> For the complete documentation index, see [llms.txt](https://docs.suno.finance/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.suno.finance/legal/eligibility-and-onboarding.md).

# Eligibility and onboarding

Who can participate, what verification asks, and where the compliance gate sits: at the swap and the desk, never on holding.

Anyone can hold a uWatt: the token is an ERC-20 and moves wherever the blockchain lets it. The compliance gate sits where value enters and leaves the system instead. Swapping pWatts into uWatt, minting at the desk, and redeeming at the desk are open only to wallets that have completed identity verification and remain eligible, and the protocol enforces that condition in code rather than by holding anyone's tokens. This page covers who is eligible, what verification asks, where the gate sits, and what it does when a wallet stops qualifying.

## Who can participate

The Terms and Conditions admit individuals and entities who meet five conditions at all times: they are of legal age and capacity under the law of their residence or incorporation; they are not a citizen, resident, or entity of a Restricted Jurisdiction; they do not appear on any sanctions list; they have completed verification to Suno's satisfaction before acquiring tokens; and they use the platform lawfully. By using the platform a user also represents, on a continuing basis, that they act for their own account, that their funds are lawfully obtained, and that they understand the risk of total loss.

The Restricted Jurisdictions named in the contract are the United States, Canada, the People's Republic of China, Australia, Iran, and North Korea, together with any jurisdiction under comprehensive sanctions from the European Union, the United Nations, or the United States Office of Foreign Assets Control. On top of that contractual list, Suno's compliance program screens a broader set of higher-risk jurisdictions drawn from Financial Action Task Force and Bermuda Monetary Authority guidance. Both lists are published on [Current designations](/legal/current-designations.md), and a prospective holder is responsible for consulting them before swapping or depositing.

A person who participates while ineligible may have access suspended or terminated, transfers or distributions restricted, and rights permanently lost, without compensation.

## What onboarding asks

Verification is run by a third-party provider, named on [Current designations](/legal/current-designations.md). Individuals may be asked for their full legal name, date and place of birth, nationality, residential address, a government-issued identity document, proof of address, a facial-recognition check, and contact details. Entities may be asked for their legal name and form, registered address, incorporation number, constitutional documents, the identity of statutory representatives and beneficial owners, proof of authority to acquire tokens, and their wallet addresses. Higher-risk profiles receive enhanced due diligence and may be asked for more.

The obligation continues after approval. A user must keep their information current and notify Suno at once of any change in address, beneficial ownership, or sanctions status. Suno may refuse or revoke approval if information is incomplete or unverifiable, if the user breaches the terms or becomes ineligible, or if continued access would create legal, regulatory, reputational, or operational risk. Whether onboarding is complete is Suno's decision.

## Whitelisting and the compliance gate

A wallet that passes verification is Whitelisted: recorded in the protocol's on-chain admission registry. The registry is the mechanism behind the contract's statement that access to platform functions "is not an unconditional right, but a state that exists only while all applicable eligibility conditions are met".

The gate is placed where new value enters the system or leaves it, and nowhere else:

* **Gated: the swap and the desk.** Exchanging pWatts for uWatt at commercial operation, minting uWatt with stablecoins or fiat, and redeeming uWatt against the Reserve all check the registry. So does any distribution paid directly to a wallet in stablecoins or fiat, which is the case the contract's Distributions provisions are written for. Onboarding must be complete before any of these, and nothing is owed for the period before it was.
* **Open: holding, transferring, and staking.** uWatt and c-uWatt can be bought on secondary markets or received from another person without any onboarding, and a holder who acquired uWatt that way can deposit it in the staking vault. None of these adds new value to the system, so none of them checks the registry. Transfers to non-whitelisted addresses go through at the blockchain level.

The yield follows the second rule rather than the first. Energy revenue is not paid out to wallets; it lands in the Reserve and reaches stakers as growth in what each c-uWatt share redeems for, as described in [Yield and staking](/protocol/yield-and-staking.md). Whoever holds the share is exposed to that growth, whether or not they have ever been onboarded. What a non-onboarded holder cannot do is convert at the desk: to turn uWatt back into stablecoins through the protocol, rather than on a secondary market, the wallet must be whitelisted.

The wallet itself can be a self-custody wallet the holder already controls, or the optional embedded wallet integrated with the platform. In both cases Suno never holds, accesses, or controls the private key; an embedded wallet is a key-management interface, and the arrangement stays non-custodial. Holders may also interact with the protocol directly through any compatible interface; the registry check applies to the gated operations regardless of the interface used.

## Monitoring and what happens when a wallet stops qualifying

Verification is followed by ongoing monitoring of transactions, wallet addresses, and user information, using screening databases, transaction monitoring, and blockchain analytics. Where Suno identifies indicators of money laundering, terrorist financing, sanctions breach, or other unlawful conduct, it may update the eligibility status of the wallet in the protocol.

What that update does is bounded by the architecture. Suno cannot take, freeze, or move tokens: they stay in the holder's wallet, on-chain, and keep whatever value the Reserve gives them. What changes is access. The wallet loses the swap, the desk, any direct distribution, and the platform's functions until eligibility is restored, and the holder is notified of the change in status and of the channels available to them. Suno accepts no liability for economic consequences of that state, including lost yield or market moves during the period of ineligibility.

Suspension and termination follow the same logic. During a suspension, platform access may be disabled, the desk, the swap, and any direct distribution closed to the wallet, and transfers to or from it blocked; the tokens remain valid on the blockchain but may be unusable through the platform. On termination, platform access is revoked permanently and the tokens are no longer recognized as eligible for any rights under the contract. Suspension or termination may mean the permanent loss of yield rights, with no compensation except where the law requires it.

## Non-ordinary events and continuity of access

Some changes in a holder's situation alter the terms on which they interact with the platform without ending the relationship: death or incapacity, becoming a politically exposed person, or suspicious on-chain behavior. These may lead to restricted access or a change in whitelisting status, while the tokens themselves stay recorded on-chain.

Death and incapacity call for preparation while the holder still has full capacity. The contract asks every holder to learn the Wallet Export Mechanism and to make sure a trusted person could exercise their keys or seed phrase if needed. That provision is the holder's responsibility alone, and Suno accepts no liability for holdings that become inaccessible because none was made. The platform presents the consequences of exporting a wallet, or keeping a platform-integrated one, at the point of decision.

The compliance program behind all of this is described in [AML/ATF policy](/legal/aml-atf-policy.md).


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