254900DKB8E8Z59ONQ39 2026-01-01 2026-12-31

Table of Contents

General Information
SUMMARY
Part A - Information about the Offeror or the Person Seeking Admission to Trading
Part B - Information about the Issuer, If Different from the Offeror or Person Seeking Admission to Trading
Part C - Information about the Operator of the Trading Platform
Part D - Information about the Crypto-Asset Project
Part E - Information about the Offer to the Public of Crypto-Assets or their Admission to Trading
Part F - Information about the Crypto-Assets
Part G - Information on the Rights and Obligations attached to the Crypto-Assets
Part H - Information on the underlying technology
Part I - Information on Risks
Part J – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
General Information
00: Table of content
true
01: Date of notification

2026-05-06

02: Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114

This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The person seeking admission to trading of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

03: Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114

This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

04: Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114

The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid.

05: Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114

Not applicable

06: Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114

The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

SUMMARY
07: Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114

Warning

This summary should be read as an introduction to the crypto-asset white paper.

The prospective holder should base any decision to purchase this crypto-asset on the content of the crypto-asset white paper as a whole and not on the summary alone.

The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law.

This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.

08: Characteristics of the crypto-asset

$GAI is the primary protocol asset of the Gency AI sovereign advertising network, issued primarily on BNB Smart Chain (BSC) with additional deployment on Base. The token is classified as a crypto-asset in the “Other” category under MiCA Regulation (EU) 2023/1114 and does not represent debt, equity, ownership, governance rights over Fort Limited, profit-sharing, or any claim against Fort Limited or any pool of assets.

$GAI functions as the coordination, staking, and incentive asset of the Gency AI protocol, enabling resource access, network security, and governance participation, while all payments and settlement across the network are conducted in stablecoins.

Structural protocol features, including market buyback and burn mechanisms, and treasury pool contributions, are built into the protocol design and do not confer distribution rights on passive token holders.

09: Further information about utility tokens

Not applicable

10: Key information about the offer to the public or admission to trading

This white paper has been prepared for the purposes of seeking admission to trading on multiple crypto-asset trading platforms. The Issuer seeks to ensure broad accessibility for the $GAI token by pursuing admission to trading across suitable venues.

Part A - Information about the Offeror or the Person Seeking Admission to Trading
A.1: Name

Fort Limited

A.2: Legal form

Company limited by shares

A.3: Registered address

ICS Corporate Services (BVI) Limited, Sea Meadow House, P.O. Box 116, Road Town, Tortola, British Virgin Islands

A.4: Head office

ICS Corporate Services (BVI) Limited, Sea Meadow House, P.O. Box 116, Road Town, Tortola, British Virgin Islands

A.5: Registration date

2026-03-16

A.6: Legal entity identifier

254900DKB8E8Z59ONQ39

A.7: Another identifier required pursuant to applicable national law

2203906

A.8: Contact telephone number

+1 9294462610

A.9: E-mail address

official@gencyai.io

A.10: Response time (days)

001

A.11: Parent company
A.12: Members of management body

1
SYARMIN BURHAN
4498 Davis Drive, Markham, Ontario L3P 2M4, Canada
Director

A.13: Business activity

Fort Limited develops an AI-driven, privacy-preserving advertising infrastructure that separates data ownership from usage rights and enables advertisers to “buy results, not data” via executable consent, encrypted audience targeting and measurement, and programmable, receipt-backed settlement across Web2 and on-chain channels. Its principal activities center on providing an ecosystem protocol and tools (including advertiser consoles, publisher SDKs, and compute/audit node infrastructure) that coordinate advertisers, media platforms, data partners, and users under a verifiable, auditable growth engine. The project primarily serves digital advertising and growth markets such as ecommerce, retail media, subscription apps, and on-chain membership and minting, targeting global advertisers, agencies, media platforms, and related data/computing partners operating across both traditional web and blockchain environments.

A.14: Parent company business activity
A.15: Newly established

true

A.16: Financial condition for the past three years

Not applicable as the offeror or person seeking admission to trading was established within the past three years.

A.17: Financial condition since registration

The offeror is a relatively new British Virgin Islands business company with a limited operating and financial track record. No audited financial statements or granular balance sheet, cash flow, or profitability data are publicly disclosed at this stage. The project is currently in a foundational development phase (2025 Q4–2026 Q2), focused on deploying core protocol capabilities and launching an initial ecosystem, rather than on mature revenue generation or long-term margin optimization; therefore, historical performance data are inherently constrained. Available non-financial KPIs emphasize product traction and network usage rather than formal financial metrics, including a reported global user base of over 400,000 users, more than $500,000 in transaction volume processed, and trust from over 200 clients, reflecting early but material adoption of the platform’s advertising and data infrastructure. Capital resources consist primarily of equity or token-related backing from a broad group of named investors and partners, with proceeds earmarked for continued protocol development, infrastructure, and ecosystem growth. The size, structure, and runway implications of this capital base are not publicly quantified and, as a young entity, there is no guarantee all roadmap milestones will be achieved or that sufficient funding will be available for full execution.

Part B - Information about the Issuer, If Different from the Offeror or Person Seeking Admission to Trading
B.1: Issuer different from offerror or person seeking admission to trading

false

B.2: Name
B.3: Legal form
B.4: Registered address
B.5: Head office
B.6: Registration date
B.7: Legal entity identifier
B.8: Another identifier required pursuant to applicable national law
B.9: Parent company
B.10: Members of management body
B.11: Business activity
B.12: Parent company business activity
Part C - Information about the Operator of the Trading Platform
C.1: Name
C.2: Legal form
C.3: Registered address
C.4: Head office
C.5: Registration date
C.6: Legal entity identifier
C.7: Another identifier required pursuant to applicable national law
C.8: Parent company
C.9: Reason for crypto-asset white paper preparation
C.10: Members of management body
C.11: Operator business activity
C.12: Parent company business activity
C.13: Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
C.14: Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
Part D - Information about the Crypto-Asset Project
D.1: Crypto-asset project name

Gency AI

D.2: Crypto-asset name

Gency AI Token

D.3: Abbreviation

$GAI

D.4: Crypto-asset project description

Purpose and Goals:
Gency AI is building an infrastructure layer for advertising that separates data ownership from usage rights, allowing advertisers to access encrypted, permissioned data without ever acquiring raw user data. Its goal is to let advertisers “buy results, not data,” enforce compliance at the system level, and create a growth engine where users, media, and service providers share in verifiable, receipt-backed revenues.

Key Features and Operation:

  • Consent-as-Code (CCL) compiles user and regulatory permissions (scope, duration, jurisdiction, privacy limits) into machine-readable policies that gate all computations while raw data remains off-chain.
  • Encrypted Segment Query (ESQ) brings computation to the data using PSI, MPC, TEE, and differential privacy, enabling audience targeting and measurement in encrypted form without exposing full datasets.
  • Verifiable Usage Receipts (VUR) record every data query and campaign outcome as cryptographically verifiable receipts, forming a shared, tamper-proof log of “what happened.”
  • A Programmable Settlement Graph (PSG) uses these receipts to automate escrow release, revenue splits, streaming payments, and user rewards in stablecoins, shrinking settlement from months to T+0/T+1.
  • The GAI token coordinates staking, slashing, compute and privacy-budget prioritization, and protocol governance, aligning long-term network incentives while real cash flows settle in stablecoins.
D.5: Details of all natural or legal persons involved in implementation of crypto-asset project

1
Development team
Tan Chee Hoe

2
Development team
Syarmin Burham

D.6: Utility token classification

false

D.7: Key features of goods or services for utility token projects

Not applicable as $GAI is not a utility token as defined under MiCA.

D.8: Plans for the token

Achievements

Gency AI has defined a fixed-cap 1,000,000,000 GAI token as the coordination layer of its network, specifying its role in staking, slashing, governance, pricing of privacy and compute resources, and value recycling via buyback-and-burn and penalty mechanisms. It has published a detailed token allocation and emission model focused on ecosystem and node incentives, community treasury, and long-vested team/advisor allocations, and outlined how stablecoin-funded campaign flows integrate with GAI for burns, rebates, and governance-aligned public goods funding.

Future Milestones (Indicative, subject to update)

  • Starting Phase (Seed-Validation) – Target timing: TBD 2026
    Launch initial “lighthouse” use cases (ecommerce loops, retail media, subscription apps, on-chain membership/minting) with goals of ≥95% Verified Use Receipt (VUR) coverage, ≥80% T+1 settlement across 3–5 major media partners and 1–2 trusted compute supply chains, and compatibility badges for connectors and compliance templates.
  • Expansion Phase (Scaling) – Target timing: TBD 2026-2027
    Integrate CTV/OTT and international channels, onboard third‑party auditing and anti‑fraud partners, open node and connector markets, and introduce dry‑run capacity bidding in the Console to create a transparent resource marketplace for peak demand.
  • Autonomous Phase (Governance Maturity) – Target timing: TBD 2027+
    Transition key protocol parameters (including k‑anonymity, ε limits, burn ratios, and deprecation timelines) to on‑chain governance controlled by GAI holders; launch ecological grants and “work rebate” standards for long‑term public goods; and reach a state where the protocol can operate stably even if the founding team exits day‑to‑day operations.

