§ 01 — THE FOUR LAYERS

Each layer is verifiable. By a different external party.

Cryptographic anchoring is verifiable against the Bitcoin blockchain. Transport & storage controls are verifiable against AWS CloudTrail and KMS audit logs. Attestation is verifiable against the publicly-posted CPA report. Insurance is verifiable against carrier-issued certificates of coverage.

01CRYPTOGRAPHIC
FBC/LAYER/01

SHA-256 + OpenTimestamps. Math, not promises.

Every document under custody is hashed with SHA-256 (FIPS 180-4) at deposit, and the resulting digest is anchored to OpenTimestamps — a free, open-source timestamping service that commits hashes to the Bitcoin blockchain. After ≥3 Bitcoin confirmations, the anchor is mathematically final: undoing the timestamp would require reorganising the Bitcoin chain. Investors and sponsors can independently verify custody records and timestamp proofs against the published transaction code.

For sponsors who prefer a traditional PKI-rooted proof, an RFC 3161 co-anchor (DigiCert or Sectigo TSA) is available as an opt-in. The two anchors are independent — and validate the same hash against two different trust roots.

Hash function
SHA-256 (FIPS 180-4)
Primary anchor
OpenTimestamps · Bitcoin mainnet
Co-anchor (opt-in)
RFC 3161 · DigiCert / Sectigo TSA
Finality threshold
≥ 3 Bitcoin confirmations
Proof artifact
.ots file · retained alongside document · downloadable
Independent verification
ots-client (open source) · or any Bitcoin full node
02TRANSPORT
FBC/LAYER/02

AES-256 at rest. TLS 1.3 in transit. Logged on every access.

Document objects are encrypted at rest with AES-256-GCM under KMS-managed keys. Each sponsor's SPVs are isolated into separate storage buckets with separate KMS keyrings; there is no shared bucket and no cross-tenant key reuse. Every object read is logged via AWS CloudTrail; logs are retained for seven years and are available under AUP sampling.

Network access is TLS 1.3 only; legacy TLS, plaintext HTTP, and SSL are not negotiated. The verification endpoint is fronted by a CDN with HSTS preload, strict Content-Security-Policy, and rate limits applied per IP and per code. These controls also extend across the sponsor-facing API and webhook infrastructure documented on the Fund Base Camp integrations architecture page.

Encryption at rest
AES-256-GCM · KMS-managed
Tenant isolation
Per-SPV bucket · per-SPV keyring · no cross-tenant key reuse
Transport
TLS 1.3 · HSTS preloaded
Object access logging
AWS CloudTrail · 7-year retention
Rate limiting
Per-IP + per-code · 429 on exceed
Backup
Cross-region replication · 99.999999999% durability
03ATTESTATION
FBC/LAYER/03

Annual independent CPA. Procedures, sampled.

A licensed CPA firm — Lukas & Co. CPAs, engaged for the first period — will perform Agreed-Upon Procedures over Fund Base Camp's custody records annually. The procedures sample a defined number of custody entries; confirm the underlying documents exist; recompute the SHA-256 digests; verify the OpenTimestamps anchors resolve against the Bitcoin blockchain; and confirm the verification page returns accurate responses for the sampled codes. First engagement is scheduled for Q3 2026 — scope is drafted; fieldwork begins July 2026.

Each report will be published openly at this URL, and every verification response will reference the period and firm of the most recent attestation. SOC 2 Type I readiness is in progress; Type II is planned for the year following Type I. The operational independence structure supporting these controls is further explained on the Fund Base Camp company and governance overview.

Engaged firm
Lukas & Co. CPAs
First engagement
Q3 2026 · scheduled · scope drafted
Cadence
Annual · following report Q3 2027
Procedures
Sample · hash recompute · anchor verify · response sampling
Publication path
fundbasecamp.com/security (this page)
SOC 2 roadmap
Type I — in readiness · Type II — year 2
04INDEMNIFICATION
FBC/LAYER/04

E&O. Crime. Cyber. D&O. Carriers disclosed.

Fund Base Camp carries professional Errors & Omissions, a commercial crime / fidelity bond, cyber liability, and Directors & Officers coverage — sized to the dollar value of documents under custody, refreshed at each policy renewal. Certificates of insurance are provided to sponsors and their prospects on request. Carriers and limits are listed below in full.

Coverage exists for the protection of sponsors and their investors. Where a sponsor requires its prospects to be named as additional insured or for certificate-of-insurance language to be customised, this is accommodated at no incremental cost within standard tiers. Coverage support, onboarding scope, and custody tiers are outlined further within the Fund Base Camp pricing structure for sponsors.

