merchants can enter into an agreement via the Attrace Network where the Publisher agrees to advertise the products or services of the Merchants in exchange for a commission paid per lead (“click”) leading to an actual sale for the Merchant.
  • Attrace uses blockchain technology to register both the leads as well as the actual sales generated by the relevant Publisher (in a smart contract).
  • Attrace issued a token (ATTR) that can be used to interact with the Attrace Network, for example, to register agreements and the (status of) leads generated by a Publisher.
  • This token is solely used to work as a measurement / audit tool "under the hood" of the Attrace network.

Two questions have come up with respect to certain of Attrace’s activities

  • Does Attrace’s current payment system trigger any license obligations pursuant to the Dutch implementation of the European Payment Services Directive ((EU) 2015/2366, PSD 2)?
  • Do the services provided by Attrace with respect to the ATTR qualify as the offering of a crypto currency wallet or crypto currency exchange, which would trigger a registration obligation pursuant to the Dutch implementation of the European Fifth Anti Money-laundering Directive ((EU) 2018/843, 5AML)?

Attrace is not a payment provider nor a crypto currency exchange

The Attrace ecosystem has been validated by two Dutch law firms as neither a payment provider nor a crypto currency exchange.

Please reach out to info@attrace.com to obtain the official statements.