Last Modified: January 15, 2026

IMPORTANT NOTICE: THIS AGREEMENT CONTAINS A BINDING ARBITRATION PROVISION AND CLASS ACTION WAIVER. IT AFFECTS YOUR LEGAL RIGHTS AS DETAILED IN THE ARBITRATION AND CLASS ACTION WAIVER SECTION BELOW. PLEASE READ THE ENTIRE DOCUMENT CAREFULLY.

1. ACCEPTANCE OF THIS AGREEMENT; CHANGES.

1.1 These Terms and Conditions for Platform Services (this “Agreement” or the “Platform Terms and Conditions”) is a legally binding contract between Paxos Trust Company, NA, a national banking association organized under the laws of the United States and regulated by the Office of the Comptroller of the Currency (“Paxos Trust”) and its applicable Affiliates (as defined below), including Paxos Global PTE LTD (“Paxos Global”), Paxos Digital Singapore Pte. Ltd. (“Paxos Digital”), Paxos Issuance Europe Oy (“PIE”) and Bruntal S.A. (dba Paxos Uruguay) (“PUY”), (collectively, “Paxos,” “we,” “us” or “our”) and you as a registered user of the Paxos Platform (as defined below) (also referred to herein as a “Customer”). A “Party” means each of Paxos and you.

1.2 This Agreement, including our Privacy Policy, GLBA Privacy Notice, and any other included schedules, exhibits, or referenced policies and guidelines, which are incorporated herein by reference and form part of this Agreement (each, a “Schedule,” and collectively, the “Schedules”), as may be updated or provided to you from time to time, govern your use of the platform and the Products and Services (as defined below) made available to Customers of Paxos thereon (the “Paxos Platform”). For the avoidance of doubt, certain Schedules may apply only if and when you elect to access or utilize applicable Paxos Products or Services made available to your jurisdiction and to which such Schedule relates.

In the event of any conflict between this Agreement and the terms of any Schedule or the Pricing Supplement (as defined below), the Schedules and the Pricing Supplement will take precedence, followed by the terms of this Agreement, unless explicitly stated otherwise in the applicable Schedule or Pricing Supplement. In the event that the Parties enter into a separate written agreement regarding the subject matter of this Agreement, the terms of such separate agreement will govern and take precedence over this Agreement to the extent of any inconsistency or conflict between them. To the extent you do not access or utilize a specific Paxos Product or Service that is described in a Schedule, the terms of that Schedule will not apply to you unless and until you do access or utilize that specific Paxos Product or Services, at which time, you will be bound by the terms and conditions therein.

1.3 This Agreement may be changed by us at any time. You may determine if any such changes have taken place by referring to the “Last Modified” date on which this Agreement was last updated. The updated terms will take effect immediately upon posting or on any later date as stated in the update itself. If we make any material changes to this Agreement, we may (but are not required to) send you an email or other written notification regarding the update. Notwithstanding the foregoing, it is your sole responsibility to review this Agreement on a regular basis to ensure that you understand how your rights and responsibilities may have been affected by any updates. You may not pick and choose which terms of this Agreement apply to you. Your continued use of the Paxos Platform constitutes your acknowledgement and acceptance of this Agreement. If you do not wish to continue to be bound by the terms of this Agreement or any updates, your sole remedy is to cease all access and use of the Paxos Platform and close your Account (as defined below). Nothing in this Agreement is intended to create any enforcement rights by third parties. If you do not understand all of the terms and conditions in this Agreement, you should consult with a lawyer before using the Paxos Platform.

1.4 Consideration for your acquiescence to all of the provisions in this Agreement has been provided to you in the form of allowing you to register for, access and/or use the Paxos Platform and you agree that such consideration is adequate.

Should you have any questions or comments regarding the Paxos Platform, please feel free to contact us at: support.paxos.com

2. ELIGIBILITY; OPENING YOUR ACCOUNT.

2.1 In order to become a Customer, you must be at least eighteen (18) years of age. By registering to become a Customer, you represent and warrant that this is the case and If you are under the age of eighteen (18) or the legal age for entering legally binding contracts under applicable laws, you are not permitted to use the Paxos Platform. By continuing to access or use the Paxos Platform, you indicate that you are eighteen (18) years of age or older or you otherwise have the capacity to enter legally binding contracts under applicable law where you reside and are located.

2.2 If you are entering this Agreement on behalf of a company or other legal entity or organization, you (a) represent that you have the full right, power and authority to bind such company, entity or organization to this Agreement and (b) agree that you will use the Paxos Platform for commercial purposes only, in which case, references to “you,” “your” or “Customer” refers to that company, entity or organization.

2.3 As part of the process to create an account on the Paxos Platform (an “Account”), Paxos will, (i) cross-check your name (and/or the names of your Authorized Users (as defined below), beneficial owners or other applicable representatives) against compliance databases such as the United States Department of Treasury Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals list and other governmental watch lists as well as those maintained by non-U.S. authorities, (ii) require you to verify your identity and identification documents presented at onboarding and (iii) not permit you to undertake any activity on the Paxos Platform with incomplete account opening information (the “Onboarding Requirements”). You may be required to refresh the Onboarding Requirements on a cadence to be determined by Paxos in its sole discretion. More information about Paxos’ Know Your Customer (KYC) and compliance processes is available in the Anti-Money Laundering/Know Your Customer (AML/KYC) Disclosure Schedule.

2.4 In connection with opening an Account, you may also be required to disclose certain third-party account information to us, including, but not limited to, your bank account number, your crypto asset wallet address(es) and other related information. While we use reasonable efforts to protect your Customer Data (as defined below) from inadvertent release or misappropriation, we are not responsible for the intentional or criminal acts of third parties such as hackers or “phishers.”

2.5 By your use of the Paxos Platform and your Account, you represent that such use is legal in your local jurisdiction and you agree that you will not use the Paxos Platform or your Account in any manner if such use is prohibited or otherwise violates the laws of the country, state, province or other jurisdiction in which you reside or of which you are a citizen.

2.6 In the event you are prompted by the Paxos Platform to designate an authorized user (i.e., an employee or contractor of Customer) (each, an “Authorized User”), you will identify to Paxos in writing each Authorized User’s name and email address, as well as provide all information required to meet and pass Paxos’ Onboarding Requirements with respect to such Authorized User. You may from time-to-time change an Authorized User by providing Paxos reasonable advance written notice of the change, provided that such Authorized User passes Paxos’ Onboarding Requirements. Each Authorized User will have a unique user name and password for access to the Paxos Platform. No Authorized User may share its unique user name and password with any other person or otherwise permit or enable any other person to access or use the Paxos Platform. You are fully responsible for protecting the confidentiality of all such unique user names and passwords and all activities undertaken through the use of such user names and passwords and acknowledges that any actions under such user names and passwords will be deemed to have been performed by you. You will immediately, without undue delay, notify Paxos of any unauthorized use of any user names or password or any other actual, potential, or threatened breach of security known to it. You are solely responsible and liable for each Authorized User’s compliance or non-compliance with the terms of this Agreement. Paxos may restrict or deny access to any Authorized User who it believes has violated, is violating, or may violate the terms of this Agreement.

3. PRODUCTS AND SERVICES.

3.1 You may use the Paxos Platform and your Account solely as outlined herein, in any Schedule and as provided in the pricing supplement provided to you by Paxos separate from this Agreement, which is incorporated herein by reference and forms part of this Agreement (a “Pricing Supplement”).

3.2 Paxos will use commercially reasonable efforts to make available on the Paxos Platform the “Products” you elect to use as further described in the Schedules hereto or other Paxos documentation that may be provided to you from time-to-time. As used herein, “Services” means the provision of the Products and any other related services you elect to be performed by Paxos and/or its Affiliates hereunder. Paxos reserves the right to add, modify, or remove Products and Services offered on the Paxos Platform at any time, with or without prior notice. You understand that access to certain Products or Services may require you to agree to additional terms and conditions, which may be set out in additional Schedules or agreements provided to you. By requesting or using such Products or Services, you agree to comply with any applicable additional terms. For clarity this Agreement does not entitle you to any support for the Products or Services.

3.3 Paxos may provide the Products and Services directly or through any Affiliate. As used herein “Affiliate” refers to any other legal entity that either directly, or indirectly through one or more intermediaries controls, is controlled by, or is under common control with a Party hereto. By requesting or using specific Products and Services, you acknowledge and agree that you may be onboarded to, and enter into a direct relationship with, Paxos or one of its applicable Affiliates, depending on the nature of the Product and/or Service you access. Paxos and its Affiliates reserves the right to determine, at their sole discretion, which entity will provide relevant Products and Services to you. Where onboarding to a Paxos Affiliate is required of you, you agree to comply with any additional terms, conditions and onboarding procedures that may apply to that entity in order to access the relevant Product or Service. For purposes of this Agreement, “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies, or operations of an entity, whether through ownership of voting securities, by contract, or otherwise.

3.4 In addition, your Affiliate(s) may access the Products and Services pursuant to this Agreement with the written consent of Paxos and subject to the entity’s successful completion of and adherence to Paxos’ Onboarding Requirements. In such instances, all references to you in this Agreement will be deemed to refer to the applicable Affiliate unless the context otherwise indicates, and the Affiliate agrees to abide by all such terms.

3.5 During the Term, you may provide Paxos with feedback regarding your use of the Products and Services, including suggestions or other information or materials relating to the Products and Services, either voluntarily or in response to Paxos’s request (collectively, “Feedback”). You hereby grant Paxos and its Affiliates (as applicable) a nonexclusive, transferable, sublicensable, worldwide, perpetual, irrevocable, royalty-free license to freely exploit and make available all Feedback.

4. PROPRIETARY RIGHTS.

4.1 Paxos (or its applicable Affiliate) owns and retains all right, title and interest in and to the Paxos website(s) (currently located at www.paxos.com), including any restricted access portions of such website(s) to which you may be provided access, as may be updated from time to time, the Paxos Platform, the Products and Services, and all intellectual and proprietary rights therein, including any data, technology, infrastructure, methods or know-how disclosed as part of delivering the Products and providing the Services (including all improvements, derivatives, and modifications thereto, as well as any user interfaces and the ‘look and feel’ thereof), as well as any instructions, documentation, code, content, and any other information (excluding Customer Data (as defined below)) and/or support services provided in connection with this Agreement (collectively, the “Paxos Materials”). Paxos hereby grants you a limited, non-exclusive, non-sublicensable, non-transferable right to access and use the Paxos Materials during the Term solely in accordance with the terms of this Agreement. Unless otherwise expressly set forth agreed via a separate written instrument, all work product of any kind created in connection with this Agreement will be deemed Paxos Materials, and you are not permitted to modify any Paxos Materials without the prior written consent of Paxos.

4.2 Notwithstanding the foregoing, you own and retain all right, title and interest in and to any data that you provide to Paxos for the provision of the Products and Services (the “Customer Data”), including all intellectual and proprietary rights therein. For clarity, Customer Data does not include any data that was or is independently obtained or derived by Paxos. You hereby grant to Paxos and its Affiliates a non-exclusive, royalty-free, worldwide, fully paid license to use the Customer Data for purposes of providing, improving or enhancing the Products and Services.

4.3 For the avoidance of doubt, nothing in this Agreement will affect or modify either Party’s ownership rights in any pre-existing or future works, trademarks, copyrights or technologies developed or created by either Party.

4.4 Unless expressly specified otherwise in this Agreement, you will not (i) use any Paxos Materials on behalf of any third party, (ii) allow any unauthorized user to access any Paxos Materials, (iii) reverse engineer, decompile, disassemble, or otherwise attempt to discover any source code related to any of the Paxos Materials, (iv) attempt to discover any trade secrets with respect to the Paxos Materials, (v) distribute, license, rent, sell, assign, re-transmit, publish, lease, share, or otherwise transfer or disclose any Paxos Materials to any third party or use or allow any third party to use, directly or indirectly, the Paxos Materials to operate a service bureau, (vi) copy, modify, adapt, translate, or create derivative works of or based on any of the Paxos Materials, (vii) remove any proprietary notices or labels on any of the Paxos Materials, (viii) use, post, transmit or introduce any device, software, or routine which interferes or attempts to interfere with the operation of the Products or Services or any Paxos Materials and (ix) attempt to re-identify or otherwise reverse engineer the data it receives in connection with this Agreement, including to derive personal information from, or merge personal information with, any non-personal information provided by Paxos. You agree to immediately, without undue delay, notify Paxos in writing of any actual or suspected breach of this Section.

4.5 You will protect any data and information provided by Paxos (including all Paxos Materials) from unauthorized access, loss and misuse, such efforts including, but not limited to, the encryption of stored information behind a secured server network and industry standard organizational, contractual, technological and managerial safeguards. You agree to immediately (and in all cases, within 24 hours) notify Paxos of any unauthorized access or acquisition of Paxos’s data or information, and to provide (at your expense) reasonable cooperation in investigations, determining and resolving any such data breach.

