Recast Lana Discount end-to-end as a Proprietary Treasury Acquisition function: own account, own capital, own risk, independent acceptance and direct treasury ownership.
Added explicit EU MiCA own-account/no-client-service perimeter based on European Commission / ESMA Q&A 2293, with CASP/Article 77 fallback only if the factual model becomes a client exchange service.
Added internal acquisition-pricing framework: reference-market-based pricing may currently target approximately 22-35% below reference, expressly treated as proprietary purchase pricing rather than a fee or guaranteed exchange rate.
Changed deferred Lana Discount settlement standard from 30 days to maximum T+15 calendar days after the agreed contractual trigger, backed by Acceptance Gate and own-capital evidence.
Removed Lana Discount as the default consumer-linked Mode B merchant settlement function. Mode B is now a separate CONDITIONAL crypto/payment function; pure P08 payment runs purchaser -> seller.
Added Treasury Acquisition Portal UI language rules and explicit prohibited exchange/cash-out/client-balance/guaranteed-buyback language.
Refreshed UK analysis through 18 August 2026: current MLR territorial/business test remains separate; added HM Treasury draft Article 9UA proprietary-trading exclusion and the requirement to re-check final SI/FCA perimeter guidance before 25 October 2027 reliance.
Revised Annexes A, B, C, D, E, F, G, H, I and K so definitions, conditions precedent, Nostr semantic mapping, legal-entity matrix, pricing taxonomy, flow matrix and UK transition matrix use the same treasury substance.
Preserved FUNCTION BEFORE LABEL: if actual operations become a service to a client, the Treasury label does not prevent reclassification.