Token Role (GAI)

GAI is the network’s coordination token: it is staked by participants (advertisers, media, compute and audit nodes) for priority access and security; used as a slashing reserve for misconduct; governs protocol parameters, fee structures, and public‑goods funding; and captures value through buyback‑and‑burn and rebate mechanisms, while underlying campaign cash flows remain anchored in stablecoins.

D.9: Resource allocation
  • Financial resources: Gency AI has secured $20 million in funding from a round that included participation from institutional investors Y&Z Capital, KDA Venture, INK Foundation, Riverpark, Arksteam, MH Ventures, ViaBTC and Basics Capital. The capital is allocated toward scaling the decentralized advertising execution and settlement network, hardening the privacy-preserving computing stack, and accelerating product deployment and ecosystem partnerships across North America, Asia, and Europe.
  • Human resources: Tan Chee Hoe(Cofounder), with a background spanning co-founding roles at Sky Venture Labs, Blockhire, Metahunter, Payra, and Findwork; and Syarmin Burham (Cofounder), with a track record of leading strategic initiatives, operational excellence, and ecosystem development at Gency AI, Zomato, and Wipro.
  • Technological resources: Gency AI has developed a sovereign advertising network built around four core protocol components: (i) a Consent-as-Code (CCL) control layer that encodes data permissions, usage constraints, and compliance requirements into enforceable, machine-readable policies; (ii) an Encrypted Segment Query (ESQ) privacy computing layer integrating technologies such as PSI, MPC, and TEE to enable encrypted audience targeting and measurement without exposing raw data; (iii) a Verifiable Usage Receipts (VUR) mechanism that records all data usage and campaign outcomes as cryptographically verifiable proofs; and (iv) a Programmable Settlement Graph (PSG) that automates escrow release, revenue distribution, and settlement processes based on verified receipts via smart contracts.
D.10: Planned use of collected funds or other tokens

Gency AI plans to use early-stage $GAI issuance and treasury allocations to bootstrap the network and fund ecosystem public goods, including compliance templates, connector development, audit toolchains, and antifraud datasets, as well as grants, partnerships, and liquidity managed by the DAO. Network fees and campaign flows in stablecoins are partly routed to a treasury and insurance pool, with additional $GAI used for buyback-and-burn and for rewarding high-quality nodes, connectors, anti-fraud challengers, and public R&D and governance contributions.

Part E - Information about the Offer to the Public of Crypto-Assets or their Admission to Trading
E.1: Public offering or admission to trading

ATTR

E.2: Reasons for public offer or admission to trading

Enable EU market access for $GAI holders.

E.3: Fundraising target

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.4: Minimum subscription goals

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.5: Maximum subscription goals

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.6: Oversubscription acceptance

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.7: Oversubscription allocation

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.8: Issue price

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.9: Official currency determining issue price

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.10: Subscription fee

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.11: Offer price determination method

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.12: Total number of offered or traded other tokens

1,000,000,000

E.13: Targeted holders

All

E.14: Holder restrictions

There are no restrictions.

E.15: Reimbursement notice

There are no reimbursement rights.

E.16: Refund mechanism

There is no refund mechanism.

E.17: Refund timeline

There is no refund mechanism.

E.18: Offer phases

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.19: Early purchase discount

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.20: Time-limited offer

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.21: Subscription period beginning

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.22: Subscription period end

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.23: Safeguarding arrangements for offered funds or other tokens

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.24: Payment methods for other token purchase

Fiat or other crypto-assets.

E.25: Value transfer methods for reimbursement

There are no reimbursement rights.

E.26: Right of withdrawal

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.27: Transfer of purchased other tokens

Via crypto-asset trading platforms on which $GAI is admitted to trading.

E.28: Transfer time schedule

There is no relevant time schedule.

E.29: Purchaser's technical requirements

There are no technical requirements.

E.30: Other token service provider (CASP) name
E.31: CASP identifier
E.32: Placement form

NTAV

E.33: Trading platforms name

Fort Limited is seeking admission to trading for the $GAI token across multiple trading platforms, including:

  • Payward Global Solutions Limited
  • Gate Technology Limited
E.34: Trading platforms market identifier code (MIC)

PGSL
N/A

E.35: Trading platforms access

Online via the platform

E.36: Involved costs
E.37: Offer expenses

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.38: Conflicts of interest

The issuer is not aware of any potential conflict of interest of the persons involved in its admission to trading.

E.39: Applicable law

Not applicable. This white paper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

E.40: Competent court

British Virgin Islands (BVI)

Part F - Information about the Crypto-Assets
F.1: Other token type

The Token is a crypto-asset under Regulation (EU) 2023/1114 of the European Parliament and of the Council which is not an e-money token, an asset-referenced token or a utility token, each as defined under such Regulation. Therefore, it falls in the "Other" category.

F.2: Other token functionality
  • Governance/voting: Used as the governance token to vote on protocol parameters (e.g., k-thresholds, ε caps, penalty coefficients), fee structures, compatible assets, and public-goods outcomes. Holding and using $GAI gives governance participation rights and potential governance-related rewards.
  • Staking collateral: Used for staking by key ecosystem participants (e.g., large advertisers and distribution channels) to access reserved resources and accelerated strategy-review lanes; staked $GAI can be penalized (slashed) for rule violations, so it functions as collateral in the coordination layer.
  • Access/priority to network resources: Used in pricing and prioritizing access to privacy budget and compute capacity on the execution layers, so holding/spending or staking $GAI can influence priority and resource allocation within protocol-defined limits (without overriding compliance constraints).
  • Incentive and reward medium: Distributed as rewards to nodes, connectors, anti-fraud challengers, and research/governance contributors, with allocations weighted by verifiable usage/result receipts (VUR) and successful audits or challenges; contributors can earn $GAI for validated work and public-goods outcomes.
  • Penalty and insurance mechanism: Used as a structured penalty reserve for misconduct (penalties and slashing are applied in $GAI and can be burned or directed to insurance/treasury pools), so it underpins the protocol’s enforcement and risk-buffer mechanisms.
  • Value recycling and burn: A portion of network fees (charged in stablecoins on verifiable ad spend) is used for market buyback and burn of $GAI, another portion funds the treasury and insurance pools, and another is redistributed as “work rebates” to high-quality contributors; this creates structural demand and burn for $GAI but does not describe a pro-rata dividend or revenue right for passive holders.
  • Explicit rights not described: Documentation reviewed does not describe $GAI as conferring equity, ownership, or fixed revenue/dividend rights in any legal entity; its described rights are limited to protocol-level governance, access/prioritization, staking-based participation, and earning potential through contribution.
F.3: Planned application of functionalities

$GAI token is currently in a pre-launch stage. Accordingly, the functionalities described for the token are not active prior to the token’s launch. The application of such functionalities is planned to commence following the token generation event. All planned functionalities for $GAI are described in Section D.8 ("Plans for the token").

F.4: Type of crypto-asset white paper

OTHR

F.5: Type of submission

NEWT

F.6: Other token characteristics

$GAI is a protocol coordination token used for staking, governance, resource allocation and incentive alignment within the Gency AI network. Unlike traditional AdTech systems that rely on opaque data aggregation and trust-based reporting, $GAI is intended to function as the economic backbone of a decentralized advertising infrastructure that aligns advertisers, publishers, AI agents and users through cryptographic guarantees, on-chain policy enforcement and measurable outcomes.

$GAI is issued primarily on BNB Smart Chain (BSC), with additional deployment on Base, supporting multi-chain accessibility and broad ecosystem integration. The initial estimated market capitalization of the token is $1 billion.

$GAI enables staking-based participation, governance and resource prioritisation within the protocol, while all payments and settlement across the network are conducted in stablecoins.

Functionally, $GAI serves as the core asset underpinning the protocol’s four operational modules: the Policy Identity layer, which enables on-chain data permission management and traceable data authorization; the ESQ Privacy Computing Layer, which supports encrypted computation through TEE, PSI, and MPC technologies; the PSG Clearing and Settlement Protocol, which converts advertising outcomes into on-chain verifiable credentials and automates revenue distribution via smart contracts; and the AI Optimization Engine, which powers advertising strategy prediction, audience matching, and campaign optimization in an anonymous and encrypted environment.

