01 Why now
Two things happened this month. The 11 September meeting moved the launch window to a 2027 working assumption and extended the security testing programme, which means there is time to design the public mining service properly rather than bolt one on at launch. And the regulatory ground under a U.S. mining pool has shifted: Pennsylvania's amended money-transmitter law — the Money Transmission and Virtual Currency Transmission Business Licensing Law, Act 7 of 2025 — has been in force since 26 August 2025, and it contains no exemption for mining pools of the kind FinCEN's federal guidance describes.
The operator is a Pennsylvania company. A pool that starts accepting shares and then discovers what its payouts are called under state law has done things in the wrong order. So the design, the terminology, the data model and the legal drafts come first, are published, and go to counsel. The pool comes after.
02 The goals
- One service, narrowly defined. Computing-power contributors collectively mine Spearmint blocks. When a block reward is earned, the service calculates each participating miner's share and distributes it to the Spearmint address that miner supplied. That sentence is the whole product.
- The software enforces the definition. There is no hosted wallet because there is no wallet code. There are no deposits because there is no deposit address. There are no transfers because there is no transfers table and no endpoint that moves value between addresses. Disclaimers describe the software; they do not substitute for it.
- Keep the network and the pool distinct. Spearmint is a decentralised network directed by Instant Access and operated by whoever runs it. Spearmint Mining is one pool that Instant Access runs. The site never implies the company owns the coin or controls the chain, and it tells you how to mine without the pool at all.
- Publish the boundaries. The features that would turn a mining pool into a wallet, an exchange, a payment service or a money transmitter are listed, and no developer may add one without a new legal review. That list is public so it cannot quietly erode.
- No hype. The site states the supply rules as facts. It does not describe SPMTC as something to buy in expectation of appreciation, and it does not promise anyone a reward.
03 The posture
The design is measured against three bodies of guidance. None of it is a conclusion that the service is lawful, licensed, or exempt; that is what counsel is for. It is the fact pattern the service is built to fit.
FinCEN: the mining-pool fact pattern
FinCEN's 2019 guidance on convertible virtual currency (FIN-2019-G001, section 5.4) describes a pool leader that claims the mined reward and distributes it to members in proportion to the processing they provided, minus a fee, and says that distribution "does not qualify as money transmission under the BSA, as these transfers are integral to the provision of services." The same section warns that a pool which also hosts wallets on behalf of its members "will fall under FinCEN's definition of money transmitter." The design responds by having no hosted wallets at all: the miner's own address is the miner's identity, rewards are always paid to the address the shares were mined under, and the unpaid figure on the dashboard is a pending mining reward awaiting a mechanical daily payout, not an account.
Pennsylvania: no exemption to lean on
Act 7 of 2025 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." Unlike the federal guidance it has no integral-services carve-out and no mining carve-out. The argument that a pool distributing block rewards it earned itself is not transmitting virtual currency on behalf of an individual is a factual one, and the design is built to make that fact pattern as clear as it can be: the operator never receives value from a miner, never holds a miner's value beyond the payout cycle, and takes its fee from the block reward as compensation for running the infrastructure, not as a charge for moving anything. Whether Pennsylvania reads it that way is the first question on the attorney review list, and the pool does not open until it is answered.
OFAC: obligations that follow the operator
A U.S. person's sanctions obligations apply wherever the servers sit. OFAC's 2021 guidance for the virtual-currency industry names miners among the businesses it expects to run a risk-based compliance programme and specifically recommends IP-based geoblocking and address screening. A pool with no accounts holds exactly three things it can screen: connection IP addresses, payout addresses, and an optional email. The sanctions policy uses all three, blocks the comprehensively sanctioned jurisdictions at the web and Stratum layers, logs every decision, and collects nothing more — because collecting names and documents to screen would create an account system the rest of the design is built to avoid.
The product decisions that follow
| Decision | Why |
|---|---|
| Payout address is the login; no accounts, no passwords | Minimum identity infrastructure; nothing to custody, nothing to phish |
| No feature to redirect rewards to a different address | A redirect would let value move between addresses on the operator's say-so |
| PPLNS, not PPS | PPS pays miners from the operator's own reserve regardless of blocks found, which is a credit relationship; PPLNS pays only from actual block rewards |
| Automatic daily payout run; no withdraw button | Distribution is mechanical and disclosed, not requested by the miner from a balance |
| 1 SPMTC threshold, 30-day inactive sweep | The threshold exists only so distributions are practical; the sweep stops rewards accumulating with the operator |
| 1% fee taken from the block reward before apportionment | Compensation for operating mining infrastructure, not a charge for transmission |
| "Pending mining reward", never "balance" | Terminology describes what the thing is: an accounting estimate of rewards awaiting distribution |
| No deposits, transfers, swaps, buy, sell, or fiat — in code or on the roadmap | Each one is a different regulated business |
04 The strategy
- Design in public, then review, then build. The full site for the mining service is up now — mining guide, reward flow, node guide, network dashboard concept, transparency page, compliance page, six legal drafts, and nine developer documents — so that counsel, miners, and anyone else can read the same thing.
