Digital Asset & Blockchain Terms

Digital Asset Services

1.1 Nature of Services

Paymenture provides software and technology services that facilitate access to Digital Asset Services offered by regulated and/or licensed third-party service providers, including virtual asset service providers ("VASPs"), exchanges, liquidity providers, custody providers, and settlement providers.

Digital Asset Services may include:

• cryptocurrency transfers;
• stablecoin settlement;
• blockchain wallet functionality;
• digital asset exchange or conversion;
• blockchain-based treasury services;
• blockchain transaction orchestration; and
• related compliance and reporting tools.

1.2 No Investment Advice

Paymenture does not provide:

• investment advice;
• tax advice;
• legal advice;
• trading recommendations;
• fiduciary services; or
• brokerage services.

Client is solely responsible for evaluating the suitability and legality of any Digital Asset activity.

1.3 No Guarantee of Asset Availability

Paymenture may add, remove, suspend, restrict, or prohibit support for any:

• blockchain;
• token;
• stablecoin;
• protocol;
• wallet;
• exchange;
• jurisdiction; or
• Digital Asset Service

at any time without notice.

General Prohibition on Illicit Use

Client agrees not to use the Digital Asset Services, or permit any third party to use the Digital Asset Services, in connection with any unlawful, fraudulent, deceptive, abusive, or prohibited activity.

Prohibited activities include, without limitation:

• money laundering;
• terrorist financing;
• sanctions evasion;
• fraud;
• ransomware;
• extortion;
• narcotics trafficking;
• human trafficking;
• prohibited weapons transactions;
• stolen funds;
• darknet marketplace activity;
• unlawful gambling;
• unauthorized money transmission;
• market manipulation;
• unlicensed financial services; or
• any activity prohibited under applicable law.

Anonymity-Enhancing Technologies & Mixers

3.1 Prohibited Technologies

To support compliance with anti-money laundering laws, sanctions laws, and internal risk-management requirements, Paymenture prohibits the use of the Digital Asset Services in connection with anonymity-enhancing technologies ("AETs"), mixers, tumblers, or privacy-preserving protocols where Paymenture reasonably determines such activity presents elevated compliance or sanctions risk.

Prohibited activity may include:

• interaction with centralized or decentralized mixers or tumblers;
• use of sanctioned or prohibited protocols;
• use of privacy-preserving technologies intended to obscure

transaction history;

• chain-hopping designed to conceal transaction origin or destination;
• structuring blockchain activity to evade compliance controls; or
• rapid, non-economic blockchain transaction cycling intended to

obscure transaction trails.

3.2 Restricted Assets

Paymenture may prohibit or restrict certain privacy-enhancing or high-risk digital assets, wallets, protocols, or blockchain services at any time.

Darknet Markets & High-Risk Counterparties

The Digital Asset Services may not be used to facilitate transactions involving:

• darknet marketplaces;
• sanctioned counterparties;
• stolen credentials marketplaces;
• ransomware-related wallets;
• prohibited jurisdictions;
• unlawful goods or services;
• shell entities;
• unlicensed virtual asset providers; or
• high-risk counterparties identified through blockchain analytics or

sanctions screening.

Paymenture and its Service Providers may utilize blockchain analytics providers, transaction-monitoring technologies, wallet-screening solutions, Travel Rule technologies, and sanctions-screening systems.

Compliance Monitoring & Blockchain Analytics

5.1 Transaction Monitoring

Paymenture and its Service Providers may monitor:

• wallet activity;
• blockchain transactions;
• counterparties;
• transaction flows;
• transaction velocity;
• wallet interactions; and
• blockchain exposure risk.

5.2 Blockchain Analytics

Paymenture may utilize blockchain analytics providers and compliance technologies to:

• screen wallet addresses;
• identify sanctions exposure;
• identify interaction with mixers or prohibited services;
• detect suspicious transaction patterns;
• support Travel Rule compliance;
• support fraud detection;
• support law enforcement requests; and
• comply with applicable law.

5.3 Travel Rule Compliance

Where required by law, Paymenture and its Service Providers may collect, retain, transmit, verify, or disclose originator and beneficiary information in connection with digital asset transfers.

