Kim Kardashian SEC settlement (US$1.26M, October 2022)
Made clear that crypto-related endorsements without proper disclosure are legally costly.
Why we structured it this way
The guardrails are not decoration.
Three pieces of legal precedent shaped the program — each one a reason compensated crypto endorsements demand substantive disclosure.
FTC Endorsement Guides (November 2023 update)
Non-compliance can be fined up to US$53,088 per violation.
SEC Marketing Rule 206(4)-1
Treats compensated endorsements as adviser advertising — requiring substantive disclosure.
The result is a small, intentional program. Vetted educators only. Mandatory disclosure on every piece. Transparent compensation structure.
Curated, not crowdsourced
Three tiers of partnership.
Tier 1 is the deepest commitment; Tier 3 is the lightest. Each is a distinct, named partnership level — graded by depth, not by width.
- TIER 1
Tier 1 — Institutional partners
Established Spanish-language educational institutions and non-profit organizations.
Examples of fit
- ONG Bitcoin Argentina
- Recognized crypto research institutes
- Peer-reviewed academic publications
Engagement
- Joint research and co-authored white papers
- Institutional sponsorship of educational events (Labitconf, ETH Argentina, ETH México)
Compensation
- Project-specific grants or sponsorship fees. NEVER per-signup.
Disclosure
- All sponsored content carries the “STAXIS Sponsored” label per FTC Endorsement Guides; institutional independence preserved.
- TIER 2
Tier 2 — Vetted individual educators
Established Spanish-language crypto educators with verifiable track records of substantive educational content over multiple years.
Vetting criteria
- ≥3 years of published crypto educational content
- Verified identity (not anonymous)
- Audited track record of accurate disclosures in prior sponsored content
- No prior regulatory complaints or sanctions
- Spanish-language native or fluent (LatAm or Spain)
- Substantive content depth (not just market commentary)
Examples of fit profile (illustrative; not commitments)
- Hugo Botto / Healthy Pockets (Chile)
- Daniel Muvdi (Colombia)
- Tech con Catalina (Argentina)
- Jaime Merino (Mexico)
Engagement
- Substantive educational collaborations — podcast episodes, YouTube long-form, written guides — that introduce STAXIS in the context of broader crypto education.
- NOT promotional “use my code” calls.
Compensation
- Flat sponsorship fee per substantive content piece (negotiated per engagement, typically US$500–$5,000 depending on reach + depth).
- NEVER variable per-signup or per-funded-account — this is the part that creates regulatory exposure.
Disclosure mandatory
- “This content is sponsored by STAXIS” or equivalent — visible/audible from the start.
- Compensation disclosed in writing on the content page or video description.
- No claims about specific performance.
- Breaker disclaimer included verbatim in any mention of the breaker.
- Performance fees only for qualified clients reminder in any mention of the performance fee.
- TIER 3
Tier 3 — Evaluation engagement
For educators we are early in evaluating, or for individual content collaboration without ongoing partnership.
We may provide
- One-time educational content (interview; guest appearance; Q&A)
- Speaker fee for STAXIS-hosted educational events
We do not provide
- Ongoing affiliate links
- Per-signup commissions
- Free product access in exchange for promotion
Disclosure
- Standard sponsored-content disclosure on the specific piece.
Non-negotiable
Mandatory disclosures.
Every piece of partner content carries — visibly and at the start — these seven attestations. Reads like a Form ADV disclosure schedule because it is one.
Sponsorship disclosure
“This [video / post / podcast episode] is sponsored by STAXIS. [Educator name] has been compensated by STAXIS for this content. Read the full disclosure terms at staxis.ai/educator-program/disclosures.”
- For YouTube: in the video description AND in the first 15 seconds of video.
- For podcast: in the episode description AND verbally in the first 60 seconds.
- For written: at the top of the article.
- For social media: within the first 3 lines AND with the #SponsoredBySTAXIS hashtag.
No performance claims
Partners may NOT claim specific performance numbers (e.g., “STAXIS users made 30% last year”). They may discuss the architecture and the discipline.
SEC Marketing Rule 206(4)-1 and FTC §5 guidelines require performance claims to be substantiable and contextualized. We do this on our own surfaces; partners are not authorized to claim performance numbers on theirs.
Breaker disclaimer (verbatim)
In any mention of the 2.5%/3% breaker, the verbatim disclaimer must be included:
The 2.5%/3% circuit breaker is a technical risk control, NOT a guarantee of maximum loss. Market gaps, slippage, exchange outages, or technical failures may cause losses exceeding 3%. STAXIS does not insure against losses.
Spanish version (for events held in Spanish):
El circuit breaker del 2.5% / 3% diario es un control técnico de riesgo, NO una garantía de pérdida máxima. Slippage, gaps de mercado, outages del venue de ejecución, eventos de liquidez extrema, o fallas técnicas en STAXIS, en Privy, o en el exchange pueden ocasionar pérdidas que excedan el 3% diario. STAXIS no asegura contra pérdidas. El usuario es siempre el único titular de su capital y asume los riesgos correspondientes.
