Legal notice and Terms of Service

The full notice, in one place. Nothing here is hidden behind a disclosure, and nothing has been shortened for the web.

What FeeRelayer is, and what it is not

FeeRelayer is a stateless, non-custodial technical relay: you build and sign your own payment, and the relay only attaches the signature that covers the network fee. It never holds your funds, never opens an account for you, and never exchanges one asset for another on your behalf.

FeeRelayer is a stateless, non-custodial technical relay. You build and sign your own payment in your own wallet; FeeRelayer merely relays it and attaches a fee-payer signature so the network gas (SOL) is covered, then hands the transaction to independent third-party infrastructure for execution. Everything of substance is performed by external, independently-operated systems: the actual movement of funds and final settlement are carried out by the public Solana network through independent RPC / validator providers (such as Helius and Alchemy); any currency conversion the operator needs for its own gas wallet is carried out by an independent exchange (such as Jupiter). FeeRelayer charges a service fee, settled in USDC inside that same transaction: consideration for a relaying service, never a deposit, a balance, or an asset held on your behalf.

Not custodial. FeeRelayer never takes possession or control of your funds. It never holds your USDC or SOL. Your funds move directly from you to the recipient you chose; FeeRelayer only adds a co-signature. The USDC service fee is consumed as payment for the service, not stored.
Not an exchange. FeeRelayer does not exchange one asset for another on your behalf, does not convert fiat currency, and does not transfer value between users. You receive a signing/relay service in return for a USDC fee. No asset-for-asset exchange is performed for your account.
Not a wallet or key custodian. FeeRelayer does not generate, store, or control any user’s private keys.
Not a virtual asset service provider (VASP). FeeRelayer performs none of the activities that characterise a VASP: it takes no custody, operates no exchange or order book, and transfers no value between parties. Settlement is performed by the public Solana network through independent providers; any conversion is performed by an independent exchange. (This is the operator’s own characterisation of the service, not a binding determination of regulatory status. See the full notice below.)
Only a thin proxy — everything is done externally. FeeRelayer operates no validator, no exchange, no order book and no custody system. It merely forwards the transaction you signed to third-party, independently-operated RPC / validator infrastructure (such as Helius and Alchemy) for broadcast and settlement on the Solana network, and relies on an independent exchange (such as Jupiter) for any conversion. The regulated / heavy-lifting functions are all performed by those external systems, not by FeeRelayer.

1. Nature of the service

FeeRelayer provides a stateless, best-effort technical transaction-cosigning service. The sole consideration paid by the user is a service fee settled in USDC within the transaction the user constructs and signs. FeeRelayer takes no custody of, and acquires no title to, the user’s assets at any point.

2. No custody, no exchange, no money transmission for users

FeeRelayer does not hold, control, pool, or commingle user funds; does not exchange or convert assets on behalf of users; and does not move value from one user to another. Each transaction is initiated, authorised and signed solely by the user, who alone controls the destination and amount.

3. Treasury management (internal)

To sustain the gas wallet that pays network fees, the operator periodically converts a portion of its own accumulated USDC service-fee revenue into SOL through an independent third-party exchange (such as Jupiter), as an ordinary customer of that exchange. This is internal corporate treasury management of the operator’s own working capital. It is not an exchange, conversion, brokerage or asset-management service offered to, or performed for, any user.

4. No account, no KYC

Because the service is a stateless technical relay that never takes custody, FeeRelayer opens no accounts, holds no balances, and performs no identity verification. The service is permissionless: anyone may deploy and operate their own relay, and the relay used for any payment is the one selected by the user in their own wallet.

5. Provided “as is”, no warranty

The service is provided “as is” and “as available”, on a best-effort basis, with no warranty of availability, transaction finality, or fitness for a particular purpose. To the maximum extent permitted by law, the operator disclaims all liability for loss arising from use of the service. You are solely responsible for the content and correctness of the transactions you sign, for the security of your keys and funds, and for your own legal and tax compliance in your jurisdiction.

