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description: 'Last update: May 10, 2025'
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# Risk Disclosure Statement and Disclaimer

This Risk Disclosure Statement and Disclaimer ("Disclosure") shall be read in conjunction with the MidasVault User Agreement ("User Agreement"). Unless otherwise defined herein, capitalized terms shall bear the meanings ascribed to them in the Terms of Service incorporated by reference. This Disclosure is intended to alert you, as a user of the MidasVault Visa Card and associated digital services, to certain legal, regulatory, operational, and financial risks inherent in the use of digital assets and payment technologies.

## Purpose and Legal Framework

This Disclosure aims to ensure transparency and compliance by setting out the principal risks associated with the use of the MidasVault Visa Card and the MidasVault platform. We have implemented comprehensive Anti-Money Laundering ("AML"), Counter-Terrorist Financing ("CTF"), and sanctions compliance frameworks (together, the "Compliance Systems") to prevent illicit activities, uphold international best practices, and maintain public confidence.

We are committed to fostering lawful and transparent transactions, and we reserve the right to suspend, restrict, or terminate access to any user account where such use is inconsistent with our Compliance Systems, legal obligations, or our internal risk assessments.

## Platform and Business Model

The MidasVault platform operates as a global digital asset and payment facilitation network, enabling users to interact as buyers and sellers in a peer-to-peer or brokered environment. While most transactions are conducted directly between users, affiliated entities may act as counterparties under specific conditions.

You acknowledge that the platform is a venue for facilitating transactions and not a party to all trades executed therein, save as expressly stated in the User Agreement.

Important Disclaimer: Transactions in digital assets and the use of associated payment methods, including virtual and physical cards, carry significant risk of loss and may not be suitable for all individuals. Users should consult independent financial, legal, or tax advisers prior to engaging in such activities.

We acknowledge that digital assets are treated differently across jurisdictions—some authorities classify them as convertible virtual currencies, others as intangible property or virtual goods. MidasVault regards these assets as novel and alternative investment instruments.

Digital assets are not fiat currency, legal tender, or guaranteed by any sovereign authority. They may be subject to legislative or regulatory changes, which may materially impact their use, value, or legality.

We may limit or deny access to our Services in jurisdictions subject to heightened regulatory restrictions, sanctions, or where we are not authorised to operate. We reserve the right to amend the list of restricted jurisdictions without prior notice in accordance with changes in law or internal policy.

## AML/CTF/Sanctions Compliance System

We operate a risk-based, multi-tiered control system designed to detect and deter unlawful transactions. This system includes:

Layer 1: Know-Your-Customer ("KYC") protocols requiring documentary verification of identity for individual and institutional users.

Layer 2: Ongoing screening of users and beneficial owners against government and intergovernmental sanction lists, including OFAC, UN Security Council, and Hong Kong Gazette publications.

Layer 3: Continuous surveillance of transaction behavior, with triggers for unusual activity based on inconsistencies in user profile or conduct. Where warranted, we may file Suspicious Transaction Reports (STRs) to the appropriate regulatory body.

Our compliance officers are trained to enforce these measures, supported by automated monitoring tools and regular audits. We retain all relevant records in accordance with statutory retention requirements.

## Key Risk Disclosures

1. Market and Volatility Risk Digital asset prices may be volatile and subject to abrupt movements. Users may incur substantial losses and should not allocate funds they cannot afford to lose.
2. Regulatory and Legal Risk Laws governing digital assets continue to evolve. Regulatory actions may adversely impact the operation, availability, or value of digital assets and the Services.
3. Technology and Systemic Risk Operational disruptions (e.g. service downtime, cyberattack, software error) may affect access to your account or the execution of transactions. While we employ robust cybersecurity standards, no system is invulnerable.
4. Counterparty Risk Where MidasVault or its affiliates act as a counterparty to any transaction, the user is exposed to the credit and operational risk of that entity. Counterparty insolvency may affect your claims or access to funds.
5. Jurisdictional Risk and Access Restrictions Access to Services may be restricted or terminated at our discretion in compliance with legal or regulatory mandates. Users remain responsible for determining the legality of using our Services in their local jurisdiction.
6. Foreign Exchange Risk and Card Use Disclosure You acknowledge and agree that any card transaction conducted in a currency other than USDT or USD will be subject to applicable exchange rates, and may involve foreign exchange conversions through third-party payment processors.
7. System Error Disclaimer: In the event of a system failure or processing anomaly (as determined at our sole discretion), any resulting discrepancy in settlement amounts, including balance discrepancies in USDT/USD equivalent, shall not give rise to liability on our part. You accept the full risk of such occurrences and agree to indemnify us against related losses or costs.

## Indemnity

You agree to fully indemnify and hold harmless MidasVault, its affiliates, officers, employees, and service providers from any claim, demand, loss, liability, cost or expense (including legal fees) arising from your use of the Services, your breach of this Disclosure or any applicable law, or your violation of any third-party rights.

## No Guarantee or Fiduciary Relationship

MidasVault and its affiliates do not act as your trustee, investment adviser, or fiduciary. No communication from us shall be construed as legal, tax, or financial advice. You alone are responsible for assessing the appropriateness of engaging with digital assets and the use of our Services.

By continuing to use the MidasVault Visa Card or the MidasVault platform, you confirm that you have read, understood, and accepted the risks set forth in this Disclosure. You further affirm that your use of the Services is voluntary and informed, and that you assume full responsibility for any and all resulting outcomes.

This Disclosure may be updated from time to time and the latest version shall be deemed effective upon publication on our website or application.

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