Mining Service Disclosure

01 What the service does

1. Runs Stratum servers that accept SHA-256 proof-of-work shares from hardware you own and operate.
2. Runs a Spearmint Core node that builds block templates and broadcasts blocks the pool finds.
3. Records every share against the payout address it was submitted under.
4. When the pool finds a block and the block matures, apportions the block reward among payout addresses under the published PPLNS methodology, deducting the 1% pool fee.
5. Automatically pays each qualifying mining reward, in a scheduled daily payout run, to the external Spearmint address the miner mined under.
6. Publishes network and pool statistics, block and payout transaction identifiers, and exportable share logs so any miner can check the arithmetic.
7. Charges a pool fee of 1% of block rewards attributable to participating miners (proposed) as compensation for operating this infrastructure.

02 What the service does not do

Each of these is a property of the software and the data model, described in the architecture documentation, not merely a statement on this page.

1. Does not create, host, or hold a Spearmint wallet or address for any miner.
2. Does not generate, receive, store, or ask for any miner's private key or recovery phrase.
3. Does not accept deposits of SPMTC or any other cryptocurrency, U.S. dollars, or stablecoins. There is no deposit address and no mechanism to credit anything received.
4. Does not let a miner send, transfer, or assign a pending mining reward to another miner or to a different address.
5. Does not exchange, buy, sell, swap, or convert SPMTC or anything else, and does not operate a marketplace.
6. Does not process or forward payments, and does not transmit value on anyone's instruction. Its only outbound transactions are scheduled payout runs under the published policy.
7. Does not pay interest, yield, or any return on anything held, because nothing is held for anyone.
8. Does not offer accounts, logins, or balances. The dashboard is a public, read-only view keyed by payout address.
9. Does not market SPMTC as something to buy in expectation of profit, and provides no way to buy it.

03 What "pending mining reward" is and is not

The dashboard shows a figure labelled Pending mining reward for each payout address. This figure is an accounting estimate of mining rewards awaiting distribution. It is not a deposit account and not a hosted cryptocurrency wallet.

1. It is the sum of allocations from matured blocks, under the methodology, that have not yet been included in a payout run. It exists because payouts are batched daily and because a minimum of 1 SPMTC per payout keeps network fees proportionate.
2. It can go down: if a block the pool found is orphaned before maturity, its allocations are reversed and the dashboard says so.
3. It cannot be moved, assigned, spent, or converted. The only thing that can happen to it is that it is paid to the address it belongs to.
4. An address that stops mining is paid any mature amount above the network dust limit within 30 days, regardless of the threshold. The service does not accumulate unpaid rewards as a matter of design.

04 How the Operator's reward and miners' rewards are separated

1. When the pool finds a block, the coinbase output pays the block reward to an operational address controlled by the Operator. At that moment the reward is the pool's, earned by the pool's combined work, and has not yet been apportioned.
2. After 100 confirmations the reward calculator applies the published methodology to the recorded shares and produces one allocation per participating payout address, plus the 1% pool fee. The allocations are written to the reward-allocation table; the fee is the Operator's.
3. The payout daemon pays the allocations to their addresses in the next daily run in which they qualify. The Operator's operational address is a pass-through for the pool's own reward on its way to the miners who earned it, not a place where miners' property is kept.
4. Records exist at each step — shares, block, allocation, payout transaction — so the path from work to payout can be shown for any address and any block.

05 Federal guidance: FinCEN

The U.S. Financial Crimes Enforcement Network published FIN-2019-G001, Application of FinCEN's Regulations to Certain Business Models Involving Convertible Virtual Currencies (9 May 2019). Section 5.4 addresses mining pools directly. It describes a pool whose leader receives the mined reward and "distributes this amount to the pool members in subsequent transfers, presumably in proportion to the computer processing provided, minus its own fee for managing the pool", and states:

"When the leader of the pool … transfer[s] CVC to the pool members … to distribute the amount earned, this distribution does not qualify as money transmission under the BSA, as these transfers are integral to the provision of services (the authentication of blocks of transactions through the combined efforts of a group of providers …)."

The same section then draws the line the design is built around:

"However, if the leader … combine[s] their managing and renting services with the service of hosting CVC wallets on behalf of the pool members … the leader … will fall under FinCEN's definition of money transmitter for engaging in account-based money transmission."