Client agrees to cooperate with all Travel Rule, KYC, sanctions, and compliance requests.

Right to Freeze, Reject, Restrict, or Report

Paymenture reserves the right, in its sole discretion or at the direction of any Service Provider, regulator, banking partner, sanctions authority, blockchain analytics provider, or law enforcement agency, to:

• reject transactions;
• delay or prevent settlement;
• reverse transactions where permitted;
• freeze funds or digital assets;
• restrict wallet functionality;
• prohibit transfers;
• suspend account access;
• impose reserves or transaction limits;
• require enhanced due diligence;
• request additional documentation;
• terminate Digital Asset Services; or
• report activity to regulators or authorities.

Paymenture may take such actions where Paymenture reasonably determines that activity presents:

• sanctions risk;
• AML risk;
• fraud risk;
• cybersecurity risk;
• legal or regulatory risk;
• reputational risk;
• operational risk; or
• suspicious or prohibited activity.

Regulatory Reporting & Disclosure

Paymenture and its Service Providers may:

• cooperate with regulators and law enforcement;
• disclose information where required by law;
• respond to subpoenas or legal requests;
• file Suspicious Activity Reports ("SARs");
• block or freeze transactions;
• comply with sanctions obligations; and
• maintain transaction records as required by law.

Client acknowledges that Paymenture may be prohibited by law from disclosing certain investigations, reporting actions, or compliance measures.

Digital Asset Risks

8.1 Volatility Risk

Digital Assets are highly volatile and may lose value rapidly, including to zero.

8.2 Blockchain Risk

Blockchain transactions may be:

• irreversible;
• delayed;
• interrupted;
• censored;
• subject to forks;
• affected by validator failures;
• affected by network congestion; or
• affected by smart contract vulnerabilities.

8.3 Stablecoin Risk

Stablecoins may:

• lose parity with fiat currency;
• experience liquidity failures;
• become restricted or frozen;
• experience reserve-related issues; or
• become unavailable due to regulatory action.

8.4 Third-Party Risk

Digital Asset Services depend on third-party:

• blockchain networks;
• liquidity providers;
• VASPs;
• custody providers;
• validators;
• market makers;
• banks; and
• infrastructure providers.

Paymenture does not guarantee continuous availability or uninterrupted access to any Digital Asset Service.

No Liability for Compliance Actions

Client acknowledges that Paymenture cannot "unmix," reverse, or recover certain blockchain transactions once processed on a blockchain network.

Paymenture shall not be liable for losses, restrictions, freezes, delays, or inability to access digital assets resulting from:

• compliance actions;
• sanctions screening;
• blockchain analytics determinations;
• Travel Rule obligations;
• law enforcement requests;
• regulatory actions;
• blockchain failures;
• stablecoin depegging;
• protocol failures;
• network congestion;
• forks;
• third-party provider actions; or
• internal risk-management decisions.

Termination of Digital Asset Services

Paymenture may immediately suspend or terminate access to Digital Asset Services where:

• suspicious activity is detected;
• sanctions concerns arise;
• Paymenture determines elevated compliance risk exists;
• blockchain exposure creates unacceptable risk;
• fraudulent or deceptive activity is suspected;
• required by law or Service Providers; or
• Client violates these Digital Asset Terms.

Paymenture may maintain freezes, reserves, restrictions, or delayed settlement after termination where reasonably necessary to:

• comply with law;
• complete investigations;
• manage disputes;
• comply with sanctions obligations;
• satisfy chargeback exposure; or
• protect Paymenture or its Service Providers.

Acknowledgment & Acceptance

Client acknowledges and agrees that:

• blockchain transactions may be irreversible;
• Digital Asset Services involve substantial risk;
• Paymenture may utilize blockchain analytics and compliance

monitoring;

• Paymenture may freeze or restrict transactions for compliance

reasons;

• Digital Asset Services may be unavailable in certain jurisdictions;
• Paymenture may cooperate with regulators and law enforcement; and
• Paymenture may modify or discontinue Digital Asset Services at any

time.

Client further acknowledges that acceptance of these Digital Asset Terms may be required through clickwrap or electronic consent before accessing Digital Asset Services.