Guidelines

1. The Principle

Bankroll Network does not do paid marketing. Never has. Never will.

This is not a budget decision. It is an architectural one.

The product is not the token — it is the composition of the holder base: a network of communities, builders, and aligned capital where the whole is larger than any one participant. Composition can only be curated, never broadcast for. Growth that must be bought is growth the network cannot keep.

2. The Alignment Test

Every participant, partner, and dollar is measured against one question:

Does their upside require the network to succeed — or just require the spend to happen?

• Holders pass. Their stake is the network.
• Community stewards pass. They bring in people who trust them personally, staking their own reputation.
• Aligned capital passes. Partners whose own mission is advanced by the network’s growth win when we win — no control required.
• A marketing firm fails by construction. Its upside is the invoice. It gets paid whether the network lives or dies.
• A paid “investor Rolodex” fails twice. Its payday is any check closing, fastest money first — the concentrated, unaligned capital the network deliberately defers.

3. What We Do Instead — Earned Attention

“No paid marketing” does not mean “no communication.” The network communicates constantly — through channels that must be earned:

• Open data. Dashboards, on-chain records, verifiable metrics. The network’s story is checkable, not told.
• Documentation and education. Clear explanations of how the contracts work, for anyone.
• Direct relationships. Founders and stewards speaking with communities and partners personally.
• Podcasts, talks, interviews, and press — accepted, never purchased.
• Community-created content. Made freely, by participants, because they hold what they talk about.

The line: earned attention, yes. Purchased reach, no.

Jurisdiction note (EU / MiCA). “Earned” does not mean “unregulated.” Under MiCA, marketing communication is read broadly — press releases, interviews, presentations, and social posts connected to a public offer or to admission to trading in the EU can qualify even when nothing was paid for them, and Articles 7 and 9 apply to marketing communications published after 30 December 2024 even for assets already trading. Any network communication connected to an EU offer or EU trading admission must therefore be: (a) clearly identifiable as a marketing communication, (b) fair, clear, and not misleading, (c) consistent with the crypto-asset white paper where one exists, and (d) accompanied by the statement MiCA mandates regarding non-review by any competent authority. [Refs 1–3]

4. What the Policy Excludes

The following are outside the network’s playbook, permanently:

• Marketing agencies and PR firms engaged for promotion.
• Paid influencers, KOLs, or shill campaigns — including payment in tokens.
• Paid investor introductions or finder’s fees. Compensation tied to capital closing is broker activity, not marketing, and it sources exactly the wrong capital.
• Paid exchange listings. Listing is distribution. Purchased distribution is purchased composition. Listings happen organically or not at all.
• Engagement farming — bots, paid trending, follower purchases, wash or incentivized trading volume, and coordinated inauthentic activity in any form, on-chain or off.

4.1 Canonical Channels, Independent Speech, and Paid Placement

The Bankroll marks and materials carry no copyright or trademark protection. Everything is public domain — anyone may use, fork, or repost any of it. The network does not police speech; it defines its own.

• Canonical channels are the network’s voice — and its only voice. Only content published at the official domain, the official GitHub, and the official social accounts speaks for the network. Everything published anywhere else, by anyone, is unaffiliated — including content by stewards and holders.
• The policy is the authentication. Because the network never runs, funds, approves, or reimburses paid placement anywhere, any paid advertisement referencing Bankroll is, by definition, not the network. “If it’s an ad, it isn’t us” is a verification rule anyone can apply.
• Third parties act at their own risk. Because the materials are public domain, anyone may discuss, promote, or market Bankroll without permission — and without endorsement. Any third party who does so acts independently, at their own expense and sole legal risk, and is solely responsible for compliance with the laws of every jurisdiction their activity reaches, including compensation-disclosure, securities, commodities, advertising, and consumer-protection requirements. The network does not review, approve, endorse, supervise, or assume any responsibility for third-party content, and no use of public-domain materials creates any affiliation with, or authorization by, the network.
• Paid placement is incompatible with the steward role. A steward who runs an ad is acting as an unaffiliated individual, using public-domain material at their own expense, under their own name, with their own disclosure obligations (Sections 5 and 8; FTC material-connection rules). The network does not pre-approve, coordinate, supply creative for, reimburse, or reward such activity — before or after. Coordination is what creates network liability, and it does not occur.
• Canonical does not mean unregulated. Content on official channels is unpaid, but it is where the issuer is unambiguously speaking — so it is where the claims discipline in Section 7 and, for EU-connected activity, MiCA’s marketing-communication requirements apply most strictly, not least.