1. Spearmint Mining is designed to match the first fact pattern and to avoid the second. It distributes the reward it earned, in proportion to work, minus its fee, to addresses the miners control — and it hosts no wallets and no accounts.
2. FinCEN's hosted-wallet analysis (section 4.2 of the same guidance) turns on who owns the value, where it is stored, whether the owner interacts directly with the payment system, and whether the intermediary has "total independent control over the value". The design keeps the Operator out of that role: miners hold their own keys, receive on-chain, and the Operator's control over allocations is limited to paying them out.
3. FinCEN reads the "integral to the provision of services" exemption strictly. The service is therefore built so that the mining service is the substantive business, and the payout is nothing more than the necessary last step of it.

06 Pennsylvania

1. The Operator is located in Pennsylvania. Pennsylvania's Money Transmitter Act was amended by Act 7 of 2025 (Senate Bill 202), effective 26 August 2025, and is now titled the Money Transmission and Virtual Currency Transmission Business Licensing Law. It requires a licence to "engage in the business of transmitting virtual currency by means of a transmittal instrument for a fee or other consideration with or on behalf of an individual".
2. The Pennsylvania statute contains no provision equivalent to FinCEN's treatment of mining pools. Whether distributing block rewards a pool itself earned, minus a fee for operating the mining infrastructure, is "transmitting virtual currency … on behalf of an individual" under the Pennsylvania text is a question this page does not answer.
3. The Pennsylvania Department of Banking and Securities has stated that it does not provide licensing determinations. The federal analysis in section 05 does not resolve the Pennsylvania question.
4. The service is designed to have the strongest reasonable factual position: the service provided is mining; miners contribute SHA-256 computation; payments are distributions of rewards produced by that mining; the Operator does not accept cryptocurrency from one person for transmission to another, does not provide general-purpose transfers, hosted wallets, exchange, or deposits; and the fee is compensation for infrastructure, not for transmission.
5. Pennsylvania licensing analysis is being reviewed by counsel before the service opens. The service will not open to the public until that review is complete.

07 Securities: SEC staff statement

1. On 20 March 2025 the Division of Corporation Finance of the U.S. Securities and Exchange Commission published a staff statement on certain proof-of-work mining activities. It expresses the Division's view that, for crypto assets intrinsically linked to the programmatic functioning of a public, permissionless network, solo mining and participation in mining pools of the kind it describes are not offers or sales of securities, and describes a pool operator's activities as primarily administrative or ministerial.
2. The statement is a staff view, not a Commission rule, and it says its view may differ where facts vary — in particular "the way in which pool members may be compensated" and "the activities conducted by pool operators".
3. Spearmint Mining is designed to stay inside the fact pattern described: rewards are apportioned in proportion to work actually contributed, the Operator does not advance rewards from its own resources or promise any return, and the site does not market SPMTC as something to buy in expectation of profit.

08 Sanctions: OFAC

1. The Operator is a U.S. person and must comply with U.S. sanctions administered by the Office of Foreign Assets Control regardless of where servers are located. OFAC's October 2021 Sanctions Compliance Guidance for the Virtual Currency Industry states that all U.S. persons must comply and encourages miners, among others, to maintain a risk-based compliance programme.
2. The service's programme is sized to the information a mining pool actually holds — IP addresses, payout addresses, and optional emails — and is described in the Sanctions / Restricted Persons Policy.

09 Regulatory change control

Every statement on this page depends on the software continuing to behave as described. A list of features that would change the characterisation of the service — hosted wallets, deposits, transfers, swaps, fiat, custody of keys, lending, staking, mixing, payment forwarding, and others — is maintained at /docs/regulatory-change-control/. None of them may be implemented without a new legal review. If a proposed feature conflicts with this disclosure, the feature is flagged; the disclosure is not weakened.

10 Version

version

0.1 — draft for attorney review

revised

13 September 2026

effective

Not in force; the service is not open

sources

FinCEN FIN-2019-G001 (9 May 2019) §§2.2, 4.2, 5.4; FinCEN FIN-2014-R001 (30 Jan 2014); Pennsylvania Act 7 of 2025 (SB 202); Pa. Dept. of Banking and Securities letter of 12 Aug 2025; SEC Division of Corporation Finance staff statement on proof-of-work mining (20 Mar 2025); OFAC Sanctions Compliance Guidance for the Virtual Currency Industry (Oct 2021)