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FIRMA-MOF-v1.0

Ministry of
Finance

The sovereign fiscal layer. Reserve policy, FIG monetary stability, PIF deployment authorization, and the Steward agents that execute fiscal operations — governed by the Foundation, separated from deal deployment, modeled on the structure that manages $941 billion in Saudi Arabia.

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Why Saudi Arabia
Separated the Functions

From 1971 to 2015, Saudi Arabia's Public Investment Fund operated as an arm of the Ministry of Finance — a sleepy desk with 40 employees managing passive equity holdings. When MBS restructured the Kingdom's economic architecture, the first move was separation. The PIF was pulled from the Ministry of Finance and placed under CEDA (the Council of Economic and Development Affairs) — a coordination body that sits above both the Ministry and the PIF, chaired by the Crown Prince himself.

The result was three distinct sovereign financial pillars, each with a different mandate, risk tolerance, and time horizon:

SAMA
Central Bank
Manages foreign reserves ($450B+). Monetary policy. Currency stability. Financial system oversight. Conservative, passive, stability-focused. The guardian — not the investor. When $40B needed to move to PIF for aggressive deployment in 2020, SAMA authorized the transfer but didn't deploy it. Different function, different mandate.
Ministry of Finance
Fiscal Policy
Government budget. Debt issuance. Fiscal coordination. Regulatory policy. Oversees development funds (housing, agriculture, industry). Sets the fiscal framework within which PIF operates. The Ministry doesn't deploy capital into deals — it sets the economic conditions and budget constraints that determine how much PIF can deploy.
PIF
Active Deployment
$941B sovereign deployment arm. Deals, ventures, infrastructure, giga-projects. Has its own board, its own staff, its own investment committee. Reports to CEDA — not to the Ministry of Finance. The PIF deploys. It doesn't manage reserves or set fiscal policy. It executes the vision within the fiscal constraints set by others.

The system works because the functions are separated. SAMA doesn't make deals. The Ministry of Finance doesn't pick investments. The PIF doesn't set monetary policy. And CEDA — the coordination council — governs all three without operating any of them. This is why $941B can be deployed aggressively without destabilizing the Kingdom's reserves. Different mandates, different risk tolerances, one coordination layer.

Three Functions,
Separated by Design

Firma replicates this separation. The Foundation (like CEDA) coordinates. The Ministry of Finance (like SAMA + MoF combined) manages reserves and sets fiscal policy. The PIF and Syndicate (like Saudi PIF) deploy capital into deals. No function crosses into another. The separation is what makes institutional counterparties trust the system — because reserve capital is governed differently from deal capital, and deal capital is governed differently from operating capital.

Coordination Layer
Firma Foundation
= CEDA
Sets constitutional constraints. Governs all three financial functions without operating any of them. Supervisory council reviews Ministry recommendations and PIF deployment proposals. Signs sovereign counterparties. Administers the IP Trust. The Foundation is not the Ministry of Finance — it is the governance layer above the Ministry, just as CEDA sits above both SAMA and the Saudi MoF.
Governance
Constitutional
Cayman Foundation
Fiscal + Reserve Layer
Ministry of Finance
= SAMA + MoF
Manages sovereign reserves. Sets FIG monetary policy — backing ratios, demurrage rates, supply management. Authorizes how much PIF capital can deploy vs remain in reserve. Enforces the Sowing Protocol allocation. Coordinates fiscal balance across all three capital pools. Governs Roca Bank's reserve and RWA operations. The Ministry decides how much to deploy, when to tighten reserves, and what FIG backing ratios should be at any given economic condition.
Reserves
FIG Stability
Fiscal Policy
Roca Bank
Deployment Layer
PIF + Syndicate
= Saudi PIF
Deploys capital into deals — land acquisition (SRI + LiquidAcre), IP acquisition (1ACCORD Trust), infrastructure (FIG backing), sovereign partnerships (nation-state deals). Operates SPVs. Manages the deal flow pipeline. Has its own investment committee. But it does not set its own budget. The Ministry of Finance authorizes deployment limits. The Foundation approves the deals. The Syndicate executes.
Deal Flow
SPVs
Capital Deployment
Operating Layer
Firma Labs
= Operations
Engineering, product, token issuance, marketplace operations. Labs generates revenue and builds technology — but does not manage reserves, set fiscal policy, or deploy PIF capital. Labs operates within the budget authorized by the Ministry, under the governance of the Foundation. This separation is why Labs can operate fast without risking the treasury.
Engineering
Operations
Revenue
STRUCTURAL COMPARISON

