Wallet & Virtual Account Terms

Overview of Wallet Services

1.1 Technology Platform

Paymenture provides software and technology services that facilitate access to Wallet Services offered by regulated third-party financial institutions, sponsor banks, electronic money institutions ("EMIs"), payment institutions, virtual asset service providers ("VASPs"), custodians, and other financial service providers ("Service Providers").

Paymenture itself is not a bank, deposit-taking institution, or custodian unless expressly stated otherwise in writing.

1.2 Wallet Services

Wallet Services may include:

• digital wallets;
• stored balances;
• virtual accounts;
• multi-currency accounts;
• IBANs;
• named receiving accounts;
• local collection accounts;
• treasury functionality;
• payout functionality;
• payment routing;
• blockchain settlement;
• stablecoin settlement; and
• related transaction functionality.

Account Eligibility & Onboarding

Paymenture and its Service Providers may require:

• identity verification;
• business verification;
• beneficial ownership verification;
• source of funds verification;
• source of wealth verification;
• sanctions screening;
• Travel Rule compliance;
• blockchain analytics screening;
• enhanced due diligence; and
• ongoing compliance reviews.

Failure to provide requested information may result in:

• delayed onboarding;
• restricted functionality;
• transaction delays;
• freezes;
• reserves; or
• termination of Wallet Services.

Wallet Balances & Funds

3.1 Ledger Balances

Wallet balances displayed through the Paymenture platform may represent:

• ledger balances;
• safeguarded balances;
• settlement balances;
• blockchain balances; or
• balances maintained by third-party Service Providers.

3.2 No Deposit Relationship

Unless expressly stated otherwise in writing by the applicable Service Provider:

• wallet balances are not bank deposits;
• wallet balances are not savings accounts;
• wallet balances are not investment accounts; and
• wallet balances are not insured by the FDIC.

Virtual Accounts & Named Accounts

Wallet Services may include:

• virtual account numbers;
• local receiving accounts;
• IBANs;
• named accounts;
• collection accounts;
• settlement accounts; or
• payment routing functionality.

Paymenture may prohibit:

• nested account activity;
• unauthorized money transmission;
• excessive transaction velocity;
• prohibited counterparties;
• prohibited jurisdictions; or
• activity presenting elevated compliance or operational risk.

Digital Asset Funding & Settlement

Certain Wallet Services may permit:

• stablecoin settlement;
• blockchain transfers;
• digital asset funding;
• blockchain treasury activity; or
• conversion between fiat and digital assets.

Such functionality is subject to:

• the Digital Asset & Blockchain Terms;
• blockchain analytics monitoring;
• sanctions screening;
• Travel Rule compliance;
• liquidity availability; and
• applicable law.

Transaction Processing & Settlement

Transactions are subject to:

• compliance review;
• fraud monitoring;
• sanctions screening;
• blockchain analytics monitoring;
• banking hours;
• payment network processing;
• blockchain confirmation times;
• liquidity availability; and
• Service Provider availability.

Paymenture does not guarantee:

• transaction completion;
• settlement timing;
• exchange rates;
• blockchain confirmation speed;
• uninterrupted access; or
• continued provider availability.

Compliance, Monitoring & Security

Paymenture and its Service Providers may monitor:

• wallet activity;
• transaction flows;
• counterparties;
• blockchain activity;
• device activity;
• API activity;
• transaction velocity; and
• behavioral indicators.

Paymenture may utilize:

• blockchain analytics providers;
• sanctions screening systems;
• fraud prevention systems;
• cybersecurity monitoring;
• Travel Rule technologies; and
• transaction monitoring systems.

Fees, Reserves & Limits

Wallet Services may be subject to:

• transaction fees;
• FX fees;
• blockchain fees;
• wallet fees;
• inactivity fees;
• reserve requirements;
• settlement fees; and
• account maintenance fees.

Paymenture may establish:

• reserves;
• rolling reserves;
• delayed settlement mechanisms;
• withdrawal restrictions; or
• account holds

where reasonably necessary to mitigate:

• fraud risk;
• sanctions risk;
• liquidity exposure;
• operational risk; or
• regulatory risk.

Right to Freeze, Restrict, or Terminate

Paymenture and its Service Providers reserve the right to:

• reject onboarding;
• reject transactions;
• reverse transactions where permitted;
• freeze funds or digital assets;
• impose reserves or limits;
• restrict withdrawals;
• suspend account functionality;
• terminate Wallet Services; or
• report activity to regulators or law enforcement.

Force Majeure

Paymenture shall not be liable for delays, interruptions, freezes, restrictions, or failures caused by:

• banking outages;
• blockchain congestion;
• stablecoin depegging;
• liquidity failures;
• sanctions actions;
• cyberattacks;
• cloud outages;
• payment network failures;
• telecommunications failures; or
• failures of Service Providers.

Export Controls & Sanctions Compliance

Users agree to comply with all applicable:

• sanctions laws;
• export control laws;
• embargo laws; and
• trade compliance regulations.

Paymenture may:

• conduct sanctions screening;
• conduct blockchain analytics;
• restrict jurisdictions;
• reject transactions;
• freeze assets; or
• terminate Wallet Services

where sanctions or export-control risks arise.

No Fiduciary Relationship

Nothing in these Wallet Terms creates:

• a fiduciary relationship;
• trustee relationship;
• custodial relationship;
• agency relationship; or
• advisory relationship.

Paymenture acts solely as:

• a technology provider;
• infrastructure provider; and/or
• service facilitator.

No Legal, Tax, or Investment Advice

Paymenture does not provide:

• legal advice;
• tax advice;
• accounting advice;
• investment advice; or
• financial planning services.

Users are solely responsible for obtaining independent professional advice.

Assignment

Paymenture may assign or transfer these Wallet Terms in connection with:

• mergers;
• acquisitions;
• restructurings;
• sponsor bank changes;
• program migrations; or
• Service Provider transitions.

Users may not assign accounts or Wallet Services without Paymenture's prior written consent.

Survival

The following provisions survive termination:

• reserves;
• compliance obligations;
• sanctions obligations;
• limitation of liability;
• dispute resolution;
• export controls;
• indemnification;
• freezes and holds; and
• Paymenture enforcement rights.