The token facilitates access to protocol services and network participation within the Gency AI ecosystem. It is intended to operate as the incentive and coordination layer across advertiser, publisher, and AI agent interactions, supporting protocol fee mechanisms, enabling staking-based access and governance participation, and coordinating the execution of settlement processes for verifiable advertising outcomes, which are carried out via the protocol’s settlement mechanisms. Detailed provisions regarding value accrual mechanisms, staking, and full tokenomics are specified in the project’s whitepaper but are not yet reflected in public market data.

F.7: Commercial name or trading name

Gency AI

F.8: Website of the issuer

https://gencyai.io/

F.9: Starting date of offer to the public or admission to trading

2026-06-04

F.10: Publication date

2026-06-04

F.11: Any other services provided by the issuer

Nothing other than already stated in the whitepaper.

F.12: Language or languages of white paper

English

F.13: Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available

L9LFLSS9P

F.14: Functionally fungible group digital token identifier, where available

FTB0X3SC0

F.15: Voluntary data flag

false

F.16: Personal data flag

true

F.17: LEI eligibility

true

F.18: Home member state

Ireland

F.19: Host member states

Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden.

Part G - Information on the Rights and Obligations attached to the Crypto-Assets
G.1: Purchaser rights and obligations

For Gency AI’s $GAI token, ownership/economic rights are limited to holding a scarce coordination and utility token; all commercial cash flows (ad spend and user rewards) are settled in stablecoins such as USDC, while $GAI is used for staking, slashing, governance and value recycling (including burns), so it does not represent a direct claim on protocol revenues or dividends.

Access/utility arises from using $GAI to stake and operate compute/audit/anti‑fraud nodes, to access priority privacy/computation capacity, to open fast‑settlement channels, and to obtain rebates or participate in value recycling mechanisms, while end‑users are rewarded in stablecoins and may optionally use $GAI for governance input.

Voting/governance rights include using $GAI as the voting instrument over protocol parameters, fee structures, compatibility matrices, public‑goods funding, and upgrades, initially via multisig/timelock and later via full on‑chain governance, with some non‑binding governance input also available to users.

Holder obligations are primarily protocol‑level: node operators and some ecosystem participants must stake $GAI and are subject to slashing and potential blacklisting for misconduct, while tokenholders participating in governance are expected to align with an “evidence‑first” and compliance‑oriented framework; there is no indication of additional legal or contractual obligations solely from holding the token.

G.2: Exercise of rights and obligations

General note

Gency AI is pre-launch; the whitepaper defines what $GAI is used for (staking, governance, coordination) but does not yet specify concrete UI flows, URLs, or smart contract addresses for exercising these rights. All procedures below are therefore framed as “once the corresponding module is live”, based on the roles and rights described in the whitepaper.

1) Marketplace / Access to Network Services

Relevant rights: using $GAI to prioritize access to privacy budget, compute capacity, and strategy review lanes; advertisers/agencies purchase PCC with stablecoins, with part converted into $GAI burn/lock; media/platforms may stake for fast settlement; compute/audit nodes must stake to run jobs.

A. As an advertiser / agency

  1. Obtain a compatible wallet and acquire the required stablecoin (e.g., USDC) and, if required by the interface, some $GAI for priority features.
  2. Connect your wallet to the Gency AI advertiser portal or dashboard (once available via the main site or docs).
  3. Create or import an advertiser account and complete any business KYC/KYB requested (see KYC/AML section).
  4. Fund your account with stablecoins, then follow the UI to purchase PCC credits; the protocol will internally route part of this into $GAI burn/lock per the economic design.
  5. (Optional) If the portal exposes “priority access” or “additional dry-run capacity” features, agree to stake the indicated amount of $GAI via the staking interface to obtain enhanced queue priority and capacity.
  6. Configure campaigns; the system will allocate privacy budget and compute according to protocol rules and your staked status.
  7. When campaigns complete or the staking term ends, use the same interface to request unstaking/withdrawal of $GAI, subject to any penalties for rule violations defined by the protocol.

B. As a media / platform participant

  1. Integrate the Gency AI SDK with your media platform (no token holding required for basic SDK integration).
  2. If you want fast-settlement channels, access the settlement/finance section in the portal and agree to stake the required $GAI amount for those channels.
  3. Configure where you receive settlement (stablecoin address); execute traffic and reporting as usual.
  4. Monitor any $GAI rebate programs tied to VUR quality and claim rebates via the portal when available.
  5. Be aware that if disputes are lost under protocol rules, part of your staked $GAI can be slashed; you will see slashing details in the claims/settlement module.

C. As a compute / audit / anti-fraud node operator

  1. Review technical docs for node requirements (hardware, TEE/PSI/MPC stack, remote attestation).
  2. Set up the node software and complete remote attestation per the instructions to prove a trusted execution environment.
  3. Acquire and fund a wallet with $GAI and required stablecoins for gas/fees, then register the node in the protocol’s node registry, staking the required $GAI to become eligible for jobs.
  4. Opt into job queues (compute, audit, anti-fraud) via the node dashboard; the protocol will assign work and track performance.
  5. Receive primary rewards in stablecoins plus any decaying $GAI incentives; claim them via the node dashboard or directly from the smart contract, as documented.
  6. If you are found malicious (e.g., incorrect execution, denial of service, falsified proofs, double signing), expect automatic stake slashing and potential blacklisting per protocol rules; you will not be able to reclaim the slashed portion.

2) Staking Rights (General)

$GAI “powers staking, slashing, pricing of privacy and compute resources, governance decisions, and value recycling.” Compute/audit/anti-fraud nodes must stake; advertisers and media can stake for priority and settlement features.

Generic staking procedure (once contracts/UI are live):

  1. Confirm your role (node operator, advertiser, media partner) and the relevant staking pool/type (e.g., node staking vs. priority access).
  2. Connect a supported wallet holding sufficient $GAI to the official staking interface linked from the main site or docs.
  3. Select the specific staking program, review its terms (lock-up, slashing conditions, expected use: priority access, fast settlement, node participation), and approve contract spend if prompted.
  4. Confirm the transaction on-chain to lock the selected amount of $GAI into the staking contract.
  5. Monitor your stake status, rewards, and any penalties/slashing via the dashboard or explorer; act according to any operational requirements (e.g., node uptime) to avoid slashing.
  6. After the minimum staking period or program end, use the same interface to request unstaking; once any unbonding delay elapses and no pending disputes remain, withdraw your $GAI.

3) Endorsements / Reputation-Linked Rights

The whitepaper describes address reputation, KYT/anti-abuse constraints, and quality-based rebates/slashing, rather than a formal “endorsement” right by token holders. Users maintain address reputation; media platforms receive rebates tied to VUR quality; malicious actors are slashed and blacklisted. There is no explicit, on-chain “endorsement vote” mechanism described.

Practical implications, once implemented:

  1. For users, maintain a clean usage pattern through the Wallet & Data App to sustain positive address reputation and continued eligibility for rewards and access.
  2. For media/platforms, maximize VUR quality metrics as specified by the protocol to earn higher $GAI rebates and avoid disputes that could lead to slashing or negative reputation.
  3. For node operators, comply with operational and correctness standards; the absence of slashing and blacklisting effectively serves as a form of protocol-level endorsement of the node’s reliability.

Because no explicit endorsement procedures (e.g., staking to “vouch” for others) are specified, there is currently no distinct step-by-step endorsement right beyond maintaining good reputation under protocol rules.

4) Governance Rights (How to Vote / Influence)

$GAI holders govern protocol parameters, fee structures, compatibility matrices, and public good funding. Initial governance is via multi-sig and timelocks, transitioning to full on-chain governance at maturity. Users can also use $GAI for non-binding governance input (e.g., product direction).

A. Binding protocol governance (as $GAI holder)

  1. Hold $GAI in a compatible wallet that the governance system recognizes (or in a designated staking/governance contract, depending on the eventual design).
  2. Access the official governance portal (link expected from main site/docs once on-chain governance is live).
  3. Browse active proposals affecting protocol parameters, fee structures, compatibility matrices, or public good funding. Each proposal should include a description, rationale, and the parameters to change.
  4. Connect your wallet and ensure your $GAI balance (or staked/voting power) is visible.
  5. For each proposal you wish to vote on, select your vote option (e.g., For/Against/Abstain) and confirm the vote transaction, following the gas/network prompts.
  6. After the voting period closes, check results and the associated timelock; if the proposal passes, the protocol’s multi-sig/timelock mechanism will execute the approved changes per schedule.

B. Non-binding governance input (users / community)

  1. Access the Wallet & Data App or other front-end where non-binding governance inputs (e.g., product direction polls) are hosted.
  2. Connect your wallet containing $GAI to prove participation eligibility.
  3. Select available non-binding polls or feedback channels, choose options or provide feedback, and submit your response; the system may weight inputs by $GAI holdings or other criteria, but these do not directly change protocol parameters.

