NeroAI | Compliance — A Memo on How We Operate
Internal Compliance Memo · Made Public

A Note on How We Operate —
and Why It Matters

This is a plain-language compliance overview from NeroAI's founder. It explains our operating model, what we are, what we aren't, and how we handle the most common regulatory concerns in the algorithmic trading space.

AV

Memo from Aaron V.

Founder & CEO, NeroAI Group LLC

Updated Feb 2026

Why This Page Exists

The algorithmic trading industry has a credibility problem. Too many companies blur the line between software and advisory. Too many make promises they can't keep. Too many hide behind vague language when regulators come calling.

I built NeroAI to be different — not because "transparency" is a good marketing angle, but because operating with clarity is the only way to build something that lasts. If you're considering our software, you deserve to understand exactly how we operate, what rules we follow, and where the lines are drawn.

This page isn't a legal document. It's a plain-language explanation of our compliance framework, written for people who are rightfully skeptical of this industry. I've organized it around the questions and concerns I hear most often.

Who this is for: Prospective clients, existing clients, and anyone evaluating NeroAI who wants to understand how we handle regulatory compliance at a structural level — not just in a footnote.

What NeroAI Actually Is

NeroAI Group LLC is a technology company. We design, develop, and license algorithmic trading software. That is the entirety of our business model.

When you become a NeroAI client, you are licensing software — the same way you might license a CRM, a design tool, or an analytics platform. You install it. You configure it. You connect it to infrastructure you control. And you can turn it off whenever you want.

Specifically, our software — Atlas — is an algorithmic FX trading system that runs on a dedicated virtual machine. It connects to the brokerage account of your choice and executes trades according to predefined, rules-based logic. It operates 24 hours a day, 5 days a week, without requiring manual intervention.

The key distinction: We build tools. We don't manage money. We don't tell you what to invest in. We don't make decisions on your behalf. The software follows its programmed logic — and you decide whether to use it.

What NeroAI Is Not

This is where most companies in our space get into trouble. They position themselves as software companies but act like advisors, fund managers, or brokers. We draw hard lines:

  • We are not a fund. We do not pool capital, manage portfolios, or operate trading accounts on behalf of clients.
  • We are not an investment advisor. We do not provide personalized financial advice, allocation recommendations, suitability assessments, or retirement planning guidance.
  • We are not a broker-dealer. We do not execute trades on your behalf, hold your funds, or have withdrawal access to your brokerage account.
  • We are not a commodity trading advisor (CTA). We do not provide specific trading recommendations or signals for individual securities or commodity interests.
  • We do not provide legal or tax advice. We will never tell you how to structure an account, claim a deduction, or handle a regulatory filing.

If any NeroAI team member crosses these lines in a conversation — tell us. Our compliance framework only works if it's enforced consistently. If someone on our team offers allocation guidance, suitability commentary, or anything resembling personalized financial advice, that is a policy violation and we want to know about it.

Our Registration Status

"Are you guys registered with the SEC? The NFA? Are you licensed to do this?"

NeroAI is not registered with the SEC, CFTC, NFA, FINRA, or any state or federal regulatory body as an investment advisor, broker-dealer, commodity trading advisor, or in any other advisory or intermediary capacity. We disclose this clearly and prominently — it is not hidden in fine print.

We are not required to register in these capacities because we do not engage in the activities that trigger those registration requirements. We do not provide personalized investment advice. We do not manage client funds. We do not act as an intermediary between clients and markets. We license software.

If our business model ever changes in a way that would require registration, we will pursue it. But as a technology provider that licenses algorithmic software and never touches client capital, our current operating model does not trigger those obligations.

Earnings Claims & Performance Language

This is the single biggest area of regulatory exposure in our industry. Most violations fall into one of four categories: implied returns, selective data presentation, hypothetical misuse, and guarantee language. Here's how we handle all four.

"How much can I expect to make? What kind of returns does Atlas generate?"

We don't answer this question — and any company that does should concern you. The moment a software provider tells you what you can "expect to earn," they've crossed from technology licensing into investment advisory territory.

