Governance 9 clauses
Governance
How the desk operates.
Each clause below is a rule someone could catch the desk breaking. That is the only kind worth publishing.
- 01 Agency only
- The desk works on mandate, for a fee. It does not custody client assets, does not trade a book of its own, does not warehouse inventory or directional risk, does not pool or manage capital, and does not make investment recommendations to the public. It is never on the other side of a client’s trade.
- 02 Settlement
- Transactions settle only on approved rails: exchange internal transfers, regulated institutional custodians, or escrow arrangements with qualified counsel. The desk does not settle wallet-to-wallet with unverified counterparties, under any circumstances.
- 03 KYC / AML
- Every counterparty is identity-verified before a transaction is structured. Source of funds and custody are confirmed before settlement. The desk declines transactions that cannot meet this standard, regardless of size.
- 04 Eligibility
- The desk works with institutional, professional and qualifying private investors only. Nothing on this site is directed at retail investors, and nothing on it constitutes an offer, a solicitation, or investment, legal or tax advice.
- 05 Confidentiality
- Counterparties are never named without written agreement. Opportunities circulate under blind teaser until an NDA is signed. Mandate terms stay off the public record. Client-commissioned assessments are never published.
- 06 Data handling
- Client engagements begin with an NDA and a written data-handling statement. The desk never trades against, and never shops, information from a client’s book. Portfolio data is used solely for the deliverable it was provided for.
- 07 Conflicts
- Assessments are commissioned by investors; subjects cannot pay for a verdict. A subject that has engaged the desk for advisory work is ineligible for assessment for six months, and thereafter may only be assessed with an independent reviewer of record who took no part in the advisory work and who signs alongside the analyst. There is no staffing exception. Advisory working papers are quarantined from the assessment file. Published policy, not case-by-case judgment. Every assessment discloses its commissioning party. The standard is versioned; no client can pay to change it.
- 08 Continuity
- Custody, settlement and escrow sit with regulated third parties, never with the desk. Collateral control and liquidation terms are agreed in writing at the outset of every mandate and documented with qualified counsel. A facility therefore runs to its agreed terms independently of any single point of contact.
- 09 Status
- Mjolnir Capital is an independent, founder-operated desk. Engagements are documented per transaction with qualified counsel. Past activity is no indication of future outcomes. The desk is not a credit rating agency and does not issue credit ratings. Assessments are informational verification of disclosed information against a published standard.