5) KYC / AML / KYT and Compliance-Related Rights/Obligations

The whitepaper emphasizes “KYT/anti-abuse constraints” and “address reputation” for users, and compliance templates and residency maps for regulated industries, but does not publish a concrete KYC procedure by jurisdiction. Rewards for users are in stablecoins, and users must comply with KYT/anti-abuse rules to maintain eligibility.

A. Users (data subjects) via Wallet & Data App

  1. Install or access the Wallet & Data App from official links on the main site/docs once released.
  2. Create or connect a wallet; follow any in-app prompts to complete required identity or risk checks (e.g., sanctions and KYT screening), which may be necessary to receive stablecoin dividends.
  3. Use the app to manage data authorizations and privacy budgets, approving or revoking consent to participate in campaigns.
  4. When eligible, claim dividends (stablecoins) via ZK membership proofs submitted through the app, subject to ongoing KYT/anti-abuse constraints and address reputation maintenance.

B. Businesses (advertisers, media, nodes) in regulated industries

  1. During onboarding to advertiser, media, or node dashboards, provide required legal entity information and documents consistent with your jurisdiction’s KYC/KYB expectations (e.g., corporate registration, directors, ownership, etc.).
  2. Review and accept the compliance templates, residency maps, and reconciliation packages applicable to your industry and geography, as made available in the portal or contract docs.
  3. Ensure your payment/settlement addresses and data flows comply with any residency requirements and “audit-without-plaintext” methodologies specified by Gency AI.
  4. Maintain ongoing compliance with KYT/anti-abuse checks; if the system flags high-risk behavior, expect potential restrictions on access, rewards, or staking features until resolved.

Summary of availability

  • Concrete, live procedures (URLs, contract addresses, exact UI steps) are not yet public for Gency AI; the above flows reflect how a holder would practically exercise the rights and obligations described in the whitepaper once the corresponding modules and interfaces are launched.
G.3: Conditions for modifications of rights and obligations

Rights and obligations under Gency AI’s system may change when protocol parameters or policies are modified through its governance and policy lifecycle: critical parameters (such as thresholds, caps, penalties, accepted stablecoins, and deprecation timelines) are first controlled by a multisig and security council, then by delegated GAI token governance, and ultimately by a fully on-chain process where proposals are audited, shadow-deployed, and then activated; policies themselves move through a draft → commit → activate → evaluate → version or revoke lifecycle, with each committed policy generating an on-chain fingerprint, and any revocation blocking future use but not retroactively altering past receipts unless a legal requirement compels retroactive change.

G.4: Future public offers

The issuer has not announced any public offerings of $GAI. Future offers, if any, will be disclosed in accordance with MiCAR.

G.5: Issuer retained other token

380,000,000

G.6: Utility token classification

false

G.7: Key features of goods or services utility tokens

Not applicable as $GAI is not a utility token.

G.8: Utility tokens redemption

Not applicable as $GAI is not a utility token.

G.9: Non-trading request

true

G.10: Other tokens purchase or sale modalities

Not applicable. This whitepaper is published solely in relation to the admission to trading of the $GAI token and does not relate to any public offering.

G.11: Other tokens transfer restrictions

Geographic restrictions (sale participation)

  • Users from the United States and China are strictly prohibited from participating in the public sale/offering of the token. Sanctioned Jurisdictions: Any country subject to comprehensive OFAC or international sanctions (e.g., North Korea, Iran, Russia)

Lock-ups / vesting (affecting transferability of allocated tokens)

  • Team & Advisors (18% of supply): subject to a 12‑month cliff, followed by 48‑month linear vesting (tokens locked and non-transferable until vested).
  • Ecosystem & Node Incentives (40% of supply): released linearly over 6 years, front‑loaded in the first 2 years (unreleased tokens effectively locked and non-transferable).

Fees on transfers / on-chain transfer constraints

  • Documentation describes a small “network fee” (e.g., 0.75–1.50%) on gross spending settled via verifiable receipts, denominated in stablecoins and used for $GAI buyback/burn, treasury, insurance, and work rebates; this is framed as a fee on advertising spend/settlement, not as an on‑chain transfer tax on $GAI between wallets.
  • No explicit on-chain transfer fee, transfer tax, or programmable restriction on peer‑to‑peer transfers of the token itself is disclosed in the available materials.

Blacklist / whitelist or other transfer controls

  • No blacklist, whitelist, or address‑based transfer control mechanisms are described in the available documentation.
G.12: Supply adjustment protocols

true

G.13: Supply adjustment mechanisms
  • PCC payment–driven buyback and burn: Each ESQ query is paid in stablecoin PCC credits; a fixed portion of PCC spend is automatically converted into $GAI on the market and burned (or partially redirected to an insurance pool), reducing circulating supply. The burn volume is a function of query complexity, remaining privacy budget ε, and the $GAI price from an oracle.

  • Network fee buyback and burn: PSG charges a small network fee (e.g., ~0.75%–1.50%) on gross campaign spending in stablecoins; a portion of these fees is systematically used to buy back $GAI on the market and burn it, creating ongoing deflationary pressure.

  • Slashing-related burns: Compute, audit, and anti-fraud nodes must stake $GAI; when nodes misbehave (incorrect execution, denial of service, double-signing, falsified proofs), part of their staked $GAI is slashed and burned, with the remainder going to an insurance/claims pool, tying supply reduction to security enforcement.

  • Governance-tunable burn ratios and emissions: Governance can adjust emission incentives in earlier “inflationary” phases and later increase the share of PCC/network-fee flows allocated to buyback and burn in more “stable” phases, allowing DAO-managed tuning of how aggressive the deflationary mechanisms are over time.

G.14: Token value protection schemes

true

G.15: Token value protection schemes description

Gency AI implements a protocol-level protection and value-support scheme built around the $GAI token, stablecoin-denominated cash flows, and an insurance/treasury structure. Advertisers pay in stablecoins via Privacy/Compute Credits (PCC) and PSG receipts, with a portion of these fees automatically converted into $GAI for buyback and burn, and a portion routed to a treasury and insurance pool, creating structural demand and reserve coverage. Node operators must stake $GAI and face slashing for misconduct, with slashed tokens partly burned and partly redirected to the claims/insurance pool to compensate affected parties, while additional network fees (e.g., 0.75%–1.50% on gross spending) fund further buybacks, burns, and rebates to high-quality participants. Collectively, the stablecoin-anchored revenues, PCC-driven buyback/burn, penalty burns, and fee-funded treasury/insurance pool form a deflationary, incentives-aligned mechanism intended to support and enhance the long-term value and security of the $GAI token and the wider ecosystem.

G.16: Compensation schemes

true

G.17: Compensation schemes description

Gency AI has an internal compensation/insurance mechanism funded at protocol level rather than an external investor-protection scheme.

Coverage and types of losses:
The protocol maintains a treasury/insurance pool that “provides coverage for losses due to node misconduct or protocol failures.” This is framed around losses arising when compute, audit, or anti-fraud nodes behave maliciously (incorrect execution, denial of service, double‑signing, falsified proofs) or when protocol-level failures impact jobs and settlements.

Conditions for compensation:
Compute, audit, and anti‑fraud nodes must stake GAI to participate; if a node “is proven to behave maliciously,” its stake is slashed and part of that slashed stake plus a share of protocol fees go into a claims/insurance pool “to compensate affected parties.” The whitepaper links coverage explicitly to proven node misconduct or protocol failures, not to general trading losses or market volatility.

Process for claiming compensation:
The documentation states that slashed stake and fee allocations are directed to a “claims/insurance pool to compensate affected parties” but does not detail a user‑facing claims procedure (e.g., how to file, timeframes, or adjudication steps). It also notes that receipts can be challenged and that payments may be paused, rejected, or rolled back automatically when disputes or compliance issues arise, which is part of the broader risk‑handling and dispute flow around settlements, but still without a step‑by‑step compensation claim process.

Sources of funds for compensation:
Funding for the compensation/insurance pool comes from two protocol sources:

  • Slashing of misbehaving node stakes, where “a portion [of the slashed GAI is burned and the remainder is directed to a claims/insurance pool.”
  • A portion of a small network fee (0.75%–1.50% on gross spending) that is “directed to the treasury and insurance pool,” with fees denominated in stablecoins collected via PSG’s receipt‑based billing.
G.18: Applicable law

British Virgin Islands (BVI)

G.19: Competent court

British Virgin Islands (BVI)

Part H - Information on the underlying technology
H.1: Distributed ledger technology (DTL)

Gency AI uses a mix of encrypted off-chain computation and on-chain smart contracts to run advertising in a verifiable way. Audience targeting and measurement are done inside secure “vaults” using privacy-preserving techniques (PSI/MPC/TEE plus differential privacy), so raw user data never leaves its domain and every computation must follow machine-readable consent policies that are cryptographically committed on-chain. Campaign results are turned into verifiable usage receipts, which then drive a programmable settlement system that automatically distributes funds in stablecoins to advertisers, media, partners, and users based on predefined rules, with the $GAI token used for staking, slashing, resource prioritization, governance, and fee flowbacks. Because receipts and policies are anchored on-chain, they form an immutable audit trail, and Gency AI exposes dashboards that let participants inspect privacy metrics, compute performance, settlement behavior, and receipt coverage end-to-end, making the flow of value and evidence transparent without exposing underlying personal data.