Lines carried
Professional E&O · Crime / Fidelity Bond · Cyber Liability · D&O
Coverage period
Bound annually · 12-month policies
Certificate of Insurance
Issued on request to sponsor or sponsor's prospect
Additional insured
Accommodated at no incremental cost
Brokers
Embroker · Vouch · Newfront (fintech practice)
§ 02 — INSURANCE

Carriers, limits, effective dates. In full.

Refreshed at each policy renewal. Where coverage is shown as BINDING, the quote has been accepted and the policy is in the process of being issued; coverage is in force as of the effective date.

Line of coverage
Carrier
Limit (per claim / agg)
Effective
Status
Professional E&O
Beazley Syndicate · via Embroker
$2,000,000 / $4,000,000
2026-03-01 → 2027-02-28
BOUND
Commercial Crime / Fidelity Bond
Chubb (Federal Insurance Co.)
$3,000,000 / $3,000,000
2026-03-01 → 2027-02-28
BOUND
Cyber Liability
Coalition · primary layer
$3,000,000 / $3,000,000
2026-03-01 → 2027-02-28
BOUND
Cyber Liability · excess
At-Bay · excess layer
+$2,000,000 excess of primary
2026-03-01 → 2027-02-28
BINDING
Directors & Officers
Travelers · via Embroker
$1,000,000 / $1,000,000
2026-03-01 → 2027-02-28
BOUND
Commercial General Liability
Hiscox
$1,000,000 / $2,000,000
2026-03-01 → 2027-02-28
BOUND

Note   Limits scale with assets under custody. The figures above reflect coverage adequate for the current scope of custody (Limen Markets Series 2026-A LLC, ≤ $25M assets under custody). Layers will be increased prior to onboarding sponsors whose aggregate custody scope warrants additional coverage. Certificates of insurance issued on request to security@fundbasecamp.com.

§ 03 — INDEPENDENT ATTESTATION

Independent CPA · Agreed-Upon Procedures. Published.

The most recent AUP report is the artifact converting "we promise we hold the documents" into "an independent CPA confirms we hold the documents." Engagement is annual; cadence may increase to quarterly as scale warrants.

What the procedures cover.

Each annual engagement is performed by an independent licensed CPA firm under the AICPA's Statements on Standards for Attestation Engagements (SSAE). The procedures are pre-agreed and disclosed; the firm's role is to perform them and report findings, not to opine. These disclosure standards operate alongside the broader legal and compliance framework disclosed in the Fund Base Camp legal documentation center. The following are sampled or verified in every engagement:

  • A defined number of custody records sampled from the FBC system, confirming the underlying documents exist and match the recorded SHA-256 hash.
  • Confirmation that the Timestamp Anchor records resolve correctly against OpenTimestamps and (where applicable) the RFC 3161 co-anchor.
  • Confirmation that the chain of custody from document submission to current state shows no unauthorized modification, by replaying CloudTrail logs against the sampled records.
  • Confirmation that the verification page and API return accurate responses for sampled Transaction Codes.
  • Review of insurance certificates and verification that coverage is in force as represented at /security.
◷ AUP Report · Pending First engagement Q3 2026

Once the first engagement closes, the signed report will be published at this URL. Sponsors and counsel can be added to a notification list by emailing legal@fundbasecamp.com.

SOC 2   Fund Base Camp is in SOC 2 Type I readiness, with target Type I issuance in year 2 of operation and Type II issuance in year 3. Once SOC 2 Type II is in force, the annual AUP becomes complementary rather than primary for institutional audiences. Until then, the AUP is the primary independent attestation and is sufficient for the great majority of allocator due-diligence requests.

§ 04 — ARCHITECTURE

The system, drawn. Trust boundaries marked.

What's inside the Fund Base Camp trust boundary, what's outside it, where data crosses, and which controls govern each crossing. The boundary nodes are highlighted; anything inside the boundary is under FBC's direct control. Sponsors evaluating operational fit can review the broader onboarding and workflow process on the Fund Base Camp sponsor infrastructure page.