We can show you our published strategy data through FX Blue. We can explain how the software's risk parameters work. We can walk you through the logic behind its design. But we will never project returns, imply expected earnings, or frame any data point as a promise of future performance.

What you'll never hear from us: "consistent returns," "reliable income," "safe trading," "proven profits," or "capital protection" used as a guarantee. These phrases imply certainty that doesn't exist in leveraged trading.

Our internal language guidelines are strict. We describe architecture, not outcomes. We use process language — "designed to," "seeks to," "structured to" — not result language. Every reference to performance data includes explicit risk disclosure.

Our standard: If a sentence implies that a future outcome is likely, predictable, or safe — it gets rewritten. No exceptions, regardless of context.

Strategy Data & How We Present It

"How do I know your performance numbers are real? Everyone says they're profitable."

Healthy skepticism. Here's how we handle data integrity:

All NeroAI strategy data is published through FX Blue — a third-party tracking platform that we do not own, control, or edit. The data reflects actual strategy execution, not backtests or simulations. The full record is available for independent review, including every drawdown period, every losing month, and every time the strategy was underwater.

We do not cherry-pick favorable windows. We do not highlight "best months" without showing worst months. When we reference data, we present it in the context of the full historical record with appropriate risk disclosures.

When we do present hypothetical, simulated, or backtested data — which we occasionally use in educational contexts — it is always clearly labeled as such, with assumption disclosures and model limitation caveats. We never blend hypothetical and live data to inflate perceived performance.

Important: FX Blue is a data publishing platform. Its role is to track and display data — not to endorse, validate, or approve any trading strategy. We never describe FX Blue as having "verified" or "approved" our strategy. The data is published there. That is the extent of the relationship.

Guarantees, Promises & Protection Language

"Can you guarantee I won't lose money? What happens if the algorithm fails?"

No one can guarantee that — and anyone who tells you otherwise is lying or breaking the law. Here's our position stated plainly:

Trading foreign exchange involves significant risk of loss and is not suitable for all investors. The use of automated trading software does not eliminate risk and may amplify losses. Past performance is not indicative of future results. You should only trade with capital you can afford to lose.

We don't soften that language. We don't bury it. It's the truth, and pretending otherwise would be doing you a disservice.

Our software is designed with risk management as a core architecture principle — drawdown parameters are hardcoded, position sizing follows strict rules, and the system is structured to limit exposure. But "designed to manage risk" is fundamentally different from "guaranteed to protect your money." The former is an engineering description. The latter is a lie.

We also don't offer satisfaction guarantees tied to performance. Our support commitment is about technical service — setup, configuration, troubleshooting. It is never linked to profitability.

  • No performance guarantees. We never promise returns, income, or profitability.
  • No profit-sharing. We charge a flat software license fee. There are no revenue splits, performance fees, or success-based charges.
  • No "capital protection" guarantees. We use "risk management" to describe design intent. "Protection" implies a guarantee we can't make.
  • No satisfaction-tied-to-profitability. Our support is about the software functioning properly — not about market outcomes.

Testimonials & Social Proof

"Do you have client reviews? Can I talk to someone who's using the software?"

We do feature client testimonials — but under strict compliance guidelines. Every testimonial is reviewed before publication. We prohibit the discussion of specific returns, percentage gains, or dollar amounts. If a client receives any benefit in exchange for their testimonial, we disclose that relationship.

Our testimonials focus on experience, process, and support — not financial outcomes. You'll never see a NeroAI testimonial that says "I made X% in my first month." That kind of language is misleading regardless of whether it's true, because it implies typicality — and individual results vary significantly.

Every testimonial we publish includes the disclosure: "Individual results vary. Testimonials are not indicative of future performance."

Brokers, Affiliates & Your Capital

"Which broker should I use? Do you get a kickback for recommending one?"

We do not recommend, endorse, or have any affiliate relationship with any brokerage. We list compatible brokers for informational purposes only — meaning we've confirmed the software functions correctly with those platforms. That's a technical compatibility statement, not a recommendation.