H.2: Protocols and technical standards

Token Standard

The $GAI token is issued primarily on BNB Smart Chain (BSC) as a BEP-20 token, with additional deployment on Base as an ERC-20 token, incorporating extensible governance features with additional governance hooks integrated at the contract level. This dual-chain deployment supports multi-chain accessibility and broad ecosystem integration.

Interoperability Model

The protocol implements a dual-stack interoperability model whereby Web2 systems and on-chain components operate in parallel under a unified event model, enabling existing ad-tech, DMP, and CDP systems to integrate with the network rather than being replaced. The core protocol primitives, namely CCL, ESQ, VUR, and PSG, are defined as open interfaces that standardize how external channels and platforms connect to the network. These primitives directly underpin the protocol's four operational modules: the Policy Identity layer for on-chain data permission management and traceable data authorization; the ESQ Privacy Computing Layer for encrypted computation; the PSG Clearing and Settlement Protocol for automated revenue distribution via smart contracts; and the AI Optimization Engine for advertising strategy prediction and campaign optimization.

On-Chain Integration and Wallet Compatibility

The system is designed with an explicit emphasis on wallet compatibility and auditable on-chain events. A dedicated User Wallet is provided for consent management and yield claiming. Settlement is executed in stablecoins, with $GAI used exclusively for staking and slashing, resource prioritization, governance, and fee flowbacks, aligning with standard BEP-20 and ERC-20 wallet flows across both supported networks.

SDKs and Client Integration Standards

A Media and Platform SDK is provided for local signing and timestamping of events, supporting offline-safe batch anchoring of receipts and standardizing how Web2 channels produce verifiable on-chain proofs. An Advertiser Workbench, User Wallet, and Node Console are integrated around the same event and receipt standards to ensure end-to-end compatibility. The project maintains SDKs and templates with strict versioning and deprecation rules, alongside a semantic dictionary and compliance template library enabling different channels and jurisdictions to map into unified semantics.

Privacy and Compute Layer Mechanisms

Four protocol-level primitives underpin the network's privacy and interoperability architecture:

  • Consent-as-Code (CCL): machine-executable consent policies that external systems must conform to.
  • Encrypted Segment Query (ESQ): a privacy-preserving query mechanism enabling cross-partner audience and measurement operations without sharing raw data, supported by TEE, PSI, and MPC technologies.
  • Verifiable Usage and Result Receipts (VUR): standardized cryptographic receipts for events and outcomes, enabling auditability across heterogeneous channels.
  • Programmable Settlement Graph (PSG): a rule-based settlement engine that distributes value based on those standardized receipts, converting advertising outcomes into on-chain verifiable credentials and automating revenue distribution via smart contracts.
H.3: Technology used

Gency AI’s architecture relies on cryptographic key management that uses multisig and threshold schemes, with explicit support for key rotation, revocation, and disaster recovery. The data layer includes a dedicated key management system that supports “bring your own key” (BYOK) and multisig controls, so that data owners retain full control over their encryption keys while interacting with the network. Initial governance and treasury-like functions are controlled via multi-signature arrangements and timelocks, before a planned transition to more fully on-chain governance. On the transfer and settlement side, Gency’s SDK locally signs events in user or partner environments and supports offline-safe batch anchoring, so transactions and proofs can be bundled and committed on-chain securely. Users configure consent and retention parameters “in-wallet” and can claim rewards using zero-knowledge proofs, which allows them to interact with the system and receive value without exposing their underlying identity or raw data.

H.4: Consensus mechanism

GAI is a multi-chain token deployed primarily on BNB Smart Chain (BSC) and additionally on Base. It therefore inherits the consensus and settlement guarantees of BNB Smart Chain's Proof of Staked Authority (PoSA) and Base's Ethereum Proof of Stake (PoS) via its optimistic rollup architecture.

BNB Smart Chain – PoSA (Primary Network)

BNB Smart Chain relies on a small elected validator set under Proof of Staked Authority, a hybrid of Delegated Proof of Stake and Proof of Authority, with staking-based validator selection. This design delivers short block times and low transaction fees while tying validator behavior to bonded stake for economic security. Validators are elected based on staked BNB, and misbehavior is subject to slashing, providing a practical balance between decentralization, performance, and security suitable for high-throughput protocol operations such as advertising settlement and on-chain policy enforcement within the Gency AI network.

Base – Ethereum PoS via Optimistic Rollup (Secondary Network)

Base is an Ethereum Layer 2 network built on the OP Stack, operating as an optimistic rollup that settles transactions on Ethereum mainnet. As such, it inherits Ethereum's underlying Proof of Stake consensus, where validators stake ETH, propose and attest to blocks, and achieve economic finality via Casper FFG checkpoint voting. Reverting finalized blocks would require slashing a supermajority of stake, making attacks economically prohibitive. Base extends this security to its Layer 2 execution environment while offering significantly lower fees and higher throughput, making it well suited for the composable ERC-20 deployment of GAI and its associated on-chain interactions across the Gency AI ecosystem.

H.5: Incentive mechanisms and applicable fees

Role of $GAI vs stablecoins

All ad spend and user rewards are settled in stablecoins (e.g., USDC); $GAI is used as the coordination token for staking, slashing, pricing privacy/compute resources, governance, and value recycling (including buyback/burn).

Who earns what (incentive mechanisms)

  • Compute, audit, anti‑fraud nodes must stake $GAI to take jobs; they earn service fees in stablecoins plus decaying $GAI “performance subsidies,” and can be slashed for incorrect execution, denial of service, double‑signing, or falsified proofs, with part of the slashed stake burned and part going to an insurance/claims pool.
  • High‑quality nodes, connectors, and compliance‑template maintainers receive “work rebates” funded from network fees, allocated in proportion to verifiable usage/result (VUR) receipts.
  • Challengers / anti‑fraud participants who successfully prove inconsistencies in receipts or policies receive rewards, funded from penalties/treasury.
  • Research & governance contributors (public R&D, protocol improvements) can receive $GAI from the treasury.
  • Users (data subjects) claim campaign rewards directly in stablecoins via ZK claims; they do not rely on $GAI price exposure for their earnings.

Staking, slashing, and “network security”

  • Operational staking: Compute, audit and anti‑fraud nodes are required to stake $GAI as collateral to participate; this stake is subject to slashing for malicious or faulty behavior, with part burned and part paid into an insurance pool to compensate affected parties.
  • Access/prioritization staking: Large advertisers or distribution channels may stake $GAI to gain access to reserved resources and faster review/queue priority; staked tokens are unlocked after the staking period, but penalties may apply for rule violations.
  • The materials do not describe PoW‑style “mining”; instead, network integrity is maintained via $GAI‑backed staking, slashing, and audit/anti‑fraud incentives on top of the underlying blockchain’s own consensus.

Fee structure and how fees are handled/burned

  • Privacy/Compute Credits (PCC) consumption: Each ESQ query consumes privacy budget (ε) and compute, paid for in stablecoins via PCC; a portion of this PCC spend is automatically converted into $GAI and burned (or redirected to an insurance pool), creating structural demand tied to query load and privacy loss.
  • Network fee on campaign spending: The PSG settlement layer applies a small “network fee” on gross ad spending (illustratively on the order of ~0.75–1.50%, governed by DAO parameters) denominated in stablecoins; this fee is split between:
  • stablecoin‑funded market buyback and burn of $GAI,
  • allocations to the treasury and insurance pool, and
  • “work rebates” to high‑quality nodes/connectors/template maintainers (weighted by VUR).
  • Per‑payout fee breakdown: For each verifiable payout triggered by VUR receipts, the docs describe fees such that:
    1. advertisers fund campaigns in stablecoins via PSG; ESQ consumes PCC, with 5% of PCC spend converted to $GAI and burned;
    2. each payout includes fees like 5% for $GAI buyback/burn, 5% to treasury/insurance, and 10% as $GAI rebates to ecosystem participants;
    3. user rewards themselves remain fully in stablecoins.