5. FEES AND BILLING.

5.1 You will pay Paxos the fees for its Products and Services as set forth in the then-current Pricing Supplement or other then-current fee schedule published or made available by Paxos (the “Fees”) in United States Dollars. You will pay all invoices within thirty (30) days of the invoice date. If you require a purchase order (“PO”) to pay invoices, you must issue the PO to Paxos prior to incurring any Fees. Any amounts overdue by more than thirty (30) days will accrue interest from the due date at the lower of (i) 1.5% per month or (ii) the maximum rate permitted by applicable law. All Fees are non-refundable and non-cancelable. All amounts payable by you under this Agreement will be paid without setoff, deduction, recoupment, or withholding of any kind, including for amounts allegedly owed by Paxos.

5.2 We reserve the right to change or modify the Fees at any time in our sole discretion. Any such changes, modifications or increases will be effective upon posting on the Paxos Platform or an updated Pricing Supplement; such posting constitutes effective notice of the new Fees. Your first use of the Paxos Platform following the posting of any changes to the Fees will constitute your acceptance of such changes. If you do not agree to the changes, you may close your Account as provided in the Paxos Contractual Documentation.

5.3 Unless expressly stated on an invoice, the Fees do not include any taxes, levies, duties or similar governmental assessments of any nature, including but not limited to value-added, sales, use or withholding taxes, assessable by any local, state, provincial, federal or foreign jurisdiction (collectively, “Taxes”). You are solely responsible for paying all Taxes and bank fees, if applicable, associated with receipt of the Products and Services hereunder. If Paxos has the legal obligation to pay or collect Taxes or bank fees for which you are responsible, the applicable amount will be invoiced to and paid by you, unless you provide Paxos with a valid tax exemption certificate authorized by the appropriate taxing authority. For clarity, Paxos is solely responsible for taxes assessable against it based on Paxos’s income, property and employees.

6. CONFIDENTIALITY.

6.1 Each Party agrees that the business, technical and financial information, that is designated in writing as confidential, or is disclosed in a manner that a reasonable person would understand the confidentiality of the information disclosed, will be the confidential property of the disclosing party, its Affiliates and/or its licensors (“Confidential Information”). Confidential Information includes, but is not limited to, the terms of this Agreement, the Paxos Materials, and the Customer Data. Confidential Information does not include information that (i) is previously rightfully known to the receiving party without restriction on disclosure, (ii) is or becomes known to the general public, through no act or omission on the part of the receiving party, (iii) is disclosed to the receiving party by a third party without breach of any separate nondisclosure obligation or (iv) is independently developed by the receiving party.

6.2 Except as expressly and unambiguously allowed herein, the receiving party will hold in confidence and not use or disclose any Confidential Information and will similarly bind its employees, consultants, and independent contractors. Each Party will, as soon as reasonably practical after discovery, report to the other Party any unauthorized disclosure or access to the other Party’s Confidential Information, subject to any reasonable restrictions on the timing of such notice by a law enforcement or regulatory agency investigating the incident, and take all reasonable measures to prevent any further unauthorized disclosure or access. If required by law, the receiving party may disclose Confidential Information of the disclosing party, but will take reasonable steps to limit any such disclosure, to give as much prior notice as possible of such disclosure to the disclosing party to permit the disclosing party to intervene, and to request protective orders or other confidential treatment therefor. The parties agree that any violation of the confidentiality obligations described herein may cause irreparable harm and significant injury to the other, which may be difficult to ascertain. Accordingly, each party will be entitled to seek equitable relief, including, an immediate injunction enjoining any breach by it of these confidentiality obligations, in addition to all other remedies available to such party at law or in equity.

7. ACCOUNT SUSPENSION, CLOSURE AND TERMINATION; CHANGES IN LAW.

7.1 This Agreement will begin on the date of your Account opening and continue until terminated in accordance with the terms of this Agreement (the “Term”).

7.2 You may close your Account by providing written notice to us, and upon receipt of such notice, a hold will be placed on your Account to allow any then pending transactions to clear. After notifying us of your desire to close your Account, we may terminate your ability to transact in your Account and only permit you to withdraw the remaining available funds associated with your Account. Closing your Account will not affect any rights and obligations incurred prior to the date of Account closure. All currencies appearing in the Product’s ledger and attributed to you must be withdrawn or otherwise sold or transferred before the closing of your Account will be finalized. You shall have a period of 90 days (or an otherwise specified timeframe agreed upon in writing) to withdraw, sell, or transfer your assets. Should you fail to take the specified actions within this defined timeline, Paxos shall be granted the right to take necessary actions on your behalf. Such actions may include the conversion of all assets into stablecoins or fiat currency, at Paxos' sole discretion.

7.3 Without limiting other remedies that may be available to us under applicable law, we reserve the right, in our sole and absolute discretion, to block access to or to suspend, close or terminate your Account (which may include closing open positions held in your Account), refuse to let you purchase or redeem crypto assets, and freeze all funds or assets in your Account, at any time, with or without advance notice, if:

1. we believe, in our sole and absolute discretion, that you have breached any terms and conditions of this Agreement;

2. you engage in unusual or abusive behavior, as determined in our sole and absolute discretion;

3. we are directed to do so by law enforcement, regulatory authority or court order or otherwise required to do so by applicable law or regulation;

4. your Account is subject to pending litigation, investigation or governmental proceeding;

5. we believe that someone is attempting to gain unauthorized access to your Account;

6. your Account has no funds and has not been accessed in the prior year; or

7. for any other reason in our sole and absolute discretion.

In addition, we may discontinue the Paxos Platform or any Product or Service available thereon at any time.

7.4 Upon closure of your Account, this Agreement will automatically terminate. Upon termination of this Agreement for any reason, (i) you and your Authorized Users, if any, will no longer have access to your Account or the Products or Services, (ii) you will cease using, destroy and remove from all computers, hard drives, networks, and other storage media all copies of the Paxos Materials and any Confidential Information of Paxos, and on written request of Paxos, will so certify to Paxos that such actions have occurred, (iii) Paxos will use commercially reasonable efforts to delete Customer Data, provided, however, that Paxos will have no obligation to delete or revoke any proprietary information that is derived from Customer Data, (iv) all licenses granted by Paxos to you hereunder will immediately terminate, and (v) neither Party will have any further liability to the other Party, other than for amounts due to Paxos for Services provided prior to and including the date of termination.

7.5 Paxos may modify, or withdraw or decline to provide to you, any Paxos Materials, Products or Services to comply with any requirements imposed by any third parties, governmental authority, applicable judicial or administrative decisions, or industry self-regulatory guidelines. In the event that there is any change in applicable laws, rules, and regulations which change renders the subject matter of this Agreement illegal, then either Party may immediately terminate this Agreement without any liability to the other Party, other than for amounts due to Paxos for Services provided prior to and including the date of termination.

7.6 Paxos may, without limiting any other remedies, suspend its performance of any Services and/or restrict or deny access to the Paxos Materials in the event of any actual or suspected unauthorized use or disclosure of the Confidential Information or if you fail to (i) comply with any data security requirements required by law or under this Agreement, or otherwise comply with the terms of this Agreement and applicable law, or (ii) pay any amount when due under this Agreement provided Paxos has given written notice of the delinquency and you have not made payment of all undisputed amounts within ten (10) days of receipt of such notice.

8. WARRANTIES, RISKS & DISCLAIMERS.

8.1 Paxos represents and warrants that the Paxos Platform, Products and Services will comply with applicable laws and regulations.

8.2 Paxos has implemented and will maintain an information security program that contains administrative, technical and physical safeguards that are appropriate to its size and complexity, the nature and scope of its activities, and the sensitivity of any customer information at issue.

8.3 Each Party represents and warrants to the other that (i) to the extent applicable, it is duly organized, validly existing and in good standing as a corporation or other entity under the laws of the jurisdiction of its incorporation or other organization, (ii) it has the full right, power, and authority to enter into and perform its obligations and grant the rights, licenses, consents and authorizations it grants or is required to grant under this Agreement, (iii) the execution of this Agreement by itself or its representative whose signature is set forth at the end of this Agreement has been duly authorized by all necessary corporate or organizational action of such Party, (iv) when executed and delivered by both Parties, this Agreement will constitute the legal, valid and binding obligation of such party, enforceable against such Party in accordance with its terms and (v) this Agreement does not violate any law, statute, or regulation and does not breach any other agreement or covenant to which it is a party or is bound.

8.4 You acknowledge and accept that there may be significant risks associated with the use of the Paxos Platform and crypto assets in general, including, but not limited to, (i) substantial losses in crypto asset trading, potentially occurring over short periods, (ii) extreme price and liquidity fluctuations, (iii) lack of government backing or protections, (iv) potential adverse effects of regulatory changes, (v) risks related to blockchain forks, which Paxos may not support, (vi) irreversibility of transactions, leading to potential loss due to fraud or error, (vii) timing discrepancies between transaction initiation and ledger recording, (viii) security risks related to the loss or compromise of private keys, (ix) dependency on market participants for value retention, (x) uncertainty in merchant acceptance of crypto assets, (xi) significant volatility relative to fiat currency, (xii) increased risks of fraud, cyberattacks, and technological failures impacting asset access, (xiii) the possibility that any bond or trust account maintained by Paxos may be insufficient to cover customer losses, (xiv) Paxos' potential lack of regulation as a financial institution in certain jurisdictions, (xv) Paxos providing no financial, legal, tax, or investment advice, and (xvi) Paxos treating airdropped crypto assets as unsupported and not crediting them to user accounts. You acknowledge that this Agreement does not disclose all potential risks associated with crypto asset transactions.

8.5 YOU ACKNOWLEDGE AND AGREE THAT USE OF THE PAXOS PLATFORM, PRODUCTS AND SERVICES IS AT YOUR SOLE RISK. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW AND EXCEPT AS OTHERWISE EXPRESSLY PROVIDED IN THIS AGREEMENT, (I) THE PAXOS MATERIALS AND THE PRODUCTS AND SERVICES ARE PROVIDED ‘AS IS’ AND ‘AS AVAILABLE,’ WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND AND (II) PAXOS MAKES NO AND HEREBY DISCLAIMS ANY AND ALL REPRESENTATIONS, WARRANTIES, AND CONDITIONS WITH RESPECT TO THE PAXOS MATERIALS, THE PRODUCTS AND THE SERVICES, EITHER EXPRESS, IMPLIED, OR ARISING BY LAW (WHETHER BY STATUTE, COMMON LAW, CUSTOM OR USAGE, COURSE OF DEALING OR OTHERWISE), INCLUDING THE IMPLIED WARRANTIES AND/OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, COMPLETENESS, QUIET ENJOYMENT, RELIABILITY, TITLE, NON-INFRINGEMENT OR THAT ANY PAXOS MATERIALS WILL MEET YOUR REQUIREMENTS, THAT THE CUSTOMER DATA WILL BE PRESERVED WITHOUT LOSS, THAT THE OPERATION OR USE OF THE SERVICES, THE PAXOS PLATFORM OR PRODUCTS ARE OR WILL BE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, UNINTERRUPTED OR ERROR-FREE, OR THAT DEFECTS IN THE PAXOS MATERIALS WILL BE CORRECTED. NO ORAL OR WRITTEN INFORMATION, GUIDELINES, OR ADVICE GIVEN BY PAXOS OR ITS AUTHORIZED REPRESENTATIVE WILL CREATE A WARRANTY.

9. INDEMNITY.

9.1 You agree to defend, indemnify, and hold harmless Paxos and its Affiliates and their respective officers, directors, employees, agents, successors and assigns, and licensors (“Paxos Entities”) from and against any claims, actions, demands, losses, judgments, fines, or expenses (including reasonable attorneys’ fees) arising out of or in connection with (i) Customer Data, including any processing of Customer Data in accordance with this Agreement, (ii) your breach of any representations, warranties, covenants or other obligations under this Agreement, (iii) any regulatory inquiry, legal action, litigation, dispute or investigation related to your Account and to your use of your Account or the Paxos Platform, (iv) gross negligence or willful misconduct by you, any Authorized User or any third party on your behalf or on behalf of any Authorized User, in connection with this Agreement, (v) your use of any Paxos Materials other than as expressly authorized herein or (x) your gross negligence, willful misconduct or fraud.

9.2 Paxos will defend, indemnify, and hold harmless you and, as applicable, your Affiliates and respective officers, directors, employees, agents, successors and assigns, and licensors (“Your Entities”) from and against any third party claims, actions, demands, losses, judgments, fines, or expenses (including reasonable attorneys’ fees) arising out of or in connection with any third-party claim (i) resulting from its gross negligence, wilful misconduct or fraud or (ii) that the Products infringe, misappropriate, or otherwise violate any U.S. patents, copyrights, trademarks or trade secrets; provided, however, that Paxos will have no obligation under this Section to the extent any such claim arises out of Customer Data or any misuse of the Paxos Materials by you, any Authorized User or any third party on your behalf or on behalf of any Authorized User.