SAUDI MODEL FIRMA MODEL

┌─────────────┐ ┌─────────────────┐
│ CEDA │ ← MBS chairs │ Firma Foundation│ ← Supervisory Council
│ (governs) │ │ (governs) │
└──────┬───────┘ └──────┬───────────┘
│ │
┌────┴────┬──────────┐ ┌────────┼──────────┬──────────┐
│ │ │ │ │ │ │
SAMA MoF PIF MoF PIF Syndicate Labs
reserve fiscal deploy reserv lead execute operate
money policy deals fiscal captal pipeline build
stabil budget invest FIG auth SPVs revenue

Who Reports
to Whom

The reporting chain answers two questions: who authorizes what (humans making decisions) and who executes what (Steward agents running operations within authorized parameters). Both chains terminate at the Foundation. Neither chain allows any single function to self-authorize.

Realistic Chain — Human Decision-Making

Level 1
Firma Foundation
Supervisory Council
Sets constitutional constraints. Approves fiscal policy changes. Authorizes sovereign deals above threshold. Amends the Sowing Protocol (requires supermajority). Appoints the Minister of Finance and PIF Governor. Reviews and ratifies Ministry reserve recommendations quarterly. This is the CEDA equivalent — it governs without operating.
Governs All
Level 2
Ministry of Finance
Fiscal Committee
A committee of the Foundation — not a separate entity. Sets reserve policy (minimum reserve ratios, FIG backing targets, emergency liquidity thresholds). Authorizes PIF deployment budgets quarterly. Reviews Roca Bank reserve operations. Recommends fiscal policy changes to the Foundation for ratification.
Fiscal Policy
Level 3a
PIF
Investment Committee
Evaluates deals within Ministry-authorized deployment budget. Sources deals through the SRI intelligence pipeline. Structures SPVs. Manages ERT conversion. Reports deployment performance to Ministry quarterly. Cannot exceed authorized deployment limits without Ministry re-authorization.
Deployment
Level 3b
Firma Labs
Operations
Operates within annual budget authorized by Ministry. Generates revenue through marketplace operations, token activity, EIR program fees, agent deployment. Revenue flows into the Commons treasury per the Treasury Allocation — Labs does not retain revenue for discretionary deployment.
Operations
Level 3c
Syndicate
Deal Execution
Executes deals approved by PIF investment committee. Manages SPV lifecycle. Distributes returns per ERT allocation. Reports to PIF. Does not source deals independently — receives pipeline from PIF. Does not authorize deployment — receives budget from PIF which received budget from Ministry.
Execution
No Self-Authorization

The Ministry cannot authorize its own budget — the Foundation does. The PIF cannot set its own deployment limits — the Ministry does. The Syndicate cannot approve its own deals — the PIF does. Labs cannot retain its own revenue — the Treasury Allocation governs it. And at the agentic layer: no agent can exceed the parameters set by the human-governed layer above it. This is separation of powers. Every function is checked by another function. This is how the Saudi model prevents $941B from becoming a personal slush fund — and how Firma prevents the treasury from becoming anyone's piggy bank.

What the Ministry
Actually Controls

The Ministry of Finance governs five policy domains. Each has defined parameters, authorized agents, and escalation paths to the Foundation for changes that exceed Ministry authority.

