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 email@example.com to obtain the official statements.