9.3 Each Party will promptly notify the other Party in writing of any claim for which a party seeking indemnification is entitled to be indemnified pursuant to this Section. The indemnified Party will reasonably cooperate with the indemnifying Party at the indemnifying Party’s sole cost and expense. The indemnifying Party will immediately take control of the defense and investigation of such action and will employ counsel of its choice to handle and defend the same, at the indemnifying Party’s sole cost and expense, provided, that, the indemnifying Party may not settle any action without the prior written approval of the indemnified Party, which approval will not be unreasonably withheld or delayed. Any failure to perform any obligations under this Section will not relieve the indemnifying Party of its obligations except to the extent that the indemnifying Party can demonstrate that it has been materially prejudiced as a result of such failure. The indemnified Party may participate in and observe the proceedings at its own cost and expense with counsel of its own choosing.

10. LIABILITY LIMITATION.

10.1 NEITHER PARTY WILL BE LIABLE TO THE OTHER PARTY, WHETHER IN CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE, PRODUCT LIABILITY OR STRICT LIABILITY) OR OTHERWISE FOR ANY CONSEQUENTIAL, INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES OR OTHER LIABILITY (INCLUDING LOSS OF DATA, LOSS OF PROFIT, REVENUE, OR USE, OR SYSTEM OUTAGES) ARISING OUT OF ANY PERFORMANCE, NONPERFORMANCE, BREACH, OR DEFAULT UNDER THIS AGREEMENT OR THE USE OF OR INABILITY TO USE ANY PAXOS MATERIALS OR ANY SERVICES PROVIDED UNDER THIS AGREEMENT.

10.2 EXCLUDING SPECIAL CLAIMS, IN NO EVENT WILL A PARTY’S LIABILITY ARISING OUT OF OR RELATED TO THIS AGREEMENT, WHETHER ARISING OUT OF OR RELATED TO BREACH OF CONTRACT, TORT (INCLUDING NEGLIGENCE) OR OTHERWISE, EXCEED THE AGGREGATE AMOUNTS PAID OR PAYABLE TO PAXOS PURSUANT TO THIS AGREEMENT IN THE TWELVE (12) MONTH PERIOD PRECEDING THE EVENT GIVING RISE TO THE CLAIM. As used in this Section, “Special Claims” means (i) your payment obligations under this Agreement, (ii) your indemnity obligations hereunder or (iii) grossly negligent, reckless, or willful acts or omissions.

11. ARBITRATION.

11.1 If a dispute arises between the Parties arising out of or otherwise relating to this Agreement, the Parties will meet and negotiate in good faith to attempt to resolve the dispute. If the Parties are unable to resolve the dispute through direct negotiations, then, except as otherwise provided herein, either Party must submit the issue to binding arbitration as further provided herein. Claims subject to arbitration (“Arbitral Claims”) will include, but are not limited to, contract and tort claims of all kinds, and all claims based on any federal, state or local law, statute, or regulation, excepting only claims by us under applicable worker’s compensation law, unemployment insurance claims, along with actions (regardless of the underlying cause of action) by us seeking injunctions, attachment, garnishment, and other equitable relief. You agree to arbitrate solely on an individual basis, and understand, acknowledge and agree that this Agreement does not permit class arbitration or any claims of any type brought as a plaintiff or class member in any class or representative arbitration proceeding.

11.2 Any dispute arising out of or relating to this Agreement, or the breach thereof, will be finally settled on an individual basis by arbitration in New York, New York administered by the American Arbitration Association in accordance with its Consumer Arbitration Rules. The language of the arbitration will be English and the Agreement will be governed by the laws of the State of New York. An arbitral decision may be enforced in any court, and a prevailing Party in any action or proceeding to enforce this Agreement will be entitled to reasonable costs and attorney’s fees. The arbitrator will have no authority to award any punitive or exemplary damages, certify a class action (or join the claims of one party with any other party), add any parties, or vary or ignore the provisions of this Agreement. The arbitrator will render a written opinion setting forth all material facts and the basis of his or her decision within thirty (30) days of the conclusion of the arbitration proceeding.

11.3 If for any reason this arbitration clause is not applicable or litigation proceeds in court, then you agree that:

1. You may bring claims against Paxos only in your individual capacity and not as a plaintiff or class member in any purported class or representative action; and

2. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAWS AND REGULATIONS, YOU HEREBY IRREVOCABLY WAIVE ALL RIGHT TO TRIAL BY JURY AS TO ANY ISSUE IN ANY ACTION, PROCEEDING, OR COUNTERCLAIM ARISING OUT OF OR RELATING TO THIS AGREEMENT OR ANY OTHER MATTER INVOLVING US ARISING OUT OF THE PAXOS PLATFORM, OR SERVICES (INCLUDING THE PRODUCTS).

3. There will be no waiver of the right to arbitration unless such waiver is provided affirmatively and in writing by the waiving party to the other party. There will be no implied waiver of this right to arbitration. No acts, including the filing of litigation, will be construed as a waiver or a repudiation of the right to arbitrate.

11.4 Notwithstanding the period of limitation prescribed by applicable laws for the bringing of any relevant action or claim, and except as otherwise provided in this Agreement, the Parties hereby mutually agree that no action, regardless of form, arising out of or in conjunction with the subject matter of this Agreement, except for claims involving intellectual property, claims to recover outstanding amounts due to us and claims for indemnification, may be brought by any Party more than one (1) year after the cause of action arose, following which either Party will have no further claim whatsoever against the other Party.

12. PUBLICITY. Neither Party will issue any press release concerning this Agreement without the prior written consent of the other Party. Any consent must be by an authorized signatory of the Party giving consent.

13. EXPORT CONTROLS. You understand, acknowledge and agree that the software elements of the Paxos Platform may be subject to regulation by agencies of the United States Government, including the United States Department of Commerce, which prohibits export or diversion of software to certain countries and third parties. Diversion of such materials contrary to the laws of the United States, or any international, provincial, state or other applicable law is prohibited. You will not assist or participate in any such diversion or other violation of applicable laws and regulations. You agree that none of the Paxos Materials or virtual currencies are being or will be used, acquired for, shipped, transferred or re-exported, directly or indirectly, to proscribed or embargoed countries or their nationals or be used for proscribed activities.

14. NOTICE.

14.1 Any notice we are required to give you under this Agreement may be provided by email utilizing the contact information provided by you when you registered for an Account. Notices from you to us will be submitted to our help desk via support.paxos.com unless otherwise specified in this Agreement. You may change your email address by submitting a notice to our help desk pursuant to the foregoing sentence. For the avoidance of doubt, the Paxos Platform is not a facility for sending or receiving private or confidential electronic communications and Paxos is not responsible for private communications sent through the Paxos Platform.

14.2 Notices will be deemed effective upon delivery. Notices by email are deemed delivered one (1) hour after transmission if sent during the recipient’s business hours, or otherwise at 9:00 a.m. (recipient’s time) the next business day. Any notice that is undeliverable will be deemed effective as of the first date that said notice was deemed undeliverable by the messenger or email server.

15 COMPLAINTS.

If you would like to contact us with a complaint, please contact Customer Support using one of the following methods:

Email Customer Support at support.paxos.com.

Write to Customer Support at:

Paxos

450 Lexington Ave,

Suite 3952

New York, NY 10163

16. MISCELLANEOUS.

16.1 Each Party is an independent contractor and not a partner or agent of the other. This Agreement will not be interpreted or construed as creating or evidencing any partnership, joint venture, or agency between the Parties or as imposing any partnership, joint venture, or agency obligations or liability upon either Party. Further, neither Party is authorized to, and will not, enter into or incur any agreement, contract, commitment, obligation or liability in the name of or otherwise on behalf of the other Party.

16.2 Paxos will not be liable or responsible to you, or be deemed to have defaulted under or breached this Agreement, for any delay or failure to perform any of its obligations under this Agreement as a result of any cause or condition beyond its reasonable control, including fire, explosion, earthquake, storm, flood, wind, drought, and act of God or the elements, pandemic, court order, act or delay or failure to act by any civil, military or other governmental authority, strike, lockout or other labor dispute, riot, insurrection, sabotage or war failure or unavailability of required equipment, supplies, goods, utilities, services or items to be provided by any third party, or any act, delay or failure to act by you, any Authorized User or any third party.

16.3 You may not assign this Agreement or any of its rights under this Agreement, directly, by operation of law or otherwise, without the prior written consent of Paxos. Subject to the foregoing, this Agreement will be fully binding upon, inure to the benefit of and be enforceable by the Parties and their respective successors and assigns.

16.4 No waiver or action made by us will be deemed a waiver of any subsequent default of the same provision of this Agreement. No failure or delay in exercising or enforcing any privilege, right, remedy, or power hereunder will be deemed a waiver of such provision by us. All waivers must be in writing.

16.5 Notwithstanding anything to the contrary, any provision of this Agreement that contemplates performance or observance subsequent to any termination or expiration of this Agreement and all provisions with respect to payment of fees, confidentiality, limitation on liabilities, and indemnification will survive any termination or expiration of this Agreement and continue in full force and effect.

16.6 This Agreement and any Schedules hereto (including any Pricing Supplement) constitutes the entire agreement and supersedes any and all prior agreements between Paxos and you with respect to the subject matter hereof; provided, however, to the extent any provision of Paxos’s terms of service for a Product or Service are not addressed in this Agreement, those terms will also apply to the extent applicable to you. Except as otherwise provided in this Agreement, no amendment, modification or waiver of any provision of this Agreement will be valid unless set forth in a written instrument signed by the Party to be bound thereby.

16.7 If any one or more of the provisions contained in this Agreement are, for any reason, held to be invalid, illegal, or unenforceable in any respect, such provision will be reformed only to the extent necessary to make it enforceable, and such invalidity, illegality or unenforceability will not affect any other provision of this Agreement, and this Agreement will be construed as if such invalid, illegal or unenforceable provision had never been contained in this Agreement.

16.8 All headings are solely for the convenience of reference and will not affect the meaning, construction or effect of this Agreement.

SCHEDULE 1: PAXOS GLOBAL TERMS AND CONDITIONS

Last Modified: December 15, 2025

In the event you are a customer of Paxos Global, this Schedule sets out the terms on which Paxos Global custodies your crypto assets. This Schedule will only apply to you in the event that you are a Customer of Paxos Global. This Schedule applies to each electronic form or contract executed by Customers who use Paxos Global’s custody services, unless expressly stipulated otherwise in this Agreement. If you have separately executed an agreement with Paxos Global regarding your use of custody Services (e.g. to access custody via an application programming interface), in the event of a conflict between such agreement and this Schedule, the terms of that other agreement will govern and control. Any capitalized term not defined in this Schedule will have the meaning ascribed to them in the Agreement.

1. Custody of Your Crypto Assets

1.1 Paxos Global will hold your crypto assets on trust for your benefit in a segregated, omnibus custody account as described below (the “Omnibus Custody Account”). Paxos Global will exercise the due care of a professional custodian for hire, in accordance with applicable industry standards, in safekeeping your crypto assets. These assets may be held in a foreign jurisdiction relative to where you are accessing the custody Services. Such laws and practices in a foreign jurisdiction may differ from Singapore’s, and such differences may affect your ability to recover assets, including potential delays in the recovery process.

1.2 The Omnibus Custody Account is a customers’ account that is segregated from our holdings of our proprietary crypto assets.

1.3 The crypto assets of other customers of Paxos Global will also be held on their behalf in the Omnibus Custody Account. Your crypto assets that we hold on your behalf will therefore be commingled with the crypto assets of other customers of Paxos Global, and may not be separately identifiable.

1.4 Paxos Global will maintain records of your crypto assets we hold for you in accordance with applicable law.

1.5 Paxos Global will be permitted, and is hereby authorized, but is not obliged, to, without any further Instructions or approval by you, notify you of notices, circulars, reports and announcements that require discretionary action, in each case, which Paxos Global has received in the course of holding your crypto assets for you. Paxos Global is not responsible for the form, accuracy or content of any such notice, circular, report, announcement, or other material that is not prepared by Paxos Global.

2. Scope of Responsibility

2.1 Paxos Global will only be responsible for the performance of those duties as are expressly set forth herein, and will have no implied duties or obligations whatsoever.

2.2 You understand and agree that (i) notwithstanding any delegation by Paxos Global of any of its obligations and duties to any affiliate or third party, your rights extend only to Paxos Global and, except as provided by law, do not extend to such affiliate or third party.

2.3 Paxos Global will not be responsible or liable for the acts, omissions, defaults or insolvency of any sub-custodian, delegate or other third party, or any Losses that may arise from or in connection with the acts, omissions, defaults or insolvency of any sub-custodian, delegate or other third party.

2.4 You understand and agree that Paxos Global’s performance is subject to the relevant local laws, regulations, decrees, orders and government acts.

2.5 You will be solely responsible for all filings, tax returns and reports on any transactions in respect of or relating to the crypto assets as may be required by any relevant authority, whether governmental or otherwise.

