FMA passporting — production gate

Status (2026-05-19): ACTIVE — Phase B workstream. Owner: Antonios. Build does not block on this; Phase A ships as research publication without it. This gate clears for Phase C (structured wrapper + execution). See PRD §8.

Production traffic must not carry client money or firm portfolio replication until this gate is cleared.

Required artefacts

• [ ] Current FMA VVG licence / passport notification reference on file
• [ ] Legal confirmation email / memo filed in compliance drive
• [ ] Pilot contractual pack executed (AUM, fee schedule, risk disclosures)

Engineering checks

• [ ] EU-only data residency for primary Postgres (Supabase audit log) + Supabase Storage backup (EU)
• [ ] MiFID-II suitability engine version locked with compliance hash
• [ ] Audit export tested (docs/compliance/audit-trail-export-format.md)

Sign-off

Date cleared: _______________