FBC SYSTEM TOPOLOGY · v2026.05 Boundary nodes ─── highlighted
INGEST · sponsor submits document via dashboard or API
EDGE
Node 01
Ingestion API
HMAC-authenticated · idempotent · request body streamed; never buffered to disk in plaintext.
Node 02
Hasher
SHA-256 computed as bytes stream past · digest returned synchronously with deposit response.
Node 03
Encrypted Object Store
AES-256-GCM at rest · KMS-managed keys · per-SPV bucket · CloudTrail access log.
EDGE
Node 04
OpenTimestamps Submit
Hash submitted to OTS calendars · proof artifact retained alongside object.
ANCHOR · hash committed to Bitcoin via OpenTimestamps
Node 05
OTS Aggregator
External · OpenTimestamps public infrastructure · aggregates submitted hashes into Merkle tree.
EXTERNAL
Node 06
Bitcoin Blockchain
External · Merkle root committed via Bitcoin txn · ≥3 confirmations = anchor final.
Node 07
Anchor Finalizer
Polls OTS for completed proofs · marks record FINAL · fires sponsor webhook.
Node 08
Code Issuer
Mints FBC-[series]-[role]-[ticket] · links to record · delivered to sponsor.
VERIFY · public read path · no PII returned
EDGE
Node 09
Verify Endpoint
Public · read-only · rate-limited per-IP and per-code · 200/404/429.
Node 10
Custody Index
Maps codes → records · no PII stored · queries not retained beyond rate-limit accounting.
Node 11
Receipt Generator
Builds self-contained PDF receipt · embeds proof and offline-verify instructions.
EXTERNAL
Node 12
CPA Sample Path
External · read-only access for AUP firm during engagement · revoked after report.
EDGE — exposed to public internet EXTERNAL — outside FBC trust boundary (unmarked) — internal · within FBC trust boundary
§ 05 — PERSONNEL & ACCESS

Who can touch what. And how it's recorded.

Access to custody materials is least-privilege by default, mediated by signed-in identity, and logged. The controls below cover human personnel; system-to-system access is covered by API key issuance and the architecture description above.

Control 01

Background checks

All personnel with any logical or physical access to custody materials pass a criminal and credit background check at engagement. Refreshed every three years and on role change.

Active · Checkr
Control 02

Identity & SSO

All access to dashboards, AWS, and internal tooling is mediated by single sign-on with hardware security key (FIDO2) MFA. Passwords alone are insufficient anywhere in the system.

Active · Okta + YubiKey
Control 03

Least privilege

No standing access to production object storage. Access is requested per-task, time-boxed (≤8h), approved by a second person, and logged. Read-only access is the default; write access requires explicit justification.

Active · IAM time-bound roles
Control 04

Operational separation

At least one authorised signer on FBC LLC is not a signer for any Limen Markets entity. Bank accounts, EIN, accounting books, signing authority, and IT environments are separate. The independence covenant is reviewed quarterly.

Active · disclosed in CSA
Control 05

Logging & retention

Every object read, every API call, every dashboard action is logged via AWS CloudTrail. Logs are retained seven years, immutable (S3 object lock), and replicated to a separate AWS account for tamper-resistance.

Active · 7y retention · immutable
Control 06

Vendor review

Subprocessors (KMS, CDN, email, SSO) are reviewed at engagement and annually thereafter; SOC 2 / ISO 27001 reports collected and retained. The subprocessor list is provided to sponsors and their counsel under NDA.

Active · reviewed 2026-Q2
§ 06 — DISCLOSURE

Found something? Tell us first.

We take responsible disclosure seriously and respond to security reports within one business day. Good-faith research is welcomed; we will not pursue legal action against researchers who follow the policy below.

Responsible disclosure policy.

If you've found a vulnerability — in the verification endpoint, the receipt PDF generator, the ingestion API, or anywhere else under fundbasecamp.com — please report it to security@fundbasecamp.com. General operational or sponsor inquiries should instead be directed through the official Fund Base Camp contact channel. PGP encryption is optional and available on request (see card alongside).

What we ask: give us a reasonable window (typically 90 days) to remediate before any public disclosure; do not access data that doesn't belong to you, beyond what's necessary to demonstrate the issue; do not degrade service for others.

What we commit: acknowledgement within one business day, status updates at least weekly while a report is open, credit (with your permission) once remediation is complete, and no legal action against researchers operating in good faith and within this policy.
PGP · SECURITY@FUNDBASECAMP.COM
emailsecurity@fundbasecamp.com
algoRSA 4096 · SHA-512
key idOn request
fingerprintOn request
PUBLIC KEY The PGP public key is provided on request to security@fundbasecamp.com — send a brief note describing the disclosure and we will reply with the current key and fingerprint via separate channels for out-of-band verification.
Plaintext email is also accepted; encryption is optional but appreciated for sensitive details.