2.6 Paxos Global does not warrant or guarantee the form, authenticity, value or validity of any crypto asset received by Paxos Global. You represent and warrant that you have full power and authority to transfer the relevant crypto assets to Paxos Global and any crypto assets transferred to Paxos Global are free of any security interest, lien or other encumbrance, or any claims, pending, threatened or otherwise.

2.7 Paxos Global currently has no clear conflicts of interest. However, in accordance with Sections 5.2.5 and 5.2.6 of the Guidelines on the Provision of Consumer Protection Safeguards by Digital Payment Token Service Providers issued by MAS, Paxos will promptly update disclosures in the event of material changes to its business model, services, or sources of potential conflicts of interest, and will inform you in a timely manner.

3. Security Interest. The assets under custody will not be subject to any right, charge, security interest, lien or claim of any kind in favor of Paxos Global or any of its creditors. We will not loan, hypothecate, pledge or otherwise encumber any assets under our custody.

SCHEDULE 2: TRADING TERMS AND CONDITIONS

Last Modified: April 8, 2026

These Trading Terms and Conditions (hereinafter this “Trading Agreement” or “Trading Terms and Conditions”) govern the provision of and use of Paxos’s custody services (“Custody”), as well as the crypto asset trading platform and related order routing and execution services managed by Paxos (the “Trading Platform” and together with Custody, the “Custody and Trading Services”). As used herein, “Paxos,” “we,” “us” or “our” may refer to Paxos Trust Company, NA or any of its applicable affiliates. These terms apply to each electronic form or contract executed by any User or Customer who accesses or uses the Custody and Trading Services or any website managed by Paxos with domains ending in “itbit.com” and “paxos.com” (together, the “Paxos Platform”). As used in this Trading Agreement, a “Customer” refers to a registered customer of Paxos who may obtain access to use additional non-public elements of the Paxos Platform or the and a “User” refers to any non-registered user that accesses any public portion of the Paxos Platform.

To the extent there is a conflict between the Trading Agreement and the terms of any other agreement you (as a User or Customer, as applicable) may have with Paxos, including, for example, the General Terms and Conditions available at https://www.paxos.com/terms-and-conditions/general-terms-and-conditions (the “General Terms and Conditions,” the Terms and Conditions for Paxos Platform Services or other agreement to access the Paxos Platform via an application programming interface or over the counter trading services agreement (collectively, “Paxos Contractual Documentation”), the terms of this Trading Agreement will govern and control.

This Trading Agreement constitutes an addendum or supplement to your applicable Paxos Contractual Documentation and forms part of your agreement with Paxos.

Should you have any questions or comments regarding any Paxos services and products, please reach out to our customer support team by submitting a support ticket via support.paxos.com.

1. DEFINITIONS

1.1 “Account” means your account with the Trading Platform.

1.2 “Execution” means the completion of all or any portion of a Customer Order on an Execution Venue, resulting in a binding trade and the corresponding debits and credits to the relevant fiat and/or crypto asset balances in the applicable Account(s).

1.3 “ Execution Venue” means any marketplace or liquidity source at which Customer Orders may be executed, including liquidity venues operated by Paxos and any External Liquidity Provider.

1.4 “External Liquidity Provider” or “ELP” means any third-party trading venue, market maker, broker, dealer, exchange, or other source of buy or sell interest for crypto assets (which may include affiliates of Paxos), that Paxos designates from time to time as available for routing Customer Orders.

1.5 “Fill” means the quantity of a crypto asset, or portion of a Customer Order, that is executed at a particular price on an Execution Venue.

1.6 “Order” means any instruction submitted by you through the Trading Platform (including via any application programming interface made available by Paxos) to buy or sell a specified quantity of a supported crypto asset for fiat currency or another supported asse

1.6 “Order Routing System” means the automated system operated by Paxos that receives, evaluates, and routes Customer Orders, in whole or in part, to one or more Execution Venues, taking into account factors such as price, available liquidity, costs, speed, and the likelihood and quality of execution.

1.7 “Market Data” means the market value data compiled and published by Paxos on the Paxos Platform or otherwise, including bid prices, ask prices, trade prices and trading volume. Trading volume is calculated by adding together the notional values of trades executed on the Trading Platform.

2. CRYPTO ASSET RISKS.

2.1 As crypto assets are not legal tender and not backed by the government, they are subject to enhanced risks. These risks include (but are not limited to) the following:

1. accounts and value balances of crypto assets are not subject to Federal Deposit Insurance Corporation (“FDIC”) or Securities Investor Protection Corporation protections;

2. legislation and regulation (or lack thereof) of crypto assets or crypto trading platforms can change at any time which may adversely affect the use, transfer, trade, and/or value of crypto assets;

3. once executed, a crypto asset transaction may be irreversible, and accordingly, losses due to fraudulent or accidental transactions may not be recoverable;

4. some crypto asset transactions will be deemed to be made when recorded on a public ledger (e.g., a blockchain), which is not necessarily the date or time that the customer initiates the transaction;

5. the value of crypto assets may be derived from the continued willingness of market participants to trade fiat currency for crypto assets, which may result in the potential for permanent and total loss of value of a particular crypto asset should the market for crypto assets collapse;

6. there is no assurance that a person who accepts a crypto asset as a payment today will continue to do so in the future;

7. the volatility and unpredictability of the price of crypto assets relative to fiat currency may result in significant loss over a short period of time;

8. the value of a particular crypto asset may fall at any time, if, for example a new, better crypto asset is created or software developers make unexpected changes to how the crypto asset works;

9. as crypto assets are digital currency and therefore intangible, this means that like any other digital system, crypto assets are at risk of fraud, cyber attacks, and being affected by technical problems or difficulties which could result in you losing your crypto assets or delaying or preventing your ability to access or use them; and

10. any bond or trust account maintained by Paxos for the benefit of its customers may not be sufficient to cover all losses incurred by its customers.

For additional information regarding trading risks, please review the contents of Section 4 below.

2.2 TO THE FULLEST EXTENT PERMITTED BY LAW, PAXOS MAKES NO REPRESENTATION REGARDING THE LIKELIHOOD OR PROBABILITY THAT ANY ACTUAL OR PROPOSED TRADES ON THE TRADING PLATFORM WILL IN FACT ACHIEVE A PARTICULAR OUTCOME OR GOAL. PAST PERFORMANCE IS NOT A GUARANTEE OF FUTURE SUCCESS, AND IN FACT VOLATILITY MEANS THAT RETURNS IN ANY PERIOD MAY BE FAR ABOVE OR BELOW THOSE OF PREVIOUS PERIOD.

3. THE PAXOS PLATFORM.

3.1 Trading.

The Trading Platform allows Customers to trade supported crypto assets.When you submit an Order, Paxos receives that Order and, through its Order Routing System, may route it, in whole or in part, to one or more Execution Venues. Orders submitted by Customers may be executed (i) against other Customers on an order book operated by Paxos or (ii) against External Liquidity Providers or other Execution Venues, as determined by the Order Routing System. The Order Routing System is designed to seek “Best Execution” for Customer Orders, taking into account various factors such as price (including total consideration), available liquidity and market depth, expected speed of execution and settlement, likelihood and quality of execution and fill (including the risk of partial fills), the size and nature of the Order, and any explicit costs, fees or rebates associated with routing to a particular Execution Venue. Paxos generally acts in an agency capacity when arranging executions for Customers; however, you acknowledge and agree that in certain execution scenarios (including where Paxos receives a fill from an External Liquidity Provider or other execution venue and contemporaneously enters into a corresponding, offsetting transaction with you), Paxos may act as riskless principal with respect to the relevant transaction. When an Order is executed, ownership of the relevant assets is transferred between the applicable parties and is reflected by adjustments to Customers’ fiat currency and crypto asset balances on the Paxos Ledger. All trading activity on the Trading Platform is “off-chain” and is not broadcast to the applicable blockchain.

3.2 Instant Settlement; Allocation of Settlement Risk

3.2.1 Ledger Settlement Between You and Paxos. Upon Execution of your Order, and subject to this Section 3.2 and Sections 7 and 8, we will promptly: (a) credit your Account on the Paxos Ledger with the quantity of the purchased Supported Asset and debit the corresponding consideration (cash or other Supported Asset); or (b) in the case of a sale, credit the consideration and debit the sold Supported Asset from your Account, in each case in accordance with the terms of the Executed Order.

3.2.2 Finality as Between You and Paxos. As between you and Paxos, and except as expressly provided in Sections 3.2.3–3.2..5 and Sections 7.3–7.5, the credits and debits posted to your Account on the Paxos Ledger following Execution are final and unconditional. You are not responsible for, and will not bear, any failure by an External Liquidity Provider to settle with Paxos in respect of an Executed Order.

3.2.3 ELP and Venue Trade Cancellations. You acknowledge that Execution Venues, including External Liquidity Providers, may, under their own rules or applicable law or regulation, cancel, nullify, or adjust trades after initial confirmation (including clearly erroneous trades and busts). Where an Execution that has been reflected on the Paxos Ledger is subsequently cancelled or adjusted at the Execution Venue level, Paxos may, to the extent reasonably necessary to reflect that cancellation or adjustment, reverse or adjust the corresponding entries on your Account, in each case in accordance with Section 7.4 and any applicable ELP trade-cancellation policies. Paxos bears no liability for any decision by an External Liquidity Provider or other Execution Venue to cancel, nullify, or adjust a trade, except to the extent required by applicable law.

3.2.4 Force Majeure, Market Disruptions, and Legal Constraints. Our obligations under this Section 3.2 are subject to:

(a) any event or circumstance beyond our reasonable control as described in Section 16.2 of the General Terms (including system outages, market disruptions, network failures, or similar events) that materially impairs our ability to settle or reflect Executions on the Paxos Ledger in real time; and
(b) any applicable law, regulation, sanctions program, court order, directive of a governmental or supervisory authority, or similar legal constraint that, in our reasonable judgment, prohibits, restricts, or conditions the execution, settlement, holding, transfer, or withdrawal of a Supported Asset or fiat currency.

In such circumstances, we may suspend, delay, or sequence Executions, ledger updates, and withdrawals as we reasonably determine necessary and will not be liable for resulting delays or inability to complete instant settlement, except to the extent required by applicable law.

3.2.5 ELP and Third-Party Risk; No Third-Party Guarantee.

(a) Your rights in respect of any Executed Order are solely against Paxos under these Trading Terms and Conditions. You do not obtain any direct claim, right, or entitlement against any External Liquidity Provider or other Execution Venue.

(b) We do not guarantee, and expressly disclaim any guarantee of, the financial condition, solvency, performance, or continued operation of any External Liquidity Provider or other Execution Venue, or that any transaction will be filled or settled on any particular external rail within a specified time.

3.2.7 No Advisory or Fiduciary Relationship. This Section 3.2 describes a contractual allocation of settlement risk and how we reflect Executions on the Paxos Ledger. It does not constitute investment, tax, legal, or other advice, and does not create any advisory, fiduciary, trust, or similar relationship between you and Paxos. You remain solely responsible for evaluating the merits and risks of each transaction you enter into or instruct through the Trading Platform.

3.3 Supported Assets; Termination of Supported Assets.

3.3.1 Crypto assets available on the Trading Platform for trading, for custody with Paxos, and for withdrawal are those that Paxos designates as supported from time to time and publishes on its “Assets and Blockchains” page (currently available at https://docs.paxos.com/guides/developer/blockchains) or a successor location. . All supported assets and chains have been approved for customers of Paxos through pursuant to Paxos’ asset listing policy and chain expansion policy pursuant to Paxos’ operations under OCC supervision. As reflected in our applicable regulatory filings and product disclosures. U.S. dollar-denominated stablecoins supported on the Paxos Platform are available for Trading Platform credit as USD (or as otherwise described in the applicable stablecoin terms), for custody, and for withdrawal, subject in each case to applicable law and the relevant product-specific terms. 3.3.2 Your Account is intended solely for proper use of supported crypto assets as are designated by Paxos from time to time. Under no circumstances should you attempt to use your Account to store, send, request, or receive any assets other than supported crypto assets. Paxos assumes no responsibility in connection with any attempt to use your Account with crypto assets that we do not support. Paxos may choose to support new crypto assets in its sole discretion, subject to applicable law. Paxos will make reasonable efforts to provide prior notice to Customers of any decision made to support a new crypto asset. The decision to support a new crypto asset will depend on a number of factors, including regulatory approval and market demand. Paxos has not received listing fees or any other form of consideration to list any crypto asset.

3.3.3 Paxos may in its sole discretion terminate support for any particular crypto asset at any time. Paxos will make reasonable efforts to provide prior notice to Customers of any decision made to cease support of a crypto asset. If you do not sell or send such crypto asset off platform before Paxos terminates its support for such crypto asset, then Paxos may, in its discretion, remove such crypto asset from your Account and credit your Account the equivalent market value of another supported crypto asset or fiat currency minus any corresponding transaction costs.