Performance fee tier qualification
When mentioning the Performance tier (0% management + 20% performance), partners must include:
Performance fees apply only to qualified clients per Advisers Act Rule 205-3 (US$2.7M+ net worth).
Jurisdictional gates
When introducing STAXIS to US audiences, partners must mention:
STAXIS geoblocks New York and gates California pending DFAL compliance.
No guarantee language
Partners must NEVER say:
- “Guaranteed returns” / “rentabilidad garantizada”
- “Risk-free” / “sin riesgo”
- “Win every time”
- “Get rich” / “hacerte rico”
- Anything implying performance is guaranteed
PSAV legend (Argentine partners)
Argentine partners targeting an AR audience must include the PSAV legend per CNV RG 994/2024 + RG 1058/2025.
Transparent
Compensation structure.
We publish compensation ranges so prospective partners and audiences understand the incentives.
Tier 1 — Institutional
- Sponsorship of educational events: US$1,000 — US$25,000 per event
- Research grants: US$5,000 — US$50,000 per project
- Co-authored white papers: editorial fee plus publication support
Tier 2 — Vetted individual educators
- Substantive content sponsorship: US$500 — US$5,000 per piece (flat fee)
- Speaking fees at STAXIS-hosted events: US$1,000 — US$5,000 per event
- NO per-signup commissions
- NO per-funded-account commissions
- NO ongoing affiliate revenue share
Tier 3 — Evaluation
- One-time content fee (interview, guest appearance): US$100 — US$1,000
- Speaker fees as above
Why flat, not variable
The fee never tracks conversions.
Variable compensation (per-signup, per-funded-account, ongoing revenue share) creates regulatory exposure because:
- Kardashian precedent. The Kim Kardashian SEC settlement (US$1.26M) established that compensated crypto endorsements without disclosure are enforceable violations.
- Marketing Rule 206(4)-1. The SEC Marketing Rule treats compensated endorsements as adviser advertising — and per-signup compensation makes the endorsement increasingly motivated.
- FTC material connection. The FTC Endorsement Guides (Nov 2023) require “material connection” disclosure — which becomes complicated to honestly disclose when compensation is variable.
Flat fees per content piece means:
- The educator’s compensation does NOT depend on whether the audience converts.
- The educator can give honest analysis without conversion incentive.
- The disclosure is simpler: “I was paid US$X for this piece.”
This structure means we attract educators who genuinely think STAXIS is a quality product — not educators looking to maximize affiliate revenue.
Application-based, deliberately selective
Application & vetting process.
Five steps from application to ongoing partnership. The program is deliberately slow at the gate — vetting alone runs four to six weeks.
Apply
- Identity verification (legal name, jurisdiction, LinkedIn or equivalent)
- 3+ samples of your educational content
- 1 paragraph: why you’d be a good fit
- 1 paragraph: any prior sponsored content (with the disclosures you used)
- Typically 4–6 weeks
Vetting
- Content depth and substantive accuracy
- Disclosure track record on prior sponsored content
- Identity verification
- OFAC sanctions screening
- Compliance with FTC Endorsement Guides in prior content
- Counsel review for high-profile partners
Partnership agreement
- Tier (1, 2, or 3)
- Compensation structure
- Mandatory disclosure obligations
- Content standards
- Term (typically 12 months; renewable)
- Termination terms (violated disclosures; dropped content quality; compliance concerns)
Onboarding
- 30-minute call with Carolina on the disclosure requirements
- Sample content review
- STAXIS-approved disclosure language (English and Spanish)
- Architectural and compliance content for accurate reference
Ongoing
- Quarterly review of partner content
- Compensation processed per content piece completed
- Compliance check on every content piece before publish
Why this program is different
What we specifically avoid.
STAXIS does NOT operate any of the following patterns common in crypto-product affiliate programs.
“Use my code for 10% off” retail affiliate
Risk: Regulatory; brand-degrading; manipulates audience.
Multi-level / pyramid affiliate structures
Risk: SEC may treat as unregistered securities offering; FTC Endorsement Guides; criminal risk.
Percentage-of-performance revenue share
Risk: SEC Advisers Act §205 (only qualified clients can pay performance fees); creates aligned-incentive problem if the affiliate also discusses performance.
“Refer 10 friends, get a year free” retail referral
Risk: We don’t run this either. Our retail tiers are priced at fair value; we don’t need referral manipulation.
“Join my Discord for exclusive signals” partnerships
Risk: SEC investment adviser registration uncertainty; FINRA concerns; mass-audience concerns.
Anonymous / pseudonymous partnerships
Risk: Cannot verify track record; cannot enforce disclosure obligations; cannot screen for sanctions.
Undisclosed sponsored content
Risk: FTC Endorsement Guides up to US$53,088 per violation; Kardashian precedent (US$1.26M).
Our program is conservative and disciplined by design. The brand requires it.