4.2 Materials, Merchandise, and the Production / Placement / Speech Test

Spending money is not the same as paid marketing. The policy prohibits purchased reach and purchased speech — not production. Every expenditure sorts into one of three buckets:

• Production — permitted. Paying vendors to make things: printing, design, merchandise, hosting, event materials. A vendor supplies the network; it does not speak for it. Shirts, stickers, one-pagers, and handouts are in-bounds to produce.
• Placement — prohibited. Paying for where something appears: ads, boosted posts, billboards, sponsored newsletter slots, paid listings, paid conference booths. Purchased reach in any form, physical or digital.
• Speech — prohibited. Paying anyone — in cash, tokens, merchandise, or anything of value — to say anything. The network has no paid spokespersons and never will. Every holder and steward is compensated solely by the performance of their own holdings: the only benefit anyone earns for speaking about the network is the appreciation of a stake they already own, which they disclose whenever they speak (Section 8).

Distribution of produced materials must itself be voluntary and unpaid — someone choosing to wear the shirt or hand a flyer to their congregation is earned attention in physical form. All printed and physical materials carry the full claims discipline of Section 7 and, where connected to EU activity, MiCA’s marketing-communication requirements (Section 3).

4.3 Named Practices

Common industry practices, named plainly so no one has to interpret the buckets.

Prohibited — these are purchased reach or purchased speech, whatever they are called

• Paid AMAs. Paying a community, channel, or host for an AMA or interview slot is purchased placement. Unpaid invitations are earned attention and welcome.
• Quest and task platforms. Token rewards for follows, retweets, joins, reposts, or any “social task” are payments for speech and engagement farming, regardless of the platform that packages them.
• Task-conditioned airdrops. Any airdrop that requires a social action, sign-up, referral, or promotional task to qualify is a payment for that task and is prohibited.
• Affiliate and referral compensation. Paying anyone per buyer, per sign-up, or as a share of proceeds for bringing in purchasers is compensated solicitation. It is prohibited as speech-for-pay and may separately require broker registration (Appendix, Ref 13).
• Paid press. Paid articles, advertorials, press-release wire placements, and “featured in” packages are purchased placement. Coverage a journalist chooses to write is earned.
• Paid call groups and signal channels. Compensating any group or channel to feature, “call,” or signal the token, in any currency.
• Paid launch and promotion programs. Paying an exchange, launchpad, or platform to feature, promote, or spotlight the token or any sale of it.
• Market makers. The network engages no market makers. All liquidity is protocol-native and on-chain, and anyone can verify this. Paid volume is manufactured volume, and manufactured volume fails the same test as trading competitions (Section 5).

Permitted — these reward building and participation, or ask for nothing at all

• Hackathon prizes and builder grants. Rewards for building on the network are participation incentives at their best, judged by the composition test.
• Retroactive airdrops. Airdrops to addresses that have already participated — held, deposited, built, integrated — reward what has already happened and require nothing in return. Permitted.
• Free gifts of tokens. Giving someone tokens freely — with no condition, no required task, and no expected promotion — is permitted and encouraged. It is one of the best things a steward can do: it makes someone a holder, and holders are the network. A steward gifting from their own holdings is spending their own property to grow the whole. Two rules keep gifts clean: nothing may be asked or expected in return, and a recipient who later speaks about the network discloses the gift like any other holding (Section 8).
• Unpaid appearances. Interviews, podcasts, panels, and AMAs the network or its stewards are invited to, without payment in either direction.

The test behind every entry is the same: a gift asks for nothing; a payment asks for something. The moment a transfer of value expects speech, reach, or the appearance of demand in return, it is prohibited — no matter what the invoice calls it.