4. DISCLAIMER; TRADING PLATFORM MARKET DATA.

4.1 The Trading Platform allows you to submit Orders to buy and sell supported crypto assets. Displayed prices and other Market Data (including bid, ask and last-trade information) are derived from quotes and executions at Execution Venues and are indicative only. They are not firm offers and may not reflect the prevailing market price when your Order is Executed. You understand and agree that: (a) there may be differences between displayed prices at the time you submit an Order and your eventual Execution price due to market movement, liquidity changes or latency between Execution Venues and the Trading Platform; (b) your Orders may be Executed at prices higher or lower than the last displayed or indicative price; and (c) Paxos does not currently apply any spread or markup to the executable prices it receives from External Liquidity Providers when routing your Orders. Paxos does not warrant that any Market Data or price reflects fair value or that any Order will be Executed at a particular price Trade with caution, and limit your trading to types of trades that are suitable for you and your risk tolerance.

For additional information regarding the difference between Oder types supported for trading, please consult the Paxos User Guide, available at https://help.paxos.com (the “Paxos User Guide”). Please also review the Paxos Contractual Documentation for additional risk factors applicable to you.

4.2 When you place Orders, Paxos may route them, in whole or in part, to one or more Execution Venues (including External Liquidity Providers) via the Order Routing System. In addition to Section 2 and Section 4.1, you understand and agree that:

• Execution / slippage risk. Orders may be filled at prices different from displayed prices due to market movement, liquidity changes, venue-specific pricing or latency. Paxos does not guarantee that any Order will be Executed, Executed in full, or Executed at any particular price.

• Partial and multi-venue fills. Orders may be partially filled or filled in multiple parts over time, including across several Execution Venues at different prices, so your average Execution price may differ from the last displayed or indicative price.

• ELP cancellation / bust risk. Execution Venues (including External Liquidity Providers) may cancel, adjust or “bust” trades under their own rules. To the extent permitted by Applicable Law, Paxos will pass through such actions and adjust your Account balances, and you bear the risk of any resulting loss or foregone profit.

• Venue availability and liquidity risk. Execution in particular assets, pairs or Order types may be limited, delayed or unavailable if Execution Venues experience outages, connectivity or operational failures, trading halts, delistings or cease to support an asset. Paxos may route to alternative venues, suspend or restrict trading, or cancel open Orders. During such periods you may be unable to place or Execute Orders, or may only be able to do so on less favorable terms, and you bear the risk of any resulting loss or missed opportunity.

4.3 Paxos compiles and publishes Market Data. You understand, acknowledge and agree that, due to technical and other restrictions, the crypto asset values displayed on the Trading Platform and in the Market Data may be delayed and therefore not reflect the current, live market value of such crypto asset. Nonetheless, you agree that the values displayed on the Trading Platform control your Account and your use of the Paxos Platform, including the Custody and Trading Services. You agree that we are not responsible for any adverse consequences that you may experience, or costs that you may incur, arising from any lapse, failure, outage or error in receiving Market Data from Paxos.

4.4 Paxos may share (including by sale or license) the Market Data with third parties. Such Market Data will not identify any particular Customer nor attribute trade(s) to a particular Customer by name, subject to the Paxos Contractual Documentation and Paxos’ Privacy Policy.

5. FDIC COVERAGE.

U.S. Dollar deposits may be held in our custody for your benefit in one or more omnibus accounts at banks located in the United States with the intention that they are eligible for FDIC “pass-through” deposit insurance, subject to applicable FDIC regulations. Our policies are designed to comply with the FDIC’s requirements for recognition of relationships entitled to pass-through insurance. Non-U.S. Dollar deposits held at a U.S. bank as well as U.S. dollar deposits held at banks outside of the U.S. may not be eligible for FDIC deposit insurance. Please review the Paxos Contractual Documentation for more information about our custody of your fiat assets as well as the FDIC Pass Through Insurance Disclosures available at https://www.paxos.com/terms-and-conditions/fdic-pass-through-insurance-disclosures (the “FDIC Pass Through Insurance Disclosures”).

6. OPENING YOUR ACCOUNT.

In order to use the Trading Platform, you must create an Account. Your Account will be used to store on your behalf various crypto asset amounts and fiat currency amounts as deposited and/or received by you. In order to create and maintain an Account on the Trading Platform, you must meet certain criteria prescribed by Paxos in its sole discretion.

6.1 Account Opening Procedures.

Paxos will, as part of its account opening process: (i) cross-check the names of users against compliance databases such as the United States Department of Treasury Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals list and other governmental watch lists; (ii) require users to verify and validate their identity and identification documents presented at onboarding; and (iii) not permit any activity on platform with incomplete account opening information.

6.2 Illegal Activities.

By your use of the Services, you represent that such use is legal in your local jurisdiction, and you agree that you will not use the Services if such use is prohibited or otherwise violates the laws of the country, state, province, or other jurisdiction in which you reside or of which you are a citizen.

7. YOUR TRADING PLATFORM ACCOUNT.

7.1 Funding Your Account.

7.1.1 After creating your Account with Paxos, you will be able to fund your Account with crypto assets and with fiat currency.

7.1.2 To fund the Account with crypto assets, you may transfer, for example, Bitcoin, from your account(s) with third-party crypto asset provider(s) (often known as “wallets”) into your Account operated by the Trading Platform. For example, to fund your Account with 100 Bitcoin, you would use the third-party Bitcoin software to transfer your own pre-existing 100 Bitcoin from your wallet to the Trading Platform’s Bitcoin address for the omnibus client account. The Trading Platform would then credit your Account with 100 Bitcoin on the Trading Platform’s ledger, and you would be able to trade those Bitcoin on the Trading Platform.

7.1.3 You may also fund your Account with fiat currency transferred from your account(s) with financial institutions. These would be transferred to the omnibus client account to be held on your behalf, and then the Trading Platform would credit your Account for that amount of fiat currency on the Trading Platform’s ledger. If a fiat currency deposit does not originate from a bank account owned by you, it will be rejected and returned immediately. Fiat currency sent before 3:00 p.m. EST will typically be credited to your Account on the same day or next business day. US dollar deposits may not be credited outside of normal banking hours. Transfer times are subject to bank holidays, the internal processes and jurisdiction of your bank, and the internal processes of our banks. In certain situations, fiat currency deposits may be delayed in connection with Downtime (as defined below).

7.1.4 When determining the amount you wish to transfer into your Account, you should be aware that you must deposit funds prior to placing an Order through the Trading Platform in an amount sufficient to satisfy your order (and associated fees, if any). All Orders on the Trading Platform must be pre-funded or they will not be accepted by Paxos or the Trading Platform.

7.1.5 You represent and warrant that all funds, including fiat currency and crypto assets, that you transfer to us do not represent the proceeds of any criminal, sanctioned, unlawful or fraudulent activity. You are not allowed to receive funds in your Account from a sender other than yourself, unless you receive specific prior approval otherwise from us. If we reasonably determine that you are not the owner of funds in your Account, we reserve the right to dispose of those funds in accordance with applicable law and in our sole discretion, which may include returning the funds to the originator or to a charity of our choosing.

7.1.6 We will make reasonable efforts to process electronic debits from and credits to your bank account, but we make no representations or warranties regarding the amount of time needed to complete processing.

7.2 Placing a Trade.

Prior to the placement of a trading Order on our Trading Platform, you will be required to review the following information: the type of Order (buy/sell, and market/limit/post-only Order), the amount of the Order, the price, and the estimated fee (if any) to be charged by the Trading Platform for executing the Order. If you place a large market Order, the Trading Platform may request that you re-confirm the Order because large market Orders may trade at a price substantially higher or lower than fair market value. For customers of Paxos, we will maintain records of your transaction history for a period of no less than seven (7) years.

7.3 Irreversible Trades.

Once an Order has been executed and the appropriate currencies and assets have been credited and debited from the Customers’ Accounts on the Trading Platform ledger, the transaction may not be reversible. For clarity, you acknowledge and agree that Paxos may cancel, reverse or adjust transactions and Account balances as described in Section 3.2.3 (including to reflect any cancellation, adjustment or “bust” by an Execution Venue, such as an External Liquidity Provider) and to correct any error.

7.4 Canceling Trades.

7.4.1 You have the right to cancel an open (i.e., unmatched) bid or offer to sell or buy crypto assets by initiating procedures through your Account online to effectuate closure of such open bid or offer. Such cancellation request may not be processed immediately by the Trading Platform, and accordingly, the open Order may be executed after the cancellation request for that Order has been submitted. If this occurs, the Order will not be canceled.

7.4.2 Absent mutual consent of parties involved, we reserve the right to cancel or nullify trades in the event that:

(i) the trade resulted from an erroneous print disseminated by the underlying market that is later canceled or corrected.;

(ii) the trade resulted from an identifiable interruption or malfunction of a of a Paxos execution, routing, or communication system that caused a quote or Order to execute in a manner inconsistent with the normal operation of the Trading Platform; or

(iii) the trade occurred at a price caused by any of the above, at a price 10% above or below fair market value, or at a price deemed clearly erroneous at Paxos’s sole discretion.

7.4.3 Trades may also be cancelled, adjusted or “busted” by Execution Venues (including External Liquidity Providers), and Paxos may cancel, reverse or adjust impacted transactions and Account balances as described in Section 4.4.3 and Section 7.3.

7.5 Withdrawing or Transferring Assets.

7.5.1 Customers may withdraw some or all of their crypto assets or fiat currency from their Accounts at any time, upon request to us, pursuant to these Trading Platform Terms and Conditions. Withdrawals may take up to three (3) days to complete, provided that larger withdrawals may take up to thirty (30) days to complete. Fiat currency will be transferred from the Customer’s Account with the Trading Platform to the bank account designated by, and owned by, the Customer. Please note that any withdrawal of crypto assets or fiat currency may be delayed as necessary to comply with applicable law and/or Paxos’s compliance program, including verification of customer identification, anti-money laundering procedures and as further detailed below.

7.5.2 Subject to the payment of any applicable fees as further specified herein and in the Paxos Contractual Documentation or Pricing Supplement (as defined below), you may transfer crypto assets that are supported by Paxos between your Account and (i) other Paxos Customers accounts (note if you are a Customer outside of the United States, you are not permitted to transfer USD to other Paxos Customer accounts) or (ii) external wallets held by third parties and not hosted by Paxos (“Crypto Transfers”). Insufficient payment of third-party network or other fees may cause a Crypto Transfer to remain in a pending state outside of Paxos’s control and Paxos is not responsible for delays or loss incurred as a result of an error in the initiation of the transaction.

7.5.3 Once a Crypto Transfer has been successfully completed, Paxos will recognize the Crypto Transfer on the relevant block-chain, if applicable. Prior to completion, Crypto Transfers may reflect a pending transaction status and will not be available to you for use via the Trading Platform or otherwise while the transaction is pending.

7.5.4 Among other compliance related activities related to Crypto Transfers, Paxos may conduct blockchain monitoring with respect to originating or recipient external third-party wallet addresses. If any such third-party wallet address is flagged by Paxos’s blockchain monitoring service, Paxos will perform a manual compliance review of such address (a “Manual Compliance Review”). During the period of any Manual Compliance Review, the relevant crypto assets will not be available for use. Following Paxos’s successful completion of a Manual Compliance Review, the impacted crypto assets will be promptly made available for a Crypto Transfer.

7.5.5 Paxos reserves the right to reject any Crypto Transfer that it deems, in its sole discretion, poses an excessive risk, or as required by any court or applicable law. Paxos will not complete any Crypto Transfer if the crypto assets are not supported by the Trading Platform and available at the time of the Crypto Transfer.