Domain 1
Reserve Policy
How much capital stays in reserve vs deploys. The Ministry sets minimum reserve ratios — the floor below which PIF deployment is frozen regardless of deal quality. Reserve ratios are reviewed quarterly and adjusted based on macroeconomic conditions, deal pipeline depth, and ecosystem revenue performance.
Ministry sets: Minimum reserve ratio. Emergency liquidity threshold. Reserve asset composition. Rebalancing triggers.
Foundation approves: Changes to minimum reserve ratio. Emergency drawdown authorization. New reserve asset class additions.
Domain 2
FIG Monetary Stability
FIG is the settlement layer for inter-network-state trade. Its stability is the Ministry's primary monetary responsibility. The Ministry governs FIG backing ratios, demurrage rates, and supply management.
Ministry sets: FIG backing ratio targets. Demurrage rate schedule. Supply expansion/contraction parameters. Settlement fee rates.
Foundation approves: Changes to FIG constitutional constraints. New Elemint class additions. Emergency stabilization interventions.
Domain 3
PIF Deployment Budget
The Ministry authorizes how much PIF capital can be deployed per quarter. This is a hard limit enforced through smart contract constraints. If a deal exceeds the remaining quarterly allocation, it either waits or requests a Ministry budget amendment.
Ministry sets: Quarterly deployment ceiling. Asset class allocation limits. Single-deal concentration limit. Co-investment ratio requirements.
Foundation approves: Annual deployment framework. Exception requests above ceiling. New asset class authorization.
Domain 4
Treasury Allocation
The Sowing Protocol defines the constitutional split (40% LP, 25% ERT, 20% Grants, 10% Infrastructure, 5% Reputation). The Ministry enforces it. Every revenue dollar that enters the Commons treasury is allocated per the Sowing Protocol — no discretionary spending, no emergency reallocation without constitutional amendment.
Ministry enforces: Real-time allocation. ERT distribution. Grant pool funding. Infrastructure budget. Reputation rewards.
Foundation approves: Any change to the split (constitutional amendment — supermajority + reputation-weighted community vote).
Domain 5
Roca Bank Operations
Roca Bank is the bridge between physical and digital reserves. It can trade RWAs and hold both physical and digital assets internationally. The Ministry governs Roca's reserve operations — what assets Roca holds, how RWA trading is conducted, and how Roca coordinates with the Nevis entity.
Ministry sets: Reserve composition policy. RWA trading parameters. Cross-border holding strategy. FIG/Elemint backing coordination.
Foundation approves: New jurisdiction authorizations. Changes to mandate scope. Emergency interventions in reserve positions.
What the Ministry Does Not Control

The Ministry does not pick deals — the PIF does. The Ministry does not build technology — Labs does. The Ministry does not govern the protocol — the Foundation does. The Ministry does not administer the IP Trust — the Foundation does. The Ministry does not run the marketplace — the 1ACCORD Commons does. The Ministry sets fiscal constraints and manages reserves. Everything else belongs to someone else.

The Agentic
Finance Layer

The Ministry's fiscal policies are executed by Steward agents — autonomous systems that operate within Ministry-authorized parameters, report through the Attestation Registry Bridge, and can be overridden by the human fiscal committee at any time. Agents execute. Humans govern. The Ministry is where agentic operations and human oversight converge.

Scale Steward
The Balancer
Primary fiscal agent. Manages FIG stability — monitors backing ratios in real-time, executes algorithmic supply adjustments, triggers demurrage rate changes within Ministry-authorized bands. When FIG backing falls below the Ministry-set floor, The Balancer intervenes automatically. When it approaches the ceiling, it recommends reserve reallocation to the Ministry fiscal committee.
Also manages cross-pool rebalancing — ensuring reserve capital, deployment capital, and operating capital stay within their Ministry-authorized ratios. The Balancer is the agent that keeps the system solvent.
FIG Stability Rebalancing Phase 1
Scale Steward
Epoch Simulator
The Ministry's scenario planning engine. Models economic conditions — what happens to reserves if FIG demand spikes 300%, what happens to PIF deployment capacity if a sovereign deal falls through, what happens to the Sowing Protocol distribution if marketplace revenue drops 50% for two quarters. Runs thousands of scenarios and presents risk-adjusted recommendations to the fiscal committee.
The agent that prevents surprise. Human judgment applies to the scenarios. The agent doesn't decide — it illuminates.
Scenarios Risk Modeling Phase 2
Ledger Steward
Treasury Execution Agent
Executes the Sowing Protocol distribution in real-time. Every dollar of Commons revenue is allocated the moment it arrives — 40% LP, 25% ERT, 20% Grants, 10% Infra, 5% Reputation. Cannot modify the split. Can only execute what the Sowing Protocol constitutionally requires.
Also handles PIF deployment disbursements within Ministry-authorized quarterly budgets. When the PIF investment committee approves a deal, the Treasury Execution Agent moves capital from the deployment pool to the SPV — but only if the move doesn't breach the Ministry's reserve floor.
Sowing Protocol Disbursement Phase 1
Security Steward
The Watchman
Monitors all fiscal operations for anomalies. Unauthorized transfers, reserve ratio breaches, abnormal FIG supply movements, concentration limit violations, and attempted policy overrides. Reports to both the Ministry fiscal committee and the Foundation supervisory council simultaneously — ensuring no single layer can suppress a fiscal alarm.
In the Saudi model, the internal audit unit reports to the PIF board. In Firma, The Watchman reports to everyone. Transparency is the security model.
Monitoring Anomaly Detection Phase 1
AGENTIC FISCAL OPERATIONS