Contribution to sustainability

  • Structural deflationary pressure on $GAI arises from PCC‑linked conversions and burns, penalty burns from slashing, and network‑fee‑funded buyback/burn, while DAO governance can adjust early inflation vs. long‑term burn ratios over time.
  • Network fees fund treasury and insurance pools and ongoing rebates to productive participants, helping sustain compute, audit, and compliance infrastructure without relying solely on continuous token inflation.

No public on‑chain market‑data‑style fee or reward statistics are available yet; the above reflects the pre‑launch economic design described in project materials.

H.6: Use of distributed ledger technology

false

H.7: DLT functionality description
H.8: Audit

false

H.9: Audit outcome
Part I - Information on Risks
I.1: Offer-related risks

Market and Liquidity Risks

  • As a pre‑launch token, $GAI initially may have limited trading venues and shallow order books, making it difficult to enter or exit positions without significant price impact.
  • Ongoing liquidity will depend on sufficient exchange listings and trading activity; the issuer does not control exchanges and $GAI could be delisted, severely hindering secondary market trading.
  • $GAI’s price may be highly volatile due to speculation, changing demand for the underlying Privacy/Compute Credits (PCC), and broader market sentiment, which could result in substantial losses.

Legal and Regulatory Risks

  • The issuer is a relatively new BVI business company with limited operating history; changes in BVI or other applicable laws could impact its ability to operate or to support $GAI.
  • The project operates in a highly regulated advertising and data‑privacy environment (e.g., GDPR, CCPA). Implementation mistakes or disputes about data boundaries could trigger investigations, fines, or injunctions that disrupt the protocol or reduce token value.
  • Geographic restrictions (e.g., exclusion of users from the United States and China from the public sale) may expand over time, limiting market access for certain investors and impacting liquidity or utility in specific jurisdictions.

AML / KYC and Sanctions Risks

  • Participation in the offering and use of the platform may be conditional on AML/KYC checks and geographic eligibility; failure to satisfy these requirements can result in inability to participate or loss of access.
  • The project uses stablecoins for settlements and user payouts, which may themselves be subject to AML, sanctions, and blacklisting controls; actions by stablecoin issuers or regulators could freeze assets or limit use within the ecosystem.
  • Privacy‑preserving reward mechanisms and pseudonymous participation (e.g., use of Merkle trees and ZK proofs) may raise additional scrutiny from regulators regarding effectiveness of AML/KYC controls, potentially leading to stricter requirements or enforcement actions.

Technical and Operational Risks

  • Core smart contracts and protocol code (including $GAI and related logic) are not yet audited; undiscovered vulnerabilities could lead to loss or theft of funds, manipulation of rewards, or protocol failure before audits are completed.
  • The system depends on complex and relatively novel technologies (TEE, MPC, differential privacy). Design or implementation flaws, hardware side‑channel vulnerabilities, or cryptographic errors could compromise confidentiality, correctness, or availability.
  • The end‑to‑end “CCL → ESQ → VUR → PSG” main track is tightly coupled; failures in any component (e.g., policy registry, matching, proof generation, or settlement) may disrupt ad campaigns and associated token flows.
  • Network performance and security rely on computing and audit nodes that stake $GAI; high operating costs, insufficient rewards, or slashing events could cause node exits, degraded service, or concentration of power in a few operators.
  • Oracle dependencies for pricing and buyback‑and‑burn mechanics introduce risks of oracle failure or manipulation, which could distort the economic model or trigger unintended token flows.
  • Key management failures, supply‑chain compromises, or misconfigured security controls could lead to unauthorized access, replay attacks, or policy bypass despite the project’s defense‑in‑depth design.

Tokenomics and Vesting Risks

  • A significant portion of supply is allocated to team and advisors (18%) with a long vesting schedule; while intended to align interests, this concentration creates overhang risk as tokens unlock over time.
  • Large allocations for ecosystem and node incentives (40%) released over several years may still generate sustained sell pressure if recipients liquidate rewards rather than hold or use $GAI in the network.
  • The economic model depends on advertiser demand for PCC, buyback‑and‑burn mechanisms, and staking dynamics; if actual demand or fee flows fall short of expectations, value‑accrual and deflationary effects may not materialize, reducing long‑term token value.
  • Initial liquidity (5% allocation) is dedicated to market‑making; if this liquidity is insufficient, poorly managed, or withdrawn, early‑stage trading could suffer from extreme volatility and slippage.

Governance and Centralization Risks

  • In early stages, governance and key decisions may be concentrated in the core team or a security council, which could take actions that are not aligned with the interests of all token holders.
  • Transitioning from a centrally steered model to more decentralized, on‑chain governance may be slower or less complete than planned, leaving long‑term control effectively in the hands of a small group.
  • Operational processes within the issuer (e.g., management of the control plane or policy registry) are critical single points of coordination; failures, mismanagement, or internal conflicts could disrupt network operations or undermine governance decisions.
I.2: Issuer-related risks

Issuer overview

The token issuer is a company limited by shares incorporated in the British Virgin Islands, with registered address at Sea Meadow House, P.O. Box 116, Road Town, Tortola, BVI.
The issuer operates the “Gency AI” advertising network and related infrastructure, focused on AI-driven, privacy-preserving, verifiable advertising and settlement.

Financial risk

As a pre-launch token project, there is no public financial information, audited accounts, or cash-flow data available for the issuer, making its solvency and funding runway difficult to assess.
The business appears venture- and partner-driven (backers and integrations highlighted on the site), which may concentrate dependence on a limited number of investors and commercial partners and expose holders to funding risk if these relationships change.

Business / industry risk

The issuer is building an AI-powered advertising and data-coordination network in a highly competitive AdTech and AI infrastructure market, where dominant incumbents and rapid technological shifts can pressure margins and adoption.
The model relies on network effects among advertisers, publishers, compute/audit partners, and users, so failure to reach sufficient scale or to integrate with key platforms could materially limit transaction volumes and fee generation.

Legal and regulatory risk

The issuer’s BVI incorporation may provide regulatory flexibility but can also create uncertainty for investors regarding applicable investor-protection regimes and recourse compared with onshore regulatory frameworks.
Because the business processes advertising, user data, and on-chain settlement across jurisdictions, it may be exposed to evolving rules on data protection, digital advertising, AI governance, and crypto-assets (including potential MiCA classification in the EU), increasing compliance cost and enforcement risk.

Internal control and operational risk

The project is early-stage with no publicly disclosed detailed governance framework, internal control descriptions, or independent audit of systems, implying execution and operational risks around smart contracts, data-handling pipelines, and the settlement mechanism.
Complex infrastructure (personal/partner data vaults, confidential compute, ZK proofs, staking for compute/audit partners) increases reliance on robust development, monitoring, and incident-response processes, which are not yet transparently documented.

ESG risk

The network’s focus on “executable consent,” privacy-preserving computation, and user-controlled data usage suggests a positive alignment with data-privacy and user-rights aspects of ESG, but these commitments are high-level and not yet backed by detailed policies, independent assessments, or reporting.
Environmental impact from computation and on-chain settlement is not quantified, and there is no public disclosure on governance structures (board composition, conflicts of interest, or ESG oversight), leaving ESG performance and governance quality uncertain.

I.3: Other tokens-related risks

Market and Liquidity Risk:
$GAI will be highly sensitive to speculative demand, with price affected by market sentiment and usage of the Privacy/Compute Credits (PCC) buyback-and-burn mechanism; limited trading activity may result in low liquidity and high slippage, and there is no assurance that holders can exit at desired prices.

Legal and Regulatory Risk:
$GAI is a protocol coordination token, but changing regimes (including MiCA) and differing national interpretations could challenge that classification, affecting trading, distribution, or use. The underlying ad-tech and data-processing stack operates in a heavily regulated privacy environment (e.g., GDPR, CCPA), and implementation errors or boundary issues could trigger investigations, fines, or forced changes to the product. Users from the US and China are explicitly restricted from the public sale to mitigate jurisdictional risk, signalling heightened regulatory sensitivity for those markets.

AML and Privacy Risk:
Gency AI’s design emphasizes privacy-preserving computation (TEEs, MPC, differential privacy) and privacy-preserving user incentives (e.g., Merkle + ZK-based claims, irreversible audience IDs), which reduces direct exposure of raw personal data but may complicate traditional identity-based monitoring and compliance approaches. While payouts are in stablecoins to support accounting and compliance clarity, regulators may scrutinize the balance between strong privacy guarantees and required traceability/AML controls in ad-finance flows.

Technical and Security Risk:
As of the latest disclosure, the protocol and smart contracts (including $GAI and PSG logic) remain unaudited by a third party, with an external audit only scheduled for Q2 2026; undiscovered vulnerabilities, implementation bugs, or economic-design flaws may exist in the interim. The system depends on complex and relatively novel privacy technologies (TEE, MPC, DP, remote attestation, Sybil defenses, staking/slashing), and any weaknesses in cryptographic assumptions, hardware TEEs, key management, or remote-attestation workflows could compromise integrity, confidentiality, or availability. Users also bear sole responsibility for private key management; loss or compromise of keys results in permanent loss of $GAI and associated rights.