6. United States money-transmission / MSB position (FinCEN / BSA)

The operator’s position is that FeeRelayer is not a money services business (“MSB”) or a money transmitter under the U.S. Bank Secrecy Act and FinCEN’s regulations (31 CFR Part 1010). This position rests on the factual design of the service:

No acceptance or control of customer funds. A money transmitter must both accept and transmit value. FeeRelayer never accepts, holds, pools or controls customer funds. The USDC service fee is consideration paid to the operator for a technical service and is consumed within the user-signed transaction. It is not value accepted for transmission to a third party.
No transmission of value for third parties. FeeRelayer does not move value from one person to another. The user alone selects the recipient, amount and timing and signs the transfer; FeeRelayer only sponsors the network gas by adding a fee-payer signature. Final settlement is effected by the public Solana network, not by the operator.
No fiat currency. No fiat currency is accepted, held, converted or disbursed at any point in the flow.
Technical / network-access role only. FeeRelayer’s function is limited to relaying and broadcasting a transaction the user has already constructed and signed: the kind of delivery, communication and network-access support that falls outside the money-transmitter definition (see 31 CFR 1010.100(ff)(5)(ii) and FinCEN guidance FIN-2019-G001).

The operator intends to obtain and retain a formal written legal opinion from qualified U.S. crypto counsel confirming this analysis. This statement reflects the operator’s position and the factual design of the service; it is not legal advice and is not a determination by any regulator.

7. European Union position (MiCA / PSD2)

The operator’s position is that FeeRelayer does not require authorisation as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 (MiCA), nor as a payment or e-money institution under Directive (EU) 2015/2366 (PSD2) / the E-Money Directive. This rests on the factual, non-custodial design of the service:

No custody (MiCA). FeeRelayer provides none of the custodial crypto-asset services regulated by MiCA: it never holds, controls, safeguards or administers crypto-assets or the means of access to them on behalf of any client.
No exchange for clients (MiCA). It does not exchange crypto-assets for funds or for other crypto-assets on behalf of clients, operates no trading platform and no order book. The transfer is performed by the user’s own wallet; any conversion the operator makes is for its OWN gas treasury, as an ordinary customer of an independent exchange.
No execution or transmission of orders (MiCA). There is no reception, transmission or execution of client orders — there are no orders, only user-signed on-chain transfers.
Express PSD2 technical-service-provider exclusion (Art. 3(j)). Even if read as payment-adjacent because USDC is an e-money token, FeeRelayer falls squarely within the exclusion in Article 3(j) of PSD2 for “technical service providers… which support the provision of payment services, without entering at any time into possession of the funds to be transferred”. FeeRelayer never enters into possession of any funds: it only attaches a network-fee (gas) co-signature and relays an already user-signed transaction to independent infrastructure.
User-initiated and user-controlled. Every transfer is constructed, authorised and signed solely by the user, who alone selects the recipient, the amount and the timing. FeeRelayer cannot originate, alter, redirect, delay or reverse a transfer.
External, decentralised settlement. Final settlement is performed by the public Solana network through independent RPC / validator providers. The operator runs no validator, no exchange and no settlement system.
Permissionless and non-exclusive. Anyone may deploy and operate their own relay; the relay used for any payment is the one the user selects in their own wallet. FeeRelayer is one interchangeable technical option among many, not a gatekeeper or a necessary intermediary.

As with the U.S. position above, the operator intends to obtain and retain a formal written legal opinion from qualified EU counsel. This statement reflects the operator’s own reasoned position based on the factual design of the service; it is not legal advice and is not a determination by any regulator or competent authority.

8. Not legal, tax or financial advice

Nothing on this page is legal, tax, regulatory or financial advice. The descriptions above reflect how the service is designed to operate; they are not a determination of any party’s regulatory status. If you operate or integrate a relay, obtain your own professional advice as to the rules applicable to you.

Donations

A donation to the gas wallet is an irrevocable gift to the operator: no refunds, no balance, no ledger, no promise of service. Every relay charges its published fee to every user, donor or not.