5. Token Incentives — The Hard Edge

Incentives paid in tokens are marketing spend in token form. The alignment test applies:

• Incentives may reward participation: deposits, integrations, building, tenure, contribution to the protocol.
• Incentives may never reward promotion: posts, threads, referrals-for-reach, or any compensated speech about the token.

Incentives that reward verifiable on-chain participation — deposits, integrations, building — are protocol design, not marketing, and are judged by the same composition test as everything else. Incentives that reward speech, in any form, are marketing and are prohibited.

Incentivized volume is prohibited. Incentives may never reward trading volume, transaction count, or any activity whose primary value is the appearance of demand. Trading competitions, and prizes tied to trading activity, are prohibited: incentivized volume is inauthentic volume — it corrupts the network’s own on-chain record, misrepresents organic demand, and approaches market-manipulation exposure under CFTC anti-fraud authority (Rule 180.1) regardless of intent. A third-party venue running such a promotion does so under Section 4.1 — independently, at its own risk, with no network participation, co-promotion, or funding. [Refs 3, 10]

Structural rule: no reward may ever be conditioned on, correlated with, or awarded in proximity to public speech about the token. Participation rewards and public commentary must be legible as unconnected — by program design, not by intention. Compensated speech about a token without full disclosure of the nature and amount of that compensation is the core of the SEC’s anti-touting provision (Securities Act §17(b)), which requires no intent to violate; the safest program is one where the question can never arise. [Refs 4–7]

6. Community Support vs. Purchased Reach

The network supports its communities. That is the mission, not marketing. The distinction:

• Funding a community’s own work — a congregation’s program, a builder’s tooling, a local initiative — honors the relationship. ✓
• Paying a community or public figure to promote the token buys the relationship. ✗

The test: if the support disappeared, would the relationship remain? If yes, it was support. If no, it was a purchase.

7. Claims Discipline

Trust compounds; exaggeration compounds faster. All communication — official or from stewards — holds to one standard: say exactly what is true.

• Describe commitments, partnerships, and integrations precisely as they exist. “In conversation” is not “committed.” An individual is not an institution.
• No price commentary, no return projections or return language, no “guaranteed,” no “can’t lose.” Market performance is publicly observable; no one comments on it or predicts it on the network’s behalf.
• Anything that can’t be verified on-chain or in writing doesn’t get claimed.

Regulatory posture — classification-agnostic. The US classification of digital assets remains in motion: the SEC/CFTC joint interpretive release of March 2026 established a five-category taxonomy (digital commodities, collectibles, tools, stablecoins, digital securities), and the CLARITY Act — which would grant the CFTC exclusive jurisdiction over digital commodities and create a decentralization safe harbor — has passed the House but remains pending in the Senate. Interpretive guidance is not statute. The network therefore holds all communications to securities-grade standards regardless of expected classification: even as a commodity, misleading statements remain actionable under CFTC anti-fraud authority (CEA §6(c)(1); Rule 180.1). Immutable contracts and the absence of admin keys support a decentralization posture, but no communication may assume or assert a settled classification. [Refs 8–11]

8. Language

Words carry legal and cultural weight. The network’s vocabulary:

• Stewards / ambassadors / community — not “promoters.”
• Participants and holders — not “investors” in community communication.
• The network — not “the project” or “the team” as the center of gravity. The community is the center of gravity.

A title changes nothing legally. Calling someone a steward instead of a promoter does not alter any disclosure duty. Any steward who holds tokens, or who has received anything of value from the network, discloses that holding or affiliation whenever speaking publicly about the network — every time, every platform. This satisfies FTC material-connection requirements and removes any anti-touting ambiguity before it can exist. [Refs 4, 12]

9. Mercenary Capital

Speculative capital will arrive on its own, attracted by price movement. That is expected and acceptable — late, on top of a composed base, as liquidity around a committed core. The policy exists so it never arrives first and becomes the base.

One rule governs it: never count it. No treasury planning, governance weight, or growth assumption is built on capital attracted solely by short-term price movement.

10. Verifiability

This policy is not a claim — it is verifiable:

• No marketing wallet exists. Treasury flows are on-chain.
• Contracts are immutable, with no admin keys. Nothing is quietly changed.
• This document is public. Anyone can hold the network to it.

A network with nothing to hide doesn’t need to be sold. It needs to be seen.

