The memo
REJECTED BECAUSE THE SURVEYED PRODUCT IS POLYMARKET INTERNATIONAL, NOT THE SEPARATE US-REGULATED APPLICATION. Polymarket's own current help center says polymarket.com is for international users, blocks United States residents from depositing or trading, and keeps accounts entirely separate from the US-only Polymarket app operated by CFTC-regulated QCX LLC. The international site identifies Adventure One QSS Inc. and expressly states that this product is not regulated by the CFTC. Its on-chain mechanics are real: pUSD collateral backs ERC-1155 Yes/No outcome tokens, a hybrid central limit order book matches signed orders off chain for atomic Polygon settlement, and the UMA Optimistic Oracle resolves markets. Those features do not make the international venue eligible for a US RIA client. The historical CFTC order against predecessor operator Blockratize—$1.4M and a required wind-down of noncompliant markets—makes the current legal-entity and product boundary especially decision-bearing rather than a cosmetic geoblock.
What would reopen the file
- Polymarket International becomes legally available to United States clients under the same registered-venue protections as Polymarket US
- Adventure One QSS Inc. obtains and publishes the registration or exemption governing the international event-contract venue
- A market clarification changes the economically reasonable interpretation of an open position or a final UMA resolution departs from the cited source
- A proposed-size position cannot exit through the order book or pUSD offramp within one business day under normal market conditions
Facts on file
- Verdict
- Rejected
- Exposure
- other
- Chains examined
- Polygon
- Memo version
- v1
- Reviewed
- Next review