Risk Disclosure & Platform Disclaimer

Nature of Echlon — Technology Provider Only

Echlon Ltd (“Echlon,” “we,” “us,” or “our”) is a British Virgin Islands incorporated financial technology company that provides software infrastructure enabling cross-border payments, settlement, and treasury workflows. All regulated financial activities are performed exclusively by Partners.

Echlon is not, and does not operate as:

• A bank or banking institution;
• A money services business or money transmitter;
• A licensed payment institution or e-money institution;
• A custodian or trustee of user funds or virtual assets; or
• A financial adviser or investment manager.

Echlon is not registered as a Virtual Asset Service Provider (“VASP”) under the BVI Virtual Assets Service Providers Act, 2022. Echlon’s technology-only, non-custodial operating model falls within the categories of activity excluded from the VASP Act’s scope — the provision of software and technology services that do not extend to the exchange, transfer, safekeeping, or administration of virtual assets on behalf of another person as a business.

Echlon does not hold, control, custody, or manage user funds or virtual assets at any time, does not control private keys, and does not operate custodial wallets. All transactions are user-authorised and executed by Partners.

Third-Party Partner Services

The regulated services accessible through the platform — including payment processing, cross-border settlement, foreign exchange, and treasury management — are provided by Partners holding the required licences and regulatory authorisations in their respective jurisdictions.

Your use of Partner services is governed by each Partner’s own terms, privacy policies, and regulatory obligations. By accessing Partner services through the platform, you agree to the applicable Partner terms, which may be presented directly or incorporated by reference into the Terms of Service. Where the Terms of Service and Partner terms conflict regarding a regulated service, the Partner terms control.

Echlon does not guarantee the availability, performance, or continuity of any Partner service and makes no representations regarding the financial condition or regulatory standing of any Partner. You have no contractual relationship with any Partner through Echlon unless you separately accept that Partner’s terms.

No Deposit Insurance or Fund Protection

Accounts and balances accessible through the platform are not covered by the FDIC, FSCS, or any equivalent deposit protection scheme unless explicitly stated by a Partner in writing. In the event of Partner insolvency, failure, or regulatory intervention, your funds may be at risk.

Self-Custody and Non-Custodial Wallets

To the extent the platform provides access to non-custodial digital asset wallets, you bear sole responsibility for the safekeeping of your private keys, seed phrases, and recovery credentials. Echlon does not store, access, or control any private keys or wallet credentials. You acknowledge and accept the following risks:

• Loss of private keys, seed phrases, or recovery credentials results in permanent, irrecoverable loss of access to your wallet and associated assets. Echlon cannot recover lost keys under any circumstances.
• Virtual assets, including stablecoins, are not legal tender and are not backed by any government or central bank unless stated by the issuer.
• Virtual asset values are highly volatile and may decrease to zero. Past performance is not indicative of future results.
• Blockchain transactions are generally irreversible. Errors in wallet addresses or transaction parameters may result in permanent loss of assets.
• Smart contract vulnerabilities, protocol failures, and blockchain network disruptions may result in loss of assets beyond Echlon’s control.

Cross-Border Payment and Settlement Risks

The following risks apply to cross-border payment and settlement services facilitated through the platform:

• Settlement timelines vary by payment rail, jurisdiction, Partner processing times, and correspondent banking relationships. Echlon does not guarantee specific timeframes.
• Exchange rates are determined by Partners at execution and may differ from mid-market rates. Conversion fees and spreads may apply.
• Regulatory changes, sanctions updates, or geopolitical events may affect the availability of payment corridors or currencies without notice.
• Cross-border transactions may be subject to intermediary bank deductions or local regulatory requirements that reduce the received amount or delay settlement.
• Transactions involving certain jurisdictions may be delayed, blocked, or rejected based on applicable sanctions requirements or Partner risk policies.

Treasury and Yield Product Risks

To the extent the platform provides access to treasury management or yield-generating products — including tokenized assets, money market instruments, or yield-generating protocols — the following risks apply:

• Yield rates and returns are not guaranteed. Past yields are not indicative of future performance. Returns may fluctuate or cease entirely.
• Tokenized assets carry issuer risk, liquidity risk, and regulatory risk in addition to general digital asset risks. Echlon does not determine or represent the regulatory classification of any asset accessible through the platform. The regulatory treatment of tokenized assets and yield-generating products is evolving and may change in ways that restrict availability or affect value.
• Access to certain products may be restricted by jurisdiction, regulatory classification, or Partner and issuer requirements. You are solely responsible for determining whether any product is permissible in your jurisdiction.
• Nothing on the platform constitutes a recommendation, solicitation, or offer to buy or sell any financial instrument or investment product.
• Liquidity of tokenized assets may be limited. Redemption or exit at your desired price or timing is not guaranteed.

AML/CFT/CPF Compliance

Platform access is subject to Echlon’s AML/CFT/CPF compliance programme, including mandatory KYC/KYB onboarding, sanctions screening, and ongoing monitoring. Full compliance obligations, account restriction powers, and disclosure limitations are set forth in the Terms of Service (Section 7).

No Financial, Legal, or Tax Advice

Nothing on the platform or in any Echlon communication constitutes financial, legal, tax, or other professional advice. You are solely responsible for assessing the suitability of any service, complying with applicable tax obligations, and obtaining independent professional advice where appropriate.

Technology and Operational Risks

The following risks are inherent in the use of the platform:

• The platform is provided “as is” and “as available.” Echlon does not warrant uninterrupted access, error-free operation, or the absence of security vulnerabilities.
• Blockchain networks are decentralised and outside Echlon’s control. Network congestion, forks, or failures may affect transaction processing.
• Cybersecurity threats present risks to accounts and assets. You are responsible for maintaining the security of your credentials and devices.
• API connectivity with Partners, payment rails, and blockchain infrastructure may experience downtime or failures beyond Echlon’s control.

Limitation of Liability

Liability limitations and aggregate caps applicable to your use of the platform and all Services are governed exclusively by the Terms of Service (Section 12). Nothing in this Disclaimer creates additional or separate liability exposure beyond what is set forth in the Terms of Service.

Jurisdictional Restrictions

The platform is not available to users in jurisdictions subject to comprehensive sanctions or otherwise prohibited under the Governing Documents. Prohibited jurisdictions and high-risk jurisdictions subject to Enhanced Due Diligence are set forth in the Terms of Service (Section 8). Additional services may be restricted by jurisdiction based on local law, Partner requirements, or Echlon’s risk assessment. You are solely responsible for ensuring your use complies with all applicable laws.

Governing Law and Dispute Resolution

This Disclaimer is governed by the laws of the British Virgin Islands. Disputes arising in connection with this Disclaimer are resolved in accordance with the Terms of Service (Section 14), including the binding arbitration and class action waiver provisions therein.

Contact

Echlon Ltd
British Virgin Islands

Compliance: [email protected]
General Support: [email protected]

May 2026