You select your own broker. You open your own account. You fund it with your own capital. NeroAI never has access to withdraw, transfer, or manage your funds. We don't receive referral fees, commissions, or any compensation from any brokerage for client introductions.

When questions come up about margin rules, account types, or regulatory implications of specific broker features — we direct you to the broker directly or to a licensed financial professional. Those aren't our areas and we won't pretend they are.

Your funds, your account, your control. At no point in the NeroAI relationship does anyone at this company have withdrawal access to your brokerage account. The software connects for trade execution only. You can revoke that connection at any time.

Our Marketing Standards

A lot of companies in this space use manipulative tactics to create urgency and pressure. We've built internal policies to prevent that:

  • No countdown timers. We don't manufacture artificial deadlines to pressure decisions.
  • No fake social proof. No "John from Texas just signed up!" notification popups. No fabricated activity.
  • No artificial scarcity. No "only 3 spots left" messaging unless there is a genuinely documented capacity constraint.
  • No unsubstantiated superlatives. We don't call ourselves "industry leaders," "the best," or "the safest." We describe what we've built and let the data speak.
  • No authority inflation. We don't use phrases like "verified trader," "certified expert," or "approved by" in contexts that would imply third-party endorsement where none exists.
  • No revenue signaling. We don't cite our business revenue as evidence that the trading software works. Company growth and software performance are separate discussions.

Our marketing communicates what the software does, how it works, and where the data lives. It doesn't manipulate, inflate, or mislead.

The Language We Don't Use — and Why

We maintain an internal blacklist of phrases that are prohibited across all NeroAI communications — sales calls, marketing copy, email, social media, and client conversations. Here's the list:

Guaranteed Safe Protected Consistent returns Reliable income Avoid losses Industry leading Best in market Proven profits Sleep at night This is suitable for you Good for retirement

Every one of these phrases either implies certainty that doesn't exist, crosses into advisory territory, or creates an expectation that no trading software can deliver. Instead, we use process-based language:

Rules-based Systematic Designed to Seeks to Structured to Risk-managed Adaptive Published data

This isn't about being overly cautious. It's about being precise. When we say the software is "designed to manage drawdown exposure," that's an accurate engineering description. When someone says the software "protects your capital," that's a guarantee they can't make. The difference matters — both to regulators and to you.

The Standard We Hold Ourselves To

I didn't build NeroAI to cut corners. The military taught me that discipline isn't a temporary posture — it's a permanent operating standard. The same principle applies here.

Every piece of marketing copy we publish goes through compliance review. Every sales conversation is guided by prohibited-language training. Every client testimonial is reviewed before it goes live. Every performance reference is paired with risk disclosure. And every team member understands where our lines are drawn — and that crossing them isn't an option.

If you're evaluating NeroAI, I'd encourage you to compare this page to how other companies in our space talk about their products. Look for the phrases on our blacklist. Ask if they're registered — and if they say yes, verify it. Ask where their data lives — and whether you can review it independently. Ask whether their testimonials include return figures. Ask who controls your funds.

The answers will tell you a lot.

Still have questions? I welcome them. Schedule a call at go.nerotrades.com/schedule or reach us directly at www.nerotrades.com/contact. Compliance isn't a department here — it's a foundation.

AV
— Aaron V.

Founder & CEO

NeroAI Group LLC · U.S. Marine Veteran

© 2026 NEROAI GROUP LLC. "NeroAI" is a technology company that licenses algorithmic trading software. We are not a broker-dealer, investment advisor, commodity trading advisor, or custodian. We do not accept, hold, manage, or have access to client funds. We do not provide investment, financial, legal, or tax advice. We do not recommend or endorse any specific brokerage. All trading activities occur through third-party regulated brokers selected at the sole discretion of the client. The client is solely responsible for all trading decisions and brokerage account management. Trading foreign exchange (Forex) and other financial instruments involves significant risk of loss and is not suitable for all investors. The use of automated trading software does not eliminate risk and may amplify losses. Past performance is not indicative of future results. You should only trade with capital you can afford to lose. NeroAI is not registered with the SEC, CFTC, NFA, FINRA, or any state or federal regulatory body.