Appendix — Regulatory References

Reviewed August 2026. Regulatory frameworks are evolving; this appendix reflects the state of law and guidance as of that date and should be re-verified periodically and before any public offer, listing, or capital raise. Nothing in this document is legal advice.

European Union

1. Regulation (EU) 2023/1114 (Markets in Crypto-Assets, “MiCA”), Article 7 — Marketing communications relating to an offer to the public or admission to trading of crypto-assets must be clearly identifiable as such; fair, clear, and not misleading; consistent with the crypto-asset white paper; and include the mandated statement that the communication has not been reviewed or approved by any competent authority, with the offeror solely responsible for its content.
2. MiCA Articles 9 and 12 — Publication and modification requirements for white papers and marketing communications; competent authorities may require issuers to cease or amend non-compliant marketing communications.
3. MiCA Article 143(2) (transitional provisions) and ESMA MiCA Q&As — For crypto-assets already admitted to trading before MiCA’s full application, Articles 7 and 9 apply to marketing communications published after 30 December 2024. ESMA guidance treats advertising messages in any medium — including press articles, press releases, and interviews — as potential marketing communications.

United States — Securities

4. Securities Act of 1933 §17(b), 15 U.S.C. §77q(b) (“anti-touting”) — Prohibits publicizing a security for consideration received, directly or indirectly, from an issuer, underwriter, or dealer without full disclosure of the nature and amount of that consideration. No showing of intent is required.
5. SEC v. Kim Kardashian, Admin. Proc. (Oct. 2022) — $1.26M settlement for promoting EthereumMax without disclosing $250,000 compensation.
6. SEC v. Paul Pierce, Admin. Proc. (Feb. 2023) — Settled charges for touting the same token without disclosing $244,000+ in compensation; the SEC treated individual tweets, including emojis and “to the moon” phrasing, as actionable promotional statements.
7. SEC v. Sun et al. (Mar. 2023) — Issuer and its principal charged with aiding and abetting §17(b) violations for orchestrating undisclosed celebrity touting; demonstrates issuer-side liability for promoter non-disclosure.

United States — Classification & Commodities

8. SEC/CFTC Joint Interpretive Release Nos. 33-11412 and 34-105020 (Mar. 17, 2026) — Five-category token taxonomy: digital commodities, digital collectibles, digital tools, stablecoins, and digital securities; CFTC to administer the Commodity Exchange Act consistently with the classification.
9. Digital Asset Market Clarity Act of 2025 (“CLARITY Act”) — Passed the House July 2025 (294–134); cleared Senate Banking Committee May 2026 (15–9); merged Senate text July 2026; not yet enacted as of August 2026. Would grant the CFTC exclusive jurisdiction over digital commodity spot markets, create registration categories for digital commodity exchanges, brokers, and dealers, and provide a conditional safe harbor for sufficiently decentralized protocols.
10. Commodity Exchange Act §6(c)(1), 7 U.S.C. §9(1), and CFTC Rule 180.1, 17 C.F.R. §180.1 — Anti-fraud and anti-manipulation authority over commodities in interstate commerce, including false or misleading statements; applies to digital commodities independent of securities status.
11. GENIUS Act (enacted July 2025) — Federal framework for payment stablecoins; relevant to any stablecoin-adjacent product communications.

United States — Promotion & Intermediaries

12. FTC Endorsement Guides, 16 C.F.R. Part 255 — Endorsers must clearly disclose material connections to the marketer, including payments, free products or tokens, and business or affiliate relationships; applies to all product endorsements regardless of securities status.
13. Securities Exchange Act of 1934 §15(a), 15 U.S.C. §78o(a) — Broker registration requirement; persons compensated for effecting or soliciting securities transactions, including transaction-based “finder’s fees” for investor introductions, generally must register. Engaging unregistered finders can expose an issuer to rescission claims and related liability.

These guidelines apply to official channels and to anyone representing the network in a steward capacity. Bankroll Network’s smart contracts are permissionless and immutable — there is no DAO and no governance process, because there is nothing to govern. These guidelines are authored and maintained by the protocol maintainer and supporting legal counsel. The principle in Section 1 is not amendable.