Governance Risk:
Although $GAI is intended to be used for governance, early-stage control is expected to be concentrated in the core team and/or a Security Council, creating a risk that key protocol, treasury, or parameter decisions reflect a narrow set of interests rather than the broader tokenholder base. Changes to governance structures over time may alter holder influence and protections in ways that are difficult to predict ex ante.

Listing and Delisting Risk:
There is no guarantee that any particular exchange will list or continue to list $GAI; the issuer does not control exchange operations, and delistings or trading suspensions would significantly impair secondary-market liquidity and price discovery. As a pre-launch token, concrete market data and live liquidity conditions are not yet available, increasing uncertainty around eventual trading depth and venue coverage.

I.4: Project implementation-related risks

Technical risks

  • The protocol combines multiple complex components (Consent CCL, Encrypted Computing ESQ, Verifiable Receipts VUR, Programmable Settlement PSG) into a single “growth engine”; integration bugs, performance issues, or failures in any layer could undermine end‑to‑end reliability and verifiability.
  • Achieving ≥95% VUR coverage and ≥80% T+1 settlement across major partners requires robust data pipelines and measurement; inconsistencies in receipt generation or settlement logic could erode trust in reported outcomes.
  • $GAI’s role in staking, slashing, pricing privacy/compute, and coordinating node incentives increases smart contract and economic design risk; bugs or mis-specified parameters could cause unintended slashing, distorted pricing, or network instability.

Operational / resource risks

  • The roadmap spans seed/validation, scaling, and “autonomous” phases with ambitious coverage, settlement, and governance targets; delays in shipping core protocol components, achieving target KPIs, or onboarding sufficient nodes and media partners would slow adoption.
  • Complex multi-stakeholder coordination (advertisers, media, users, computing and auditing nodes, DAO contributors) raises execution risk around process design, dispute handling, and day‑to‑day operations.

Third‑party dependency risks

  • The model depends on advertisers, media partners, and node operators adopting “buy results, not data” workflows and generating VUR-backed receipts; low partner adoption or inconsistent implementation would limit network effects and data quality.
  • Reliance on independent computing and auditing nodes to perform “provable work” introduces operational and security dependencies; concentration of node operators or collusion could weaken assurances.

Market / liquidity risks

  • $GAI is a fixed‑supply token with a large share allocated to ecosystem incentives, community/treasury, team/advisors, and strategic/public sale; vesting cliffs, front‑loaded emissions, or large treasury activities could create sell‑pressure and volatility once markets exist.
  • Structural consumption via buyback/burn and penalty burn depends on sustained protocol usage and fee flows; if actual demand or fee volumes underperform, the intended deflationary dynamics and incentive alignment may not materialize.

Legal / compliance risks

  • The protocol is explicitly positioned for regulated industries, using compliance templates, residency maps, and “audit‑without‑plaintext” methodologies; failure to meet evolving regulatory or sector‑specific requirements in key jurisdictions could block deployments or require costly redesigns.
  • Government and research “audit sandboxes” and reconciliation packages assume regulators and auditors will accept encrypted and receipt‑based evidence; if not, institutions may still demand traditional data access, reducing the value of the privacy‑preserving design.

Governance / tokenomics risks

  • Governance is designed to transition from multisig + security council to delegated $GAI governance and then fully on‑chain pipelines; delays or failures in this transition could leave power concentrated in early operators longer than intended, or introduce governance capture/low‑participation issues once decentralized.
  • $GAI underpins staking, slashing, governance, and incentive alignment, while economic outcomes are settled in stablecoins; misalignment between $GAI’s market value and protocol usage or fees could weaken security, distort participation incentives, or make slashing economically ineffective.
I.5: Technology-related risks

Technology Risks (Gency AI / $GAI)

  • Smart contracts and programmable settlement: The protocol uses smart contracts for staking, slashing and programmable settlement (PSG), coordinating incentives and penalties across ESQ/VUR/PSG, but no third‑party audit has been completed yet; undiscovered logic or implementation bugs in $GAI contracts or PSG could lead to loss or misallocation of funds.

  • Cross‑stack / cross‑environment complexity: The design explicitly targets “dual‑stack interoperability” across Web2 and on‑chain environments under a unified event model, increasing integration surface and the risk of inconsistencies or misconfigurations between off‑chain delivery, confidential compute, and on‑chain policy/settlement logic.

  • Scalability and performance: The infrastructure layer must enforce consent, run privacy‑preserving ESQ queries, generate verifiable usage/result receipts (VUR) and trigger PSG settlement, all on high‑volume advertising data; combining TEE/MPC/DP with verifiable receipts may introduce latency, throughput bottlenecks, or failure modes that are not yet proven at internet‑scale.

  • Wallet, key management and privacy guarantees: Users and node operators are solely responsible for private key security, and lost keys cannot be recovered, creating permanent loss risk; at the same time, the system promises strict privacy (row‑level plaintext never leaving its domain, consent‑as‑code, encrypted segment queries), so any flaw in cryptographic logic, TEE/MPC implementation, or consent enforcement could undermine both data confidentiality and regulatory claims.

  • L2 / base‑chain dependencies: Public documentation for the token and architecture focuses on protocol roles (coordination, settlement in stablecoins) and does not yet specify the exact L1/L2 deployment environment; once chosen, the protocol will inherit that chain’s consensus, bridge, and data‑availability risks, and any rollup/outsource DA solution used for receipts or settlements would add another dependency layer.

  • Audits and security maturity: As of the latest disclosures, the protocol (including $GAI smart contracts and PSG logic) has not undergone an external security audit; a third‑party audit is only planned for Q2 2026, and the heavy reliance on novel privacy‑preserving technologies (TEE, MPC, DP) means both software and hardware‑level vulnerabilities (e.g., side‑channel attacks) remain material risk factors until independently reviewed and battle‑tested.

I.6: Mitigation measures

Differential Privacy (DP) Accuracy Trade-off

The project identifies that adding too much DP noise can degrade ad measurement accuracy and drive advertisers away.

Concrete mitigation measures (design-level and operational):

  • Tunable privacy–accuracy tiers:
    Implement multiple DP “modes” (e.g., high-privacy/low-noise, medium, strict-privacy/high-noise), allowing advertisers to choose acceptable trade-offs per campaign, with clear UI warnings about accuracy ranges.
  • Granular budget allocation:
    Allocate the privacy budget (ε) adaptively across metrics and time so that high-value KPIs (e.g., conversions) get lower noise, while less critical aggregates absorb more noise.
  • Continuous calibration using holdout data:
    Maintain non-identifying holdout datasets or simulated data to empirically estimate error bounds for each DP configuration and regularly recalibrate noise parameters to keep accuracy within defined Service Level Objectives (SLOs).
  • Accuracy SLOs and contractual disclosures:
    Define internal quantitative SLOs (e.g., “for metric X, expected DP error < Y% at Z% confidence”) and disclose expected error ranges in documentation and commercial terms so advertisers understand limitations.
  • Feedback loops with advertisers:
    Collect structured feedback and performance metrics from advertisers (e.g., lift tests, A/B experiments) and use these to iteratively tune DP parameters and aggregation logic.
  • Metric design for robustness:
    Prefer coarse-grained metrics, robust aggregations (e.g., medians, trimmed means), and larger cohorts where DP noise has less relative impact, reducing the chance that noise overwhelms the signal.
  • Guardrails and monitoring:
    Implement monitoring to detect when DP-induced error exceeds thresholds (e.g., anomaly detection on variance, convergence checks) and trigger automatic fallback to less noisy modes or temporarily relaxed DP for affected metrics, subject to policy constraints.

Limitations:

  • Even with tuning and monitoring, there is an irreducible trade-off: beyond a certain privacy level, some granular measurement use cases will remain infeasible or unreliable.
  • For low-volume advertisers or very fine-grained targeting, maintaining both strong DP guarantees and commercially useful accuracy may not be possible; such configurations may need to be disallowed or clearly marked as “experimental/low reliability.”

Oracle Dependency

The project notes that buyback and pricing mechanisms depend on real-time oracle price feeds, creating a risk that oracle failure or manipulation disrupts the economic model.