Foundation Constitutional Layer
├── Governmint smart contracts (immutable fiscal constraints)

Ministry Agent Layer
├── The Balancer ──────── FIG stability, reserve ratios, rebalancing
├── Epoch Simulator ───── Scenario modeling, risk projections
├── Treasury Exec Agent ─ Sowing Protocol distribution, PIF disbursement
└── The Watchman ──────── Anomaly detection, dual reporting

All agents report through Attestation Registry Bridge
All actions attested on-chain with timestamps
All parameters set by human fiscal committee
All agents overridable by Foundation supervisory council

Deployment Agent Layer (operates within Ministry budgets)
├── Deal scoring agents (SRI pipeline)
├── Portfolio monitoring agents
├── Marketplace operations agents
└── Liquidity management agents

The Bridge Between
Physical and Digital

Roca Bank is the institutional interface between traditional finance and the Firma ecosystem. It can trade RWAs and hold both physical and digital assets internationally — making it the operational arm of the Ministry's reserve strategy. While the Ministry sets policy, Roca executes the physical-world reserve operations that back FIG, support Elemint baskets, and provide institutional counterparties with the custody and compliance infrastructure they require.

Reserve Function
RWA Reserve Custody
Roca holds the physical-world assets that back FIG and Elemint reserves. Real estate (via LiquidAcre tokenization), commodity positions, traditional financial instruments, and fiat currency reserves. These assets are held internationally — not dependent on any single jurisdiction. The Ministry sets the target composition. Roca manages custody, compliance, and reporting.
Trading Function
RWA Trading + Conversion
Roca trades between asset classes — converting physical reserves to digital, digital to physical, RWAs to stablecoins, stablecoins to FIG-backing instruments. This is the liquidity mechanism that allows the Ministry to rebalance reserves without fire sales. When The Balancer identifies a rebalancing need, Roca is the execution venue.
Institutional Function
Counterparty Interface
Institutional investors — sovereign wealth funds, family offices, pension funds — need a regulated banking interface. They cannot wire capital directly to a smart contract. Roca provides the on-ramp: KYC/AML compliance, fiat deposit, wire transfer settlement, and the regulatory reporting that institutional treasuries require. Capital enters through Roca and deploys through Ministry-authorized channels.
Nevis Coordination
Private Asset Management
The Nevis entity holds the PIF capital pool and private IP. Roca Bank coordinates with the Nevis entity for cross-border asset management — moving capital between jurisdictions, managing private asset custody, and providing the banking infrastructure that the Nevis LLC requires to operate internationally. The Ministry governs the policy. Nevis holds the assets. Roca moves them.

Roca Bank is not independent. It reports to the Ministry of Finance fiscal committee for all reserve-related operations. Roca can trade, hold, and convert assets — but only within Ministry-authorized parameters. New asset classes, new jurisdictions, and new counterparty relationships all require Ministry approval. Roca is the hands of the Ministry in the physical world — not a bank making its own investment decisions.

Governed by the Foundation.
Enforced by agents.
Separated by design.

The Ministry of Finance is the missing layer between governance and deployment — the fiscal function that ensures reserve policy, FIG stability, and treasury allocation happen within constitutional constraints, executed by Steward agents, with Roca Bank bridging the physical and digital worlds.