7.5.6 YOU ARE REQUIRED TO AND ARE RESPONSIBLE FOR VERIFYING THE ACCURACY AND COMPLETENESS OF ALL TRANSACTION INFORMATION SUBMITTED IN RESPECT OF A CRYPTO TRANSFER (INCLUDING, BUT NOT LIMITED TO, THE APPLICABLE DESTINATION ADDRESS AND THE AMOUNT AND TYPE OF CRYPTO ASSETS). YOU UNDERSTAND AND AGREE THAT PAXOS BEARS NO LIABILITY OR RESPONSIBILITY IN THE EVENT THAT (I) YOU PROVIDE INCORRECT TRANSACTION INFORMATION, (II) YOU ATTEMPT TO INITIATE A CRYPTO TRANSFER FOR CRYPTO ASSETS THAT ARE NOT SUPPORTED BY PAXOS AND/OR THE DESTINATION ADDRESS, OR (III) PAXOS REJECTS A CRYPTO TRANSFER. YOU FURTHER UNDERSTAND AND AGREE THAT CRYPTO TRANSFERS CANNOT BE REVERSED ONCE THEY HAVE BEEN BROADCAST TO THE RELEVANT BLOCKCHAIN NETWORK OR COMMUNICATED TO THE TRADING PLATFORM (EVEN WHEN IN A PENDING STATE). PAXOS DOES NOT CONTROL THE BLOCKCHAIN NETWORK AND MAKES NO GUARANTEES THAT ANY CRYPTO TRANSFER WILL BE CONFIRMED BY THE APPLICABLE NETWORK

8. SERVICE INTERRUPTIONS.

From time to time due to technological factors, scheduled software updates and the performance of other maintenance, as well as factors beyond or within our control, the Paxos Platform (or portions thereof) may be temporarily interrupted (“Downtime”). Information on scheduled maintenance windows can be found on the Paxos Platform. Open Orders and/or trades will be held during Downtime and processed normally following Downtime. Following any Downtime, market conditions and prices may differ significantly from conditions and prices prior to such Downtime. Paxos reserves the right, at its sole discretion, to temporarily or permanently suspend, limit, or otherwise restrict access to services on the Paxos Platform in the event that any crypto assets offered on the platform are experiencing issues, including but not limited to depegging events, security breaches, network disruptions, liquidity shortages, or any other circumstances that may compromise the integrity, stability, or security of the assets or in the event that one or more Execution Venues (including External Liquidity Providers) supporting those assets experience outages, trading halts, connectivity issues, operational failures, delistings, or otherwise cease to support an asset or pair. In such circumstances, Orders in affected assets may be delayed, partially filled, or unfilled even if the Paxos Platform itself remains operational. Paxos will make reasonable efforts to notify users of such suspension, but may act without prior notice if deemed necessary to protect the interests of the Paxos Platform.

9. FORKS.

9.1 You understand, acknowledge and agree that the underlying operating rules of certain crypto assets may change from time to time in such a way as to result in more than one related version of an existing crypto asset (each instance of any such change, a “Fork”). If a Fork occurs, it will result in the creation of a new crypto asset (the “New Forked Asset”) related to an existing crypto asset (the “Prior Asset”). As a result, we will hold an amount of the New Forked Asset proportional to our holdings of the Prior Asset. You further understand, acknowledge and agree that each Fork may materially affect the value, function, and/or name, of the original crypto asset that we custody on your behalf or you hold in your Account, and that the New Forked Asset may have minimal or no value.

9.2 WE HAVE NO CONTROL OVER, NOR DO WE HAVE THE ABILITY TO INFLUENCE, THE CREATION OR IMPLEMENTATION OF A FORK OR OF THE NEW FORKED CURRENCY. WE CAN PROVIDE NO ASSURANCES ABOUT THE SAFETY, FUNCTIONALITY OR SUPPLY OF ANY CRYPTO ASSET, INCLUDING BOTH THE NEW FORKED ASSET AND THE PRIOR ASSET. YOU UNDERSTAND, ACKNOWLEDGE AND AGREE THAT WE ASSUME NO LIABILITY RELATING TO ANY CHANGE IN THE VALUE OF ANY CRYPTO ASSET (WHETHER OR NOT RESULTING FROM A FORK).

9.3 If a Fork occurs, you understand, acknowledge and agree that we may temporarily suspend the operations of the Paxos Platform (with or without advance notice to you) while we determine, in our sole discretion, whether to support either or both of the New Forked Asset and the Prior Asset. In addition, while we will endeavor to make this determination expeditiously, we have the right to continue the suspension of the Paxos Platform for such length of time as we deem prudent in order to make such determination. You understand, acknowledge and agree that the Trading Platform is unlikely to support trading in all New Forked Assets.

9.4 You understand, acknowledge and agree that you have no right, claim or privilege in, or with respect to, any New Forked Asset. If we do not support a New Forked Asset, you may not be able to withdraw the New Forked Asset from the Paxos Platform promptly or at all; you may not be able to trade the New Forked Asset on our platform for fiat currency or other crypto assets; and you may lose any value associated with such New Forked Asset. If we determine not to support a New Forked Asset, we may, in our sole discretion, (i) obtain and retain the New Forked Asset as property belonging to us; or (ii) make the New Forked Asset available to you on a one-time basis, based on your holding of the Prior Asset at the time of the Fork, subject to the withholding and retention by us of an amount reasonably calculated to fairly compensate us for the cost of making such New Forked Asset available and subject to our withdrawal procedures. We will notify you only if we elect to permit a one-time withdrawal pursuant to (ii) above.

9.5 You understand, acknowledge and agree that if you or a third party deposits an amount of a New Forked Asset (or any other crypto asset) that the Trading Platform does not support into our omnibus client account for crypto assets, we have the right to and will account for any such unsupported crypto asset (including unsupported New Forked Assets) as belonging to us. We have, and assume, no obligation or duty to return the crypto asset transmitted to one of our accounts. If we determine, in our sole and absolute discretion, to return the unsupported crypto asset, we retain the right to charge transaction and/or other fees in connection with the transfer of the unsupported crypto asset off of the Paxos Platform.

10. AIRDROPS.

You understand, acknowledge and agree that in the event that a third party attempts to or does distribute (sometimes called “airdropping” or “bootstrapping”) a crypto asset (whether or not supported by the Trading Platform) to crypto asset addresses, we will treat such airdropped crypto asset as we would treat all unsupported crypto assets, as set forth above. You further agree and understand that airdropped crypto assets do not create a relationship between us and the transferor, or sender, and/or the related network that created the airdropped crypto asset; and, further that we are not subject to any obligation as it may relate to the transferor and/or the related network.

11. FEES.

11.1 Trading Fees.

An overview of our fees for the Trading Platform (the “Trading Fee”) is set forth in the Pricing Supplement provided to you by Paxos separate from this Trading Agreement, which is incorporated herein by reference (the “Pricing Supplement”). The Trading Fee is added to the purchase price for buyers and subtracted from the sale price for sellers.

11.2 Banking Fees.

We charge transaction fees for deposits into Paxos’s bank accounts and withdrawals from Paxos’s bank accounts to customer bank accounts (collectively, “Banking Fees”). These fees are deducted from the amount transferred. Our deposit and withdrawal fees are set forth in the Paxos User Guide or the Pricing Supplement, as applicable. Among other fees, Paxos passes through the market “network” fee, or an approximation thereof, to the customer when transferring crypto assets to an external wallet address.

In addition to the fees described above, your financial institution and/or the provider of your crypto asset wallet may charge transaction and other fees related to the transfer of funds to your Account.

11.3 Crypto Transfer Fees.

With respect to on-chain activity for PAXG, Paxos may charge the fees set forth in the Paxos User Guide or the Pricing Supplement, as applicable. With respect to withdrawals of supported crypto assets, including PAXG, you will be subject to the applicable market network fees and other fees as described in the Paxos User Guide or Pricing Supplement, as applicable.

11.4 Additional Fees for Certain Accounts.

Due to the cost of maintaining and supporting your Account and subject to applicable law, you will incur a monthly charge of two U.S. Dollars (US $2.00) (or equivalent in other fiat or crypto asset) if you maintain a non-zero balance (or equivalent in other fiat or crypto asset) and there has been no trading activity on the Account for twelve months or longer. Such fee will be auto-debited from your account on a periodic basis in USD or the then current crypto asset equivalent.

For more information on fees for Custody Accounts, please reach out to [email protected] or consult the Pricing Supplement (to the extent applicable).

11.5 Right to Change Fees and Fee Structure.

We reserve the right to change or modify our fee structure or increase any of our fees at any time and from time to time. Any such changes, modifications or increases will be effective upon posting such changes, modifications or increases on the Paxos Platform, in the Paxos User Guide or updated Pricing Supplement. Your first use of your Account following the posting on the Paxos Platform of any changes to the fees will constitute your acceptance of such changes. If you do not agree to the posted changes, you may close your Account as provided in the Paxos Contractual Documentation.

12. Affiliated Party Transactions.

12.1 From time to time we or our Affiliates (together, “Affiliated Parties”) may operate Execution Venues, and/or act as Market Makers or other liquidity providers on those venues in connection with Customer Orders. You acknowledge and agree that your Orders may be routed for Execution to, and may be Executed against, such Affiliated Parties; provided, however, that no Affiliated Party acting in any trading capacity will receive earlier, different or otherwise preferential access to information about Customer Orders, bids or offers than is available to other API‑integrated Customers or participants on the relevant Execution Venue, and that the Order Routing System evaluates and routes Customer Orders among Execution Venues only (including any such venues or External Liquidity Providers operated by, or involving, an Affiliated Party) based on the factors described in Section 3.1 and is not designed to explicitly preference any Affiliated Party or its venues over other Execution Venues in a manner that is inconsistent with those factors.

13. OTC.

13.1 This OTC Section will only apply to you if you plan to invest in or otherwise acquire crypto assets supported for trading by Paxos and desire to enter into Over-the-Counter (“OTC”) crypto asset purchase and sale transactions (“OTC Transactions”) without being subject to the rules of any established central limit order book exchange such as the Trading Platform. On a periodic basis, Paxos will broker, on a reasonable efforts basis, one or more OTC Transactions between you and other Customers (each an “OTC Counterparty”). Every OTC Counterparty must be a Customer of Paxos. All OTC Counterparties are subject to the AML, KYC and similar requirements of the Paxos entity to which they have onboarded.

13.2 Quotes.

13.2.1 You agree that this Section governs all (i) submissions of quotes (“Quotes”) by you to buy and/or sell crypto assets to the OTC trading desk operated by Paxos (“OTC Desk”); and (ii) responses by you to Quotes from other Customers to the OTC Desk. Paxos will treat a Quote as a request provided to Paxos for Paxos, through its OTC Desk, to locate a counterparty for an OTC Transaction in a supported crypto asset. OTC services include instant message conversations, oral communications, and other methods of communications used by Paxos to receive Quotes, request responses to Quotes, negotiate OTC Transactions between you and OTC Counterparties, execute and confirm OTC Transactions, and settle OTC Transactions, among other things. Paxos will communicate with each potential counterparty to an OTC Transaction and act as an agent of each counterparty in negotiating the OTC Transaction. You agree that Paxos may, in its sole and absolute discretion, determine whether to process or decline to process a Quote or any response to a Quote.

13.2.2 In response to a Quote, Paxos may request Quotes from one or more potential OTC Counterparties. We will always be truthful to you in any statement that we make by using clear and unambiguous language regarding pricing.

13.3 Negotiation and Execution.

Each OTC Counterparty will, on an anonymous basis, agree upon the specific terms of any OTC Transaction through the OTC Desk, by communicating directly with Paxos as agent. OTC Counterparties may, with Paxos’ consent to communication method, negotiate OTC Transactions using electronic, written, or oral communications with Paxos; however as set out below in this Section, execution may only occur by written email communication. As soon as practicable following Paxos believing that all OTC Counterparties have indicated to Paxos that they agree to the terms of a proposed OTC Transaction (including asset, quantity, price, settlement time, and transaction fees), Paxos will provide to the OTC Counterparties an email setting out those terms (the “Confirmation Email”) and once all OTC Counterparties have confirmed those terms by sending to Paxos a written email response to the Confirmation Email, the OTC Transaction becomes binding and final (the “OTC Execution”). An OTC Transaction for which OTC Execution has occurred is an “Executed OTC Transaction” and may not be unwound unless all OTC Counterparties agree in writing otherwise. However, if Paxos determines that a Quote communicated by it to an OTC Counterparty contained an obvious error with respect to the price or amount of crypto assets set forth in that Quote, Paxos will have the right to cancel the Executed OTC Transaction by delivering notice of the cancellation to both OTC Counterparties at any time prior to OTC Settlement (as defined below). In the absence of such an obvious error, the terms of a Confirmation Email confirmed by email response by all OTC Counterparties will be conclusive. You agree that, for the avoidance of doubt, Paxos may, in its sole and absolute discretion, accept statements similar or analogous to the following as your indication of agreement to the terms of a proposed OTC Transaction: “done,” “I buy,” “bought,” “I sell,” or “sold”; however, as set out above, the proposed OTC Transaction does not become binding and final, i.e., an OTC Execution, until all OTC Counterparties have confirmed the terms of the proposed OTC Transaction by sending to Paxos a written email response to the Confirmation Email. Upon OTC Execution, the terms of the Executed OTC Transaction will constitute a binding contract between you and the other relevant OTC Counterparty. For the avoidance of doubt, Paxos has sole and absolute discretion whether to accept or reject any Quotes or other Orders.

13.4 Pre­-Funded Trading.

Except for OTC Transactions where you are afforded delayed settlement terms pursuant to this Trading Agreement, you agree that you must deposit with Paxos the full amount of relevant crypto assets and/or fiat currency before OTC Execution. If OTC Execution occurs prior to noon Eastern Standard Time on a Business Day, on that Business Day, and if OTC Execution occurs at or after noon Eastern Standard Time on a Business Day, on or before the next following Business Day, Paxos will settle an Executed OTC Transaction by delivering to each OTC Counterparty the crypto assets and/or fiat currencies owed to that OTC Counterparty under the Executed OTC Transaction to that OTC Counterparty’s crypto asset wallet and/or fiat wallet at Paxos (“OTC Settlement”). You will not withdraw, attempt to withdraw, transfer, alienate or provide a lien to any third party on any crypto asset or fiat currency held by Paxos to satisfy your obligation under any Executed OTC Transaction. For the purposes of this Section, “Business Day” will mean times between 9:00:00 am and 5:00:00 pm Eastern Standard Time Monday through Friday, excluding U.S. Federal holidays or days when Paxos’ New York City office is closed due to weather or other emergencies. Paxos will not be responsible for any failure to settle in accordance with the timing set out above as a result of technological failures such as the internet going down and being unavailable.