Concrete mitigation measures:

  • Use multiple independent oracle providers:
    Aggregate prices from several reputable oracle networks and/or direct exchange feeds with distinct data sources and update mechanisms; use median or weighted-median aggregation to reduce single-source manipulation risk.
  • Circuit breakers and sanity checks:
    Implement on-chain or contract-level checks (e.g., max % deviation vs. time-weighted average price, max intrablock move, bounds vs. external reference prices) that pause buybacks or pricing logic when feeds appear abnormal.
  • Graceful degradation / fallback logic:
    Define explicit fallback behavior if oracles fail (e.g., halt buybacks, switch to last-known safe TWAP, require governance/manual intervention) rather than continuing with stale or missing data.
  • Time-weighted averages and smoothing:
    Base critical calculations on TWAPs over appropriate windows and volume-weighted aggregates where feasible, making it harder for short-term price spikes to distort mechanisms.
  • Access control and upgrade governance:
    Restrict who can change oracle addresses, aggregation rules, or parameters (e.g., through timelocked governance or multisig), with transparent on-chain records and delays before changes take effect.
  • Stress testing and scenario simulation:
    Run simulations for oracle outages, extreme volatility, and targeted price manipulation to define safe parameter ranges (update frequency, deviation thresholds, pause conditions) before deployment.
  • Monitoring and alerting:
    Set up real-time off-chain monitoring of oracle performance (latency, deviation vs. major CEX/DEX prices, failure rates) with automatic alerts and incident runbooks for operators.

Limitations:

  • Oracle risk cannot be fully eliminated: all off-chain price feeds introduce some dependency and potential attack surface.
  • In thinly traded or illiquid markets, even robust oracle designs may still propagate distorted prices if underlying market data are themselves easily manipulated.
Part J – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
S.1: Name

Fort Limited

S.2: Relevant legal entity identifier

254900DKB8E8Z59ONQ39

S.3: Name of the crypto-asset

GencyAI Token

S.4: Consensus mechanism

GAI is a multi-chain token deployed primarily on BNB Smart Chain (BSC) and additionally on Base. It therefore inherits the consensus and settlement guarantees of BNB Smart Chain's Proof of Staked Authority (PoSA) and Base's Ethereum Proof of Stake (PoS) via its optimistic rollup architecture.

BNB Smart Chain – PoSA (Primary Network)

BNB Smart Chain relies on a small elected validator set under Proof of Staked Authority, a hybrid of Delegated Proof of Stake and Proof of Authority, with staking-based validator selection. This design delivers short block times and low transaction fees while tying validator behavior to bonded stake for economic security. Validators are elected based on staked BNB, and misbehavior is subject to slashing, providing a practical balance between decentralization, performance, and security suitable for high-throughput protocol operations such as advertising settlement and on-chain policy enforcement within the Gency AI network.

Base – Ethereum PoS via Optimistic Rollup (Secondary Network)

Base is an Ethereum Layer 2 network built on the OP Stack, operating as an optimistic rollup that settles transactions on Ethereum mainnet. As such, it inherits Ethereum's underlying Proof of Stake consensus, where validators stake ETH, propose and attest to blocks, and achieve economic finality via Casper FFG checkpoint voting. Reverting finalized blocks would require slashing a supermajority of stake, making attacks economically prohibitive. Base extends this security to its Layer 2 execution environment while offering significantly lower fees and higher throughput, making it well suited for the composable ERC-20 deployment of GAI and its associated on-chain interactions across the Gency AI ecosystem.

S.5: Incentive mechanisms and applicable fees

Role of $GAI vs stablecoins

All ad spend and user rewards are settled in stablecoins (e.g., USDC); $GAI is used as the coordination token for staking, slashing, pricing privacy/compute resources, governance, and value recycling (including buyback/burn).

Who earns what (incentive mechanisms)

  • Compute, audit, anti‑fraud nodes must stake $GAI to take jobs; they earn service fees in stablecoins plus decaying $GAI “performance subsidies,” and can be slashed for incorrect execution, denial of service, double‑signing, or falsified proofs, with part of the slashed stake burned and part going to an insurance/claims pool.
  • High‑quality nodes, connectors, and compliance‑template maintainers receive “work rebates” funded from network fees, allocated in proportion to verifiable usage/result (VUR) receipts.
  • Challengers / anti‑fraud participants who successfully prove inconsistencies in receipts or policies receive rewards, funded from penalties/treasury.
  • Research & governance contributors (public R&D, protocol improvements) can receive $GAI from the treasury.
  • Users (data subjects) claim campaign rewards directly in stablecoins via ZK claims; they do not rely on $GAI price exposure for their earnings.

Staking, slashing, and “network security”

  • Operational staking: Compute, audit and anti‑fraud nodes are required to stake $GAI as collateral to participate; this stake is subject to slashing for malicious or faulty behavior, with part burned and part paid into an insurance pool to compensate affected parties.
  • Access/prioritization staking: Large advertisers or distribution channels may stake $GAI to gain access to reserved resources and faster review/queue priority; staked tokens are unlocked after the staking period, but penalties may apply for rule violations.
  • The materials do not describe PoW‑style “mining”; instead, network integrity is maintained via $GAI‑backed staking, slashing, and audit/anti‑fraud incentives on top of the underlying blockchain’s own consensus.

Fee structure and how fees are handled/burned

  • Privacy/Compute Credits (PCC) consumption: Each ESQ query consumes privacy budget (ε) and compute, paid for in stablecoins via PCC; a portion of this PCC spend is automatically converted into $GAI and burned (or redirected to an insurance pool), creating structural demand tied to query load and privacy loss.
  • Network fee on campaign spending: The PSG settlement layer applies a small “network fee” on gross ad spending (illustratively on the order of ~0.75–1.50%, governed by DAO parameters) denominated in stablecoins; this fee is split between:
  • stablecoin‑funded market buyback and burn of $GAI,
  • allocations to the treasury and insurance pool, and
  • “work rebates” to high‑quality nodes/connectors/template maintainers (weighted by VUR).
  • Per‑payout fee breakdown: For each verifiable payout triggered by VUR receipts, the docs describe fees such that:
    1. advertisers fund campaigns in stablecoins via PSG; ESQ consumes PCC, with 5% of PCC spend converted to $GAI and burned;
    2. each payout includes fees like 5% for $GAI buyback/burn, 5% to treasury/insurance, and 10% as $GAI rebates to ecosystem participants;
    3. user rewards themselves remain fully in stablecoins.

Contribution to sustainability

  • Structural deflationary pressure on $GAI arises from PCC‑linked conversions and burns, penalty burns from slashing, and network‑fee‑funded buyback/burn, while DAO governance can adjust early inflation vs. long‑term burn ratios over time.
  • Network fees fund treasury and insurance pools and ongoing rebates to productive participants, helping sustain compute, audit, and compliance infrastructure without relying solely on continuous token inflation.

No public on‑chain market‑data‑style fee or reward statistics are available yet; the above reflects the pre‑launch economic design described in project materials.

S.6: Beginning of period to which disclosed information relates

2026-03-25

S.7: End of period to which disclosed information relates

2026-04-07

S.8: Energy consumption

5.97496

S.9: Energy consumption sources and methodologies

Data provided by CCRI; all indicators are based on a set of assumptions and thus represent estimates; methodology description and overview of input data, external datasets and underlying assumptions available at:
https://carbon-ratings.com/dl/whitepaper-mica methods-2024 and https://docs.mica.api.carbon ratings.com. We do not account for any offsetting of energy consumption or other market-based mechanism as of today.

S.10: Renewable energy consumption

Not applicable as the annual energy consumption is less than 500,000 kWh.

S.11: Energy intensity

Not applicable as the annual energy consumption is less than 500,000 kWh.

S.12: Scope 1 DLT GHG emissions - controlled

Not applicable as the annual energy consumption is less than 500,000 kWh.

S.13: Scope 2 DLT GHG emissions - purchased

Not applicable as the annual energy consumption is less than 500,000 kWh.

S.14: GHG intensity

Not applicable as the annual energy consumption is less than 500,000 kWh.

S.15: Key energy sources and methodologies

Not applicable as the annual energy consumption is less than 500,000 kWh.

S.16: Key GHG sources and methodologies

Not applicable as the annual energy consumption is less than 500,000 kWh.

S.17: Energy mix
S.18: Energy use reduction
S.19: Carbon intensity
S.20: Scope 3 DLT GHG emissions - value chain
S.21: GHG emissions reduction targets or commitments
S.22: Generation of waste electrical and electronic equipment (WEEE)
S.23: Non-recycled WEEE ratio
S.24: Generation of hazardous waste
S.25: Generation of waste (all types)
S.26: Non-recycled waste ratio (all types)
S.27: Waste intensity (all types)
S.28: Waste reduction targets or commitments (all types)
S.29: Impact of the use of equipment on natural resources
S.30: Natural resources use reduction targets or commitments
S.31: Water use
S.32: Non recycled water ratio
S.33: Other energy sources and methodologies
S.34: Other GHG sources and methodologies
S.35: Waste sources and methodologies
S.36: Natural resources sources and methodologies

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