Compliance & structure

Built to be boring

One corporation, one class of stock, one register. Here is the legal structure, the controls, and the tests we watch every month.

Structure

One company, no fund

Fifth Meridian Energy, Inc. is a Delaware C-corporation. One company, one class of common stock, sold continuously at NAV per share. The acquisition engine that finds and prices the interests it buys is AIsopach (aisopach.com), licensed by the company's manager.

The company owns its oil and gas interests directly. There is no fund, no general partner, no manager entity, no blocker. It sells one class of common stock continuously at NAV per share and pays distributions out of the cash the wells produce.

Why not a fund

A company whose business is owning and operating oil and gas interests is not an investment company. We rely on the Investment Company Act §3(c)(9) posture — substantially all of the business is owning or holding oil, gas or other mineral royalties or leases, or fractional interests in them — and, independently, the §3(a)(1)(C) 40% test: investment securities must stay below 40% of total assets excluding cash and government securities. The only investment security the company holds is the ADHI block, which is why it is disclosed, marked monthly and monitored against a 30% warning line.

Investment Company Act monitor

Live balance sheet unavailable.

Regulatory posture

Securities
Common stock; Regulation A Tier 2 (once qualified), Rule 506(c), Regulation S
Exchange Act
Section 12(g) registration when holder-of-record thresholds are met; transfer agent registered with the SEC
Ongoing reporting
Reg A Tier 2: annual (1-K), semi-annual (1-SA) and current (1-U) reports
Tax status
C-corporation; U.S. real property holding corporation (FIRPTA applies to non-U.S. holders' return-of-capital portion)
Resale limits
Rule 144 / Regulation S 12-month restricted period for 506(c) and Reg S shares; none for Reg A
Share ledger
Transfer agent register; mirrored on-chain under DGCL §224 with permissioned transfers

Controls

Who can hold shares, and how we know

KYC

Identity & AML

Document and liveness verification, PEP and adverse-media checks for every shareholder, with periodic re-screening. Entities provide beneficial-ownership information.

506(c)

Accreditation

U.S. accredited investors are verified by a third-party service (income, net worth or professional licence) before any subscription is accepted. Verification letters expire and are renewed.

OFAC

Sanctions & wallet screening

Every shareholder is screened against OFAC and international sanctions lists. Every payout wallet is verified as the shareholder's own and screened with blockchain analytics before its first payment, and continuously thereafter.

REG

Regulation A limits

Non-accredited individuals under Regulation A are limited to 10% of the greater of annual income or net worth per 12 months; the portal enforces the limit at subscription.

TA

Transfer agent

The definitive shareholder register is maintained by an SEC-registered transfer agent. The on-chain ledger mirrors the register and can only move shares between verified holders; in any conflict the register controls.

NAV

Valuation committee

NAV is prepared by management from the reserve report, production data and the strip, reviewed by a valuation committee that includes independent directors, and published with its inputs. Marks on the ADHI block are approved by independent directors.

Custody and cash

Stablecoin balances — subscriptions awaiting conversion and distribution funding — are held with Coinbase Prime under a qualified custody arrangement with segregated accounts and multi-party approval for withdrawals. Dollar balances are held at an FDIC-insured bank. The company never holds shareholders' private keys and never lends or earns yield on customer stablecoin.

Service providers

Independent reserve engineer
Engaged annually; named in the offering circular
Auditor
PCAOB-registered firm; named in the offering circular
Transfer agent
SEC-registered; named in the offering circular
Custody
Coinbase Prime
Identity verification
Sumsub
Wallet & sanctions screening
Blockchain analytics provider

What we do not do

  • No lending, borrowing against shares, or margin of any kind.
  • No hedging, derivatives or commodity trading.
  • No yield on stablecoin balances.
  • No tokens other than the share ledger itself: a share is a share.
  • No general solicitation of U.S. non-accredited investors until Regulation A qualification.

Documents available on request

  • Offering circular (Regulation A) and private placement memorandum (506(c) / Reg S)
  • Certificate of incorporation, bylaws and plan of conversion
  • NAV policy and reserve report summary
  • Transfer agent and custody agreements (summary)
  • Share repurchase program terms

Request documents