13.5 Post­-Execution Funding and Delayed Settlement.

A prospective OTC Counterparty may make a request to Paxos that a proposed OTC Transaction be subject to post-OTC ­Execution funding pursuant to this paragraph. With Paxos’ written or verbal consent, made in its sole and absolute discretion, funding of such OTC Transaction by one or more OTC Counterparties and OTC Settlement may be delayed for up to a further Business Day after OTC Execution. The timing of post-­OTC Execution funding and OTC Settlement will be a material term of a proposed OTC Transaction that both OTC Counterparties must agree to through the OTC Desk prior to OTC Execution. Any OTC Counterparty afforded delayed settlement must deposit in their Paxos wallet(s) assets sufficient to satisfy their obligations under an Executed OTC Transaction within the time period specified at OTC Execution. You agree not to withdraw, transfer, alienate, or provide a lien to any third party on any assets held by Paxos to satisfy a delayed settlement OTC Transaction. For the avoidance of doubt, Paxos, in its sole and absolute discretion, may permit only one OTC Counterparty to an OTC Transaction to delay funding; in such event, the OTC Counterparty not afforded delayed funding must pre­fund the OTC Transaction pursuant to the foregoing paragraph.

13.6 No Name Disclosure.

Trading through the OTC Desk will be anonymous, and Paxos has policies and procedures reasonably designed to prevent the disclosure to any other OTC Counterparty of the identity of one OTC Counterparty (or any person acting on its behalf) submitting or responding to a Quote. However, if ever Paxos or an affiliate of Paxos is the OTC Counterparty in an OTC Transaction, disclosure that Paxos is acting as a principal in the OTC Transaction will be made to you.

13.7 Default by Your OTC Counterparty.

Paxos will make commercially reasonable attempts to contact all OTC Counterparties to an Executed OTC Transaction to effect OTC Settlement. In the event that your OTC Counterparty fails to settle an Executed OTC Transaction, Paxos may stand in as your OTC Counterparty with the same terms as agreed between you and the defaulting OTC Counterparty, with the exception that Paxos will have an additional Business Day to settle any such OTC Transaction. When this occurs and Paxos is acting as principal in an OTC Transaction, disclosure that Paxos is acting as principal will be made to you.

13.8 Default by You.

If you fail to effect OTC Settlement of an Executed OTC Transaction by, among other things, failing to consent to the transfer of assets by Paxos, you will be considered in default (“Default”). You hereby grant Paxos a secured interest pursuant to the New York Uniform Commercial Code in all of your assets, including fiat currency and crypto assets, held by Paxos up to the value of any Executed OTC Transactions on which you are in Default. You also hereby grant to Paxos a security interest pursuant to the New York Uniform Commercial Code in any assets held by Paxos to the extent of any liability you have to Paxos due to a Default.

13.9 Effect of Default.

In the event you are in Default, Paxos may in its sole and absolute discretion:

1. stand in as the counterparty on your behalf and settle such Executed OTC Transaction with the OTC Counterparty;

2. cancel and/or terminate all of your Quotes and responses to Quotes, and liquidate, close out, net, cancel and/or terminate pending OTC Transactions; liquidate any and all of your assets and positions held at Paxos to cover any losses incurred by the non­defaulting OTC Counterparty as a result of your Default, and in connection with any such liquidation, Paxos expressly disclaims responsibility for any loss incurred in the liquidation of your assets and positions held at Paxos or due to price slippage, market timing and similar matters;

3. refuse to accept from you Quotes or responses to Quotes or require all future OTC Transactions involving you be instantaneously settled notwithstanding any other agreements; and/or

4. terminate, with or without prior notice, your Account, this Trading Agreement and/or other Paxos Contractual Documentation you have in place.

13.10 Damages.

In the event that an Executed OTC Transaction is not settled because of your Default, you will be liable to Paxos for losses incurred as a result of the failure to settle the Executed OTC Transaction; provided, however, that under no circumstances will you or any other defaulting OTC Counterparty be liable to Paxos or the non­-defaulting OTC Counterparty for indirect, special, punitive, or incidental losses or damages of any character. Any net proceeds obtained from the liquidation of assets held by Paxos will be applied to discharge any and all of your obligations to Paxos.

13.11 OTC Representations and Warranties.

13.11.1 You acknowledge and agree that when entering OTC Transactions, you will be transacting for your own account, and in an arm’s-­length role in relation to Paxos.

13.11.2 You acknowledge and agree that Paxos will not generally be exercising discretionary trading authority on your behalf or providing any advisory services to you; however when Paxos is given any discretion by you, you will be made aware of how that discretion will be exercised and Paxos will exercise that discretion reasonably, fairly, and in a way that is not designed or intended to disadvantage you. You acknowledge and agree that Paxos will work on a reasonable efforts basis to broker OTC Transactions based on parameters (including quantity and price) provided by you. You also acknowledge and agree that while Paxos will attempt to broker your OTC Transactions, there may be occasions when Paxos will be the principal to an OTC Transaction with you and, in such circumstances, disclosure that Paxos is acting as principal will be made to you. Paxos does not operate a Principal Trading Desk and does not currently have any intention to do so; any principal trading by Paxos will be for the sole purpose of providing liquidity and satisfying Customer goals, and will not be intended to earn a profit for Paxos. Paxos will not execute for its own account or benefit an OTC Transaction in a crypto asset while Paxos is in possession of specific confidential information regarding the trading interest of our Customers in such crypto asset or in a manner that is designed or intended to disadvantage you.

13.11.2 If this OTC Section is applicable to you, Paxos grants to you a limited, non­exclusive, non­transferable, non­assignable, right to access and use the OTC Desk exclusively for the purposes described in this OTC Section. All copyright, trademark, trade secret, and other intellectual property rights in, to, and related to the OTC Desk or any of its components (including feedback or suggestions provided by you regarding Paxos’ business), or any data submitted to or generated by Paxos, are the sole and exclusive property of Paxos, and you will not obtain any such rights, except as explicitly specified herein.

13.11.3 You agree that it is your sole responsibility to control, monitor, and restrict the methods you use to access communication to Paxos at its OTC Desk (“Access Methods”), including without limitation, all passwords and security devices. You will be bound by all instructions communicated to the OTC Desk using your Access Methods and usual communication methods, and Paxos will have no obligation to verify whether any such instruction has been duly authorized. If you learn that your Access Methods and usual communication methods may have been compromised, you will immediately notify Paxos pursuant to the notice provisions of this User Agreement. You will be responsible for any instructions sent using your Access Methods and usual communication methods until you notify Paxos and Paxos has disabled the compromised Access Methods or agreed not to accept that usual communication method.

13.11.4 You agree that you are solely responsible for (a) any computer systems, applications, communications software, telecommunications equipment, and other equipment and software (“Equipment”) used by you to access or communicate to the OTC Services; and (b) any telecommunications services, Internet service, or other communications services used by you to connect to or communicate to the OTC Desk (“Connectivity”). Any Paxos assistance with your Equipment or Connectivity is provided without warranty as described in the Paxos Contractual Documentation.

13.11.5 Paxos reserves the right, at any time, with or without cause or prior notice, to limit, suspend, or terminate all or part of the OTC Services or your access to the OTC Desk. For the avoidance of doubt, Paxos will not have any obligation to send any price Quote received by the OTC Desk to prospective OTC Counterparties. You understand that you are solely responsible for maintaining any alternative arrangements that may be needed or desirable if any or all of the OTC Services becomes unavailable or disrupted.

SCHEDULE 3: ANTI-MONEY LAUNDERING/KNOW YOUR CUSTOMER (AML/KYC) DISCLOSURE

Last Modified: December 15, 2025

By agreeing to the terms of any agreement you may have with Paxos Trust Company, NA, a national banking association organized under the laws of the United States and regulated by the Office of the Comptroller of the Currency (“Paxos Trust”) or its applicable affiliates, including Paxos Global PTE LTD (“Paxos Global”), Paxos Digital Singapore Pte. Ltd. (“Paxos Digital”), Paxos Issuance Europe Oy (“PIE”) and Bruntal S.A. (dba Paxos Uruguay) (“PUY”), (collectively, “Paxos,” “we,” “us” or “our”), including, for example the General Terms and Conditions available at https://www.paxos.com/terms-and-conditions/general-terms-and-conditions and the Terms and Conditions for Paxos Platform Services (collectively, “Paxos Contractual Documentation”), Customers also acknowledge that Paxos has implemented the Anti-Money Laundering (“AML”) / Know Your Customer (“KYC”) program as described in this disclosure. All capitalized terms not defined herein will have the meaning ascribed to them in the Paxos Contractual Documentation, as applicable.

Paxos protects itself from involvement in money laundering or suspicious activity by the following:

• A system of internal controls designed to assure ongoing AML compliance;

• Independent testing of AML compliance through an annual, independent AML audit;

• Designation of a Compliance Officer for managing AML Compliance; and

• AML training for all employees.

INTERNAL CONTROLS

Paxos has established a set of AML/KYC policies and procedures which are approved by Paxos’s Board. The approved policies will be provided to all employees. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.

Paxos has developed and implemented internal controls for the purpose of ensuring that all of its operations comply with AML requirements and that all required reports are made on a timely basis.

INDEPENDENT TESTING

Paxos’s AML program will be subject to independent testing through an annual, independent AML audit. The audit will be conducted by an independent third party with working knowledge of AML requirements, or by Paxos personnel with working knowledge of AML requirements, none of whom work for or with the Compliance Officer. The Compliance Officer will develop corrective action plans for all issues that are raised in the audit, supervise the remediation performed, and report all updates to the corrective action plans to Paxos’s senior management.

COMPLIANCE OFFICER

TRAINING

All of the officers and employees of Paxos are required to receive AML training at least annually. Paxos will track the training progress of all employees and maintain documentation of each employee, the date of the AML training as well as a description of such training. New employees will receive appropriate AML training within thirty (30) days of their hire date. Training for all employees will include not only the legal elements of AML laws and regulations but will also cover job specific applications of these laws. Ongoing training will be provided and updated regularly to reflect current developments and changes to laws and regulations.

CUSTOMER IDENTIFICATION PROGRAM

Paxos has developed and implemented a Customer Identification Program (“CIP”) that establishes procedures for verifying the identity of each customer that opens a new account on Paxos’s Platform. It is Paxos’s policy to ensure that it has reasonably identified each User and/or Customer who uses the Paxos Platform.

ACCOUNT OPENING PROCEDURES

Additionally, Paxos will, as part of its account opening process: (i) cross-check the names of users against compliance databases such as the United States Department of Treasury Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals list and other governmental watch lists; (ii) require users to verify and validate their identity and identification documents presented at onboarding; and (iii) not permit any activity on Paxos Platform with incomplete account opening information.

IDENTITY VERIFICATION

Individual

• Individual name

• Date of birth

• Residential address

• Identification number (e.g., social security number)

• Acceptable and valid government-issued identification document (e.g., drivers license, passport, national identification card)

• details regarding the customer's activities

• the nature and scope of their business

• financial status

• the purpose of the usage of the service, and the origin of the funds;

• whether the individual is a politically exposed person (PEP), a family member of a PEP, or a known close associate/business partner of a PEP.

Institutions

• Institution name

• The address of the institution’s principal place of business and, if different, the institution’s mailing/registered address

• Identification number of the institution (e.g., employer identification number)

• Name of institution’s representative/user for the account

• For institutions, Paxos will collect the identifying information with respect to each beneficial owner and will use risk-based procedures to verify the identity of such beneficial owners, including:

  • Acceptable and valid government-issued identification document (e.g., drivers license, passport, national identification card) for each beneficial owner; and

  • Proof of residency (e.g., utility bills, government issued correspondence, documentation issued by recognized financial institutions).

• Customer due diligence procedures will include additional information regarding the institution including but not limited to the following:

  • A description of the institution’s business, including products and services, main customer types, and geographies served;

  • Purpose of account; and

  • Source of funds.

TRANSACTION MONITORING

Paxos maintains a transaction monitoring program reasonably designed for the purpose of monitoring transactions for potential AML violations and suspicious activity reporting. Transactions that are unusual will be carefully reviewed to determine if it appears to be involved with money laundering, tax evasion, terrorist financing, or other illegal or criminal activity.