- Make the flow of value legible. The architecture page has two diagrams: the work path (miner → Stratum → Spearmint Core → chain) and the reward path (block reward → calculation → automatic distribution → the miner's own address). There is no deposit arrow in either, and the data model has no table that could hold one.
- Treat some features as compliance-significant forever. The regulatory change control document lists them and sets the rule: none is implemented without a new legal review, and any pull request that touches payouts, the ledger, addresses, or an inbound-value path is labelled and reviewed as such.
- Score everything. The compliance-by-design matrix evaluates each feature against custody, money-transmission, exchange, securities, OFAC, consumer-protection and privacy risk, and recommends omission where a feature adds risk without being necessary for mining.
- Keep a public list of what a lawyer still has to answer. The attorney review page is the honest version of "compliant": here are the questions, here is what the design assumes, here is what is still open.
- Use mining words. Miners, workers, shares, hashrate, mining reward, payout. Not balance, deposit, withdraw, funds, interest, yield, investment. The terminology page is the reference, and the dashboard wireframe uses it.
05 What changed on the site
| Area | Change |
|---|---|
| Homepage | Repositioned around mining: "Mine Spearmint. Rewards to your own address." Four paths (learn, run a node, start mining, statistics). A mining section with the custody statement and the proposed pool parameters. Roadmap gains the legal-review gate. |
| Navigation | Mining · Rewards · Run a node · Network · Transparency · Compliance · Guides · Build log. Footer restructured into Mining, Network and Legal columns with the custody statement and private-key warning. |
| /mining/ | New. SHA-256, endpoints (proposed), worker setup, difficulty and shares, fee, PPLNS, payout schedule, external-address requirement. |
| /mining/rewards/ | New. The visual flow from hardware to your address with a worked example. |
| /node/ | New. Running Spearmint Core independently, including solo mining against your own node. |
| /network/ | New. Dashboard concept; live figures at launch. |
| /transparency/ | New. Methodology, fee, payouts, maturity, source availability, network rules, publication cadence. |
| /compliance/ | New. What the service does and does not do, and the guidance it is designed against. |
| /legal/ | New. Six first-pass drafts for attorney review: Terms, Privacy, Mining Service Disclosure, Reward and Payout Policy, Sanctions Policy, Risk Disclosure. |
| /docs/ | New. Architecture, security, recordkeeping, terminology, onboarding, dashboard wireframe, compliance matrix, regulatory change control, attorney review list. |
| /guides/ | New. Everything above, grouped: mine it, run it, check it, the paperwork, the record. |
| /contact/ | New. Support scoped to mining and network operation. |
| /updates/ | New. This page and the running list. |
06 What did not change
- The economic policy: 210 million cap, 50 SPMTC initial reward, 30-second target, six-month then annual halvings, 8% pre-launch acquisition by ordinary solo mining. Still proposed until genesis.
- The timeline: launch window under review, 2027 working assumption, no date set. The mining service's legal review is now an explicit gate alongside the testing programme.
- The chain identity in the build log, and the commitment to publish failures as well as successes.
- The pool is not open and no endpoint on this site is live. Everything marked proposed is proposed.
07 What is still open
The complete list is on the attorney review page. The items that block opening the pool:
Two facts in the design are placeholders until confirmed: the pool fee (1%) and the payout threshold (1 SPMTC). Both are marked proposed wherever they appear and both will change only with 30 days' notice on this page's parent list.
08 Next steps
- Engage Pennsylvania counsel on the Act 7 question and record the outcome on the review page.
- Take the six legal drafts through counsel and publish final versions with a version number and date.
- Build the pool to the published architecture — ckpool fork, share database, PPLNS calculator, payout daemon — with the schema and API rules from the change-control document enforced in review.
- Continue the security testing programme; record results in the build log.
- Reconvene to set a launch window once both gates are met. Until then: 2027, working assumption, nothing firmer.