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This page describes Barker’s compliance posture and provides suggested user-facing language. It is not legal advice. Consult your own counsel for jurisdictional requirements.

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Custody model

Barker Yield Engine is 100% non-custodial:
  • User funds move directly from the user’s wallet to a BarkerEngine smart contract via on-chain transactions the user signs themselves.
  • Barker does not hold private keys, custody assets, or sign transactions on behalf of users.
  • The BarkerEngine contract has no admin withdrawal path. The only ways assets leave are: (a) the share-holder calling redeem / withdraw, or (b) EmergencyWithdraw which redeems from the underlying vault back into the engine itself (does not transfer to any external party).
  • Both Barker’s and the partner’s fee income are share allocations (yield-only, after the fact) — neither party can extract user principal.

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KYC / AML responsibility

The party who onboards the end user owns KYC/AML. In practice:
ModeOnboarding partyKYC/AML owner
Embed iframePartner — user lands in Barker iframe from inside the partner’s productPartner
Headless APIPartner — user signs deposit in the partner’s UIPartner
Barker does not collect, retain, or screen end-user PII. If your jurisdiction requires KYC for the deposit flow, you must run it before the user signs approve / deposit. For sanctions screening, treat the deposit as if you were the on-ramp: screen the wallet address against your sanctions list before allowing the transaction. Barker performs partner-level due diligence; partners perform user-level due diligence.

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What to disclose to your users

Before a user signs their first deposit, show:
  1. Non-custodial nature — “Your funds remain on-chain in a smart contract; [Partner] and Barker never take custody.”
  2. Variable APY — “APY is variable and reflects current rates. It is not a guaranteed return.”
  3. Underlying vault risk — “Yield is generated by an underlying ERC-4626 vault [link to underlying]. Risks include smart contract bugs, oracle failures, depeg of stablecoin assets, and counterparty risk in the underlying protocol.”
  4. No deposit insurance — “Deposits are not covered by FDIC, SIPC, or equivalent deposit insurance.”
  5. Withdrawal mechanics — “Withdrawals execute on-chain and may be subject to underlying vault liquidity. In normal conditions, withdrawal is instant.”
  6. Smart contract risk — “BarkerEngine is open-source [link to source]. Smart contract risk is inherent in DeFi; deposit only what you can afford to lose.”

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Suggested copy block

By depositing, you acknowledge:

• Funds remain in your wallet's control via a smart contract — neither
  [Partner] nor Barker takes custody.
• APY is variable and not guaranteed. Past returns do not predict future
  returns.
• Yield comes from an underlying DeFi protocol [link]. You are exposed to
  that protocol's smart contract, oracle, and counterparty risk.
• Deposits are not covered by deposit insurance.
• You are responsible for tax reporting on yield earned.
• Withdrawals execute on-chain and depend on underlying vault liquidity.
Adapt to your jurisdiction’s required language. We’ve seen partners place this as a checkbox before the deposit button, or as a one-time onboarding modal — both work.

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Audit & verifiability

  • BarkerEngine and BarkerEngineFactory source code: github.com/YBSbarker, verified on each chain’s block explorer.
  • All AUM verifiable on-chain: any block explorer call to engine.totalAssets() returns the true total.

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Sanctions and prohibited jurisdictions

Barker’s terms restrict the service from being offered to:
  • Persons or entities on OFAC SDN, EU consolidated, or UK HMT sanctions lists
  • Residents of comprehensively sanctioned jurisdictions (consult your counsel for the current list)
  • Persons who would be prohibited from accessing DeFi protocols generally
Partners are responsible for enforcing these restrictions in their own product. If your user base spans jurisdictions, build a geo-block / sanctions screen into your onboarding.

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Tax

Yield earned through Barker is generally treated as interest or investment income in most jurisdictions, but tax treatment varies. Barker does not issue tax forms. Partners should:
  • Surface a “view earnings” report (the fee-stats endpoint provides daily yield per user-position)
  • Direct users to consult their own tax advisor

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Data we hold

For partner accounts (your team, not your end users):
  • Partner organization name, contact email, fee recipient wallet address
  • API key hashes (raw keys never stored)
  • API request logs for rate limiting and abuse detection (typically 30 days)
For end users: none directly. We see anonymous wallet addresses from on-chain events, never PII.

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Contact

Compliance questions: compliance@barker.money. For partner-tier disclosures (e.g. financial statements, audit reports, due-diligence questionnaires), reach out via your account manager.

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What’s next

  • Smart Contracts — verify what you’re integrating against
  • Webhooks — vault_pause events let you halt deposits proactively