SCHEDULE 4: MARKET MANIPULATION PROTECTION

Last Modified: December 15, 2025

By agreeing to the terms of any agreement you may have with Paxos Trust Company, NA, a national banking association organized under the laws of the United States and regulated by the Office of the Comptroller of the Currency(“Paxos Trust”) or its applicable affiliates, including Paxos Global PTE LTD (“Paxos Global”), Paxos Digital Singapore Pte. Ltd. (“Paxos Digital”), Paxos Issuance Europe Oy (“PIE”) and Bruntal S.A. (dba Paxos Uruguay) (“PUY”), (collectively, “Paxos,” “we,” “us” or “our”), including, for example, the General Terms and Conditions available at https://www.paxos.com/terms-and-conditions/general-terms-and-conditions and/or the Terms and Conditions for Paxos Platform Services (collectively, “Paxos Contractual Documentation”), Customers also agree to abide by the following marketplace rules for the crypto asset trading platform managed by Paxos and operating under the trade name itBit (the “Trading Platform” and these “Marketplace Rules”). All capitalized terms not defined herein will have the meaning ascribed to them in the Paxos Contractual Documentation, as applicable.

1. General Fraudulent Acts. Customers will not engage in any fraudulent act or engage or attempt to engage in any scheme to defraud, deceive or trick users of the Trading Platform, employees of the Trading Platform or the underlying software of the Trading Platform.

2. Fictitious Transactions. Customers will not place any order with no intention to execute.

3. Market Manipulation. Customers will not engage in any disruptive trading or manipulation of the Trading Platform. This includes orders placed for the purpose of generating volatility or creating a condition in which prices do not or will not reflect bona fide supply and demand.

4. Violation of Applicable Laws and Regulations. Customers will not use the Trading Platform in a way that violates the laws and regulations applicable to Paxos and the Trading Platform.

5. Misstatements. Users and Customers will not make any misstatement of material fact to Paxos.

6. Activities That Bring Disrepute upon Paxos. Users and Customers will not access the Paxos Platform or use the Trading Platform or any Trading and Custody Services in any way that could be expected to bring disrepute upon Paxos.

7. Disclosing Orders. Customers will not disclose to any person, including, but not limited to, another market participant, any order placed by Customer or any related party or any order placed by another person, including, but not limited to, another Customer.

8. Pre-Arranged Trades. Members will not place any order on the Trading Platform that has been pre-arranged (or discussed with another Customer prior to being placed on the Trading Platform) for the purpose of creating an artificial price, fictitious trade, or other disruptive, fraudulent, noncompetitive, or unfair impact on the Trading Platform.

9. Wash Trades. Customers, through one or more accounts owned by Customer or any related party, will not place or accept buy and sell orders at the same price, where Customer or any related party knows that the purpose of the orders is to artificially create the appearance of activity (transactions commonly known as wash trades).

10. Money Passes. Customers will not prearrange the execution of transactions on the Trading Platform for the purpose of passing money between accounts.

11. Accommodation Trading. Customers will not enter into transactions on the Trading Platform for the purpose of assisting another person to engage in transactions that are in violation of these Marketplace Rules or any applicable laws and regulations.

12. Front-Running. Customers will not take a position based upon non-public information regarding an impending transaction by another Customer.

13. Disruptive Practices. Customers will not engage in any trading, practice or conduct on the Trading Platform that: (i) demonstrates intentional or reckless disregard for the orderly execution of transactions or (ii) involves spoofing (bidding or offering with the intent to cancel the bid or offer before execution).

14. Customers will not engage in any conduct that threatens, harasses, coerces, intimidates or otherwise attempts to improperly influence another Customer or any other person.

MARKETPLACE RULES VIOLATIONS

If we suspect that you have violated these Marketplace Rules, we will give you written notice of such suspected violation, including the general nature of the activity observed. You will have the right to submit within ten (10) calendar days from the date of notification, a written explanation to us as to why no disciplinary action should be taken. You agree and understand that you are obligated to respond in writing to any queries from us within the time period for response set forth therein and to furnish documents and other information in connection with any investigation initiated under these Marketplace Rules. Following the conclusion of the investigation, we will make a determination, in our sole discretion, as to whether your conduct violated these Marketplace Rules. If we determine that you have violated these Marketplace Rules, in addition to terminating your Account, we may notify our regulators, self-regulatory organizations, including any organizations with which we share Market Data, and law enforcement of the activity, including your identity, and you agree to the same.

SCHEDULE 5: FDIC PASS THROUGH INSURANCE DISCLOSURES

Last Modified: December 15, 2025

Certain conditions must be satisfied for pass–through deposit insurance coverage to apply to fiat currency. The underlying fiat currency may be eligible for pass-through insurance; however, no crypto asset is insured or guaranteed by the FDIC.

The primary depository account that holds fiat cash is protected by FDIC insurance up to $250,000 for each account ownership category. Paxos Trust Company, NA and its applicable affiliates (“Paxos”) maintains FDIC-insured deposits for stablecoins at the following depositories:

• BMO Bank National Association (FDIC Certificate #16571)

• BNY Mellon (FDIC #639)

• Customers Bank (FDIC Certificate #34444)

• State Street Bank and Trust Company (FDIC Certificate #14)

• Western Alliance Bank (FDIC #57512)

Further, Paxos may utilize deposit placement networks operated by IntraFi Network LLC and Reich & Tang Deposit Solutions, LLC wherein the totality of balances in these deposit networks are FDIC-insured.

A list identifying IntraFi Network-insured depository institutions at which funds may be placed may be found here.

A list of Reich & Tang Deposit Solutions, LLC’s network banks can be found here. Paxos may exclude particular insured depository institutions within each network from eligibility to receive funds.

Paxos maintains FDIC-insured omnibus deposits at the following depositories:

• BMO Bank National Association (FDIC Certificate #16571)

• State Street Bank and Trust Company (FDIC Certificate #14)

• Customers Bank (FDIC Certificate #34444)

SCHEDULE 6: ILLEGAL ACTIVITY

Last Modified: December 15, 2025

Use of assets managed by Paxos Trust Company, NA, a national banking association organized under the laws of the United States and regulated by the Office of the Comptroller of the Currency(“Paxos Trust”) or its applicable affiliates, including Paxos Global PTE LTD (“Paxos Global”), Paxos Digital Singapore Pte. Ltd. (“Paxos Digital”), Paxos Issuance Europe Oy (“PIE”) and Bruntal S.A. (dba Paxos Uruguay) (“PUY”), (collectively, “Paxos,” “we,” “us” or “our”), for illegal activity is strictly prohibited as further provided herein:

1. We may freeze, temporarily or permanently, your use of, and access to PYUSD, USDP, USDG and/or BUSD or the US dollars backing your PYUSD, USDP, USDG and/or BUSD with or without advance notice, if we are required to do so by law, including by court order or other legal process.

2. Your PYUSD, USDP, USDG and/or BUSD and the US dollars backing your PYUSD, USDP, USDG and/or BUSD may be subject to seizure or forfeiture by law enforcement, and we will comply with legal process in respect thereof.

3. If we determine after investigation that PYUSD, USDP, USDG and/or BUSD has been used, or is being used, for illegal (or sanctioned) activity, we may not permit you to redeem your PYUSD, USDP, USDG and/or BUSD for US dollars from Paxos, and, if presented for redemption, such PYUSD, USDP, USDG and/or BUSD and the US dollars backing such PYUSD, USDP, USDG and/or BUSD may be forfeited.

4. Any PYUSD, USDP, USDG and/or BUSD or fiat currency underlying PYUSD, USDP, USDG and/or BUSD that is subject to freeze, seizure, forfeiture or similar limitation on its use imposed by law may become wholly and permanently unrecoverable and unusable, and in appropriate circumstances, may be destroyed.

5. This applies to all holders of PYUSD, USDP, USDG and/or BUSD, regardless of whether the holder is a registered customer of Paxos.

6. By using PYUSD, USDP, USDG and/or BUSD, you agree that we may take the actions set forth above and that we will not be liable to you therefore.

7. Paxos’s Compliance Department must comply with any legal directive to freeze, temporarily or permanently, user access to Paxos issued asset-backed tokens including USD stablecoins and gold-backed stablecoins (PAXG). Paxos will only freeze such assets (a) if required to do so by law, specifically when Paxos receives a formal legal directive from a regulator, judicial body, law enforcement agency, or other legal entity having jurisdiction over Paxos, or (b) pursuant to a formal notification by a Paxos partner according to previously agreed contractual terms. Required legal directive formats include court-ordered subpoenas, national security letters, and formal written directives from a regulator with oversight over Paxos.

8. If any party is aware of improper conduct involving a Paxos supported asset backed token, the party should immediately contact Paxos at support.paxos.com, as well as law enforcement to work towards filing a law enforcement report. Paxos will make reasonable efforts to cooperate with law enforcement inquiries and assist with investigations pertaining to Paxos supported asset backed tokens.

9. Tokens held by non-registered customers of Paxos may subsequently also be subject to seizure or forfeiture if Paxos is instructed to seize such funds by formal written legal directive from a regulator, judicial body, law enforcement agency, or other legal entity having jurisdiction over Paxos. Seizure may not occur under any circumstances absent such a legal directive.

10. If tokens are seized, the Paxos transaction generation will ensure that the seized funds are sent to a segregated wallet address held by Paxos for the purposes of seizure/forfeiture, until such time as they may be disposed of or otherwise handled as required by law.

SCHEDULE 7: RISK DISCLOSURES

Risk Warning On Digital Payment Token Services

Last Modified: December 15, 2025

The Monetary Authority of Singapore (“MAS”) requires Paxos Global Pte. Ltd. (“Paxos Global,” “we,” “us” or “our”) to provide this risk warning to you as a customer of a digital payment token (“DPT”) service provider. Before you: (a) pay your DPT service provider any money or DPT; or (b) pay a third party any money or DPT under an arrangement by your DPT service provider, you should be aware of the following:

1. Your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider or any other third party referred to above, if your DPT service provider’s or the third party’s business fails. You should be aware that MAS does not supervise or regulate your DPT service provider for the provision of unregulated services. This includes any service of trading digital payment token derivatives such as futures.

2. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by your DPT service provider.

3. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.

4. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”.

Paxos Global does not offer customers its own exchange rate. Customers who deposit currency other than USD into Paxos Global or its affiliates’ accounts at its third-party partner banks will have their foreign currency deposits automatically converted into USD at a rate independently determined by such bank. The exchange rate to be applied by such bank to relevant payment services will not be available at the point of transaction.

Please note that by requesting and accepting access to and use of the services and products offered by Paxos Global, the customer agrees to Paxos Global converting all customer monies received in the customer’s account to Pax Dollar tokens (“USDP”), PayPal USD tokens (“PYUSD”), Global Dollar tokens (“USDG”), and/or Binance USD tokens (“BUSD”) (hereinafter together referred to as “USD Stablecoins”). Upon the receipt of customer monies, Paxos Global will apply such monies to purchase an equivalent amount of USD Stablecoins, which will be held by Paxos Global on behalf of the customer in segregated custodial accounts.

USD Stablecoins are not money or legal tender and are not monetary instruments. Once you have USD Stablecoins, you can transfer them, trade them, keep them, use them to pay persons that will accept USD Stablecoins, or redeem them for U.S. dollars from the USD Stablecoin custody account, subject to certain limitations. Please refer to the Paxos General Terms and Conditions available at https://paxos.com/2019/03/29/general-terms-and-conditions/ for more information.

Please note that the safeguarding requirements under Section 23 of the Payment Services Act 2019 (“PS Act’) will not apply to USD Stablecoins held by Paxos Global on your behalf. The USD Stablecoins are fully backed by reserves in US dollars held by Paxos Trust Company, NA on the customer’s behalf in segregated custodial accounts with US banks, and/or debt instruments that are expressly guaranteed by the full faith and credit of the United States Government, and/or money-market funds composed of such debt instruments specifically held for the benefit of USD Stablecoin customers. Please refer to Paxos Trust Company, NA’s Monthly Reserves Holding Reports here for more information about assets backing USD Stablecoins.

To the extent that Paxos Global is unable to effect the conversion of the customer monies into USD Stablecoins as described above, customer monies that have not been converted into USD Stablecoins will be deposited into a trust account maintained by Paxos Global with a safeguarding institution (as defined in Section 23(14) of the PS Act) in Singapore. Customer monies received from a customer will be deposited into the same trust account and be commingled with monies received by Paxos Global from other customers. Accordingly, in the event that there is a shortfall in the monies held in the trust account due to any part being utilised to apply towards the obligations or default of another customer, there is a risk that a customer may not recover all the customer monies that were held for that customer. In the event that the safeguarding institution holding the customer monies becomes insolvent, Paxos Global will be an unsecured creditor vis-à-vis the safeguarding institution in respect of the customer monies. As such, there is a risk that Paxos Global may not be able to fully recover all the customer monies placed with the safeguarding institution on account of its customers, and that a customer may not be able to fully recover all the customer monies that were deposited into the trust account to be held for that customer’s account.