Ematia
Ematia Limited Governance framework

What the parent decides, and what it refuses to decide.

Ematia Limited owns two operating brands and governs them at arm's length. This page sets out how ownership works, where each brand stands with its regulators, how client funds are treated, and the conditions a brand has to meet before it moves forward.

Ownership and control

One owner, two mandates, no shared trading book.

Ematia Limited is a private company registered in England and Wales under number 14798473. It holds Pegasus Alfa and Serafim Global outright. The parent allocates capital, appoints management and sets the rules below. It does not trade, does not hold client money, and is not itself a regulated firm.

What the parent does

Capital, appointments, mandate

Funds each brand, approves its mandate and scope, appoints and removes its management, and holds the authority to stop a launch. Group-level policy on separation, safeguarding and disclosure is set here and is not negotiable at brand level.

What the parent does not do

Client relationships and day-to-day trading

Does not contract with clients, hold client funds, or run the operations of either brand. Clients contract with the brand, under that brand's own terms and its own regulator. Ematia Limited is not a party to those arrangements.

The rules the parent does not bend

Three constraints, applied in this order.

They are numbered because the order matters. Separation is a precondition for authorisation, and authorisation is a precondition for launch. A brand cannot pass the third by arguing about the first.

1
Separation

Separate brands, separate books

Pegasus Alfa and Serafim Global share an owner and nothing else. Different clients, different regulators, different ledgers, different terms.

Neither brand trades on the other's name, is presented as part of the other, or relies on the other's permissions. Client data does not move between them. Ematia Limited's other interests are not associated with either brand.

2
Authorisation

Permission before activity

No regulated activity begins before the permission covering it is in place. Building, testing and integration work continue in the meantime; taking client funds does not.

Moving a system from test to live is treated as a regulatory event with its own approval, not as a configuration change an engineer can make.

3
Sequencing

Gates, not calendars

Each phase of a rollout opens only when the conditions for it have been verified. A launch date is the outcome of passing a gate, never a reason to skip one.

Commercial pressure is not a condition. If a gate is not met, the phase waits, and the parent expects to be told rather than managed around.

Regulatory position

Where each entity currently stands.

Stated plainly, including where permission has not yet been granted. Nothing below should be read as a claim to hold a permission that is still pending.

Entity
Regime
Status
Ematia LimitedParent · England & Wales
Companies Act. Holding company, no regulated activity carried on.
Not a regulated firm
Holds the brands; does not contract with clients or hold client money.
Pegasus AlfaFintech · brand of Ematia
Financial Conduct Authority. Payments and e-money permissions, with safeguarding requirements attaching to client funds.
Application pending
Not currently authorised. No regulated service is offered and no client funds are held until authorisation is granted.
Serafim GlobalGlobal trade & blockchain · held through Ematia
Designed against MiCA Title II as an other crypto-asset, UK financial promotion rules, and the FINMA functional-at-issuance test for utility tokens.
Business counterparties only
No public offering, no pre-sale, no retail participation. SERA carries no fiat backing and no redemption right.
Client funds and fee treatment

Money that belongs to a client is never money the business can spend.

The distinction is designed into the ledger rather than reconciled afterwards, because a control that depends on someone remembering to apply it is not a control.

Safeguarding

Client funds held apart

Safeguarded client funds are held separately from group and brand operating cash, in accounts that exist for that purpose alone. Operating expenses are never met from safeguarded balances.

Fees

Recognised as a separate entry

A fee earned against a client transaction is booked as its own double entry and moved out of the safeguarded pool deliberately. Fee income is never allowed to sit inside client balances.

Attestation

Records are not instruments

A Serafim Proof Record attests that a verified trade event occurred. It is non-fungible, non-transferable and has no market. It is evidence, not an asset, and is not offered as one.

Utility

Earned, not sold

SERA is capped at 1,000,000,000 units, earned against verified attestation and transferable only between approved counterparties. Founder allocation is 10%: half a non-transferable, slashable operating bond, half held in treasury under external co-signature.

Phase gating

Four phases. Each one opens on evidence.

The pattern below governs Serafim Global's rollout and is applied to Pegasus Alfa in the same spirit. A phase is a state the business is in, not a quarter in a plan.

Phase one

Build and verify in a closed environment. Counterparties are named, volumes are bounded, and nothing settles for value.

Phase two

Live attestation with a limited set of verified counterparties. Records are created against real trade events; the utility layer stays closed.

Phase three

Utility opens to approved counterparties under permissioned transfer, once the attestation record has held up in production.

Phase four

Wider counterparty admission, subject to the regulatory position in each jurisdiction being settled rather than assumed.

Disclosure and enquiries

If something here does not match what you were told, tell us.

Group governance, regulatory and compliance enquiries reach the parent directly. Complaints about a service reach the brand that provides it, under that brand's own complaints procedure.

Group enquiries
Registered office
Ematia Limited
College House, 17 King Edwards Road
Ruislip HA4 7AE, United Kingdom
Brands
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