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Special Risk Disclosure

Last updated: 19.08.2026

1. Introduction

This Special Risk Disclosure Notice provides a non-exhaustive overview of certain risks associated with Crypto Assets, fiat payment services, foreign exchange, custody, execution, settlement and related services provided by AXENTE SWISS GmbH (“AXENTE”).

This Special Risk Disclosure Notice forms an integral part of the Business Relationship between the Client and AXENTE and must be read together with AXENTE’s General Terms and Conditions (“GT&CS”), Fee Schedule, Privacy Notice, and any applicable service agreement.

The risks described herein are not exhaustive. Additional risks may exist or may arise in the future. The Client should seek independent legal, tax, financial and technical advice before entering into any transaction involving Crypto Assets or using any service provided by AXENTE (“Service”).

By entering into or continuing the Business Relationship and using the Services, the Client expressly accepts such risks. If the Client does not understand, accept or is not willing to assume any of the risks described in this Special Risk Disclosure Notice, it must refrain from entering into the Business Relationship and/or from using the Services.

2. No Investment, Legal or Tax Advice

AXENTE provides its Services on an execution-only basis unless otherwise expressly agreed in writing. AXENTE does not provide investment advice, legal advice, tax advice or financial planning.

The Client is solely responsible for assessing whether any Crypto Asset, transaction, payment, conversion, custody arrangement or Service is suitable for its own legal, financial, tax, regulatory and operational situation.

3. General Risks of Crypto Assets

Crypto Assets may be highly speculative, volatile and illiquid. Their value may decrease significantly or become worthless. There is no guarantee that any Crypto

Asset will retain its value, remain transferable, remain liquid or remain supported by AXENTE or any third-party provider.Crypto Assets are usually not legal tender, not backed by any government, central bank, issuer or institution, and may not confer any enforceable rights against any person.

4. Market Risk

The market value of Crypto Assets may fluctuate significantly within short periods of time, including on an intraday basis. Price movements may be caused in particular, but not limited to, by supply and demand, market sentiment, regulatory developments, governmental decisions or posts, macroeconomic events, technical incidents, cybersecurity events, failures of market participants, and/or developments affecting specific blockchain networks.

The Client may suffer a partial or total loss of value.

5. Liquidity Risk

Crypto Asset markets may be fragmented, immature, undercapitalized or temporarily illiquid. Certain Crypto Assets may not be capable of being sold or converted at a reasonable price, within a reasonable time, or at all.

Low liquidity may result in wide spreads, high slippage, rejected transactions, delayed execution or inability to execute orders.

6. Volatility Risk

Crypto Assets are subject to high volatility. Prices may be affected by events unrelated to the intrinsic characteristics of the relevant Crypto Asset, including market rumors, announcements, exchange failures, social media activity, cyber incidents or general market stress.

A sharp decline in one major Crypto Asset or traditional asset may negatively affect the broader Crypto Asset market.

7. Execution and Pricing Risk

Orders may not be executed at the expected price or within the expected timeframe. Execution may be affected by market volatility, insufficient liquidity, price movements, trading venue restrictions, counterparty availability, operational constraints, compliance checks or technical issues.

Where AXENTE executes orders through third-party venues, liquidity providers or counterparties, the Client is exposed to the execution practices, availability and solvency of such third parties.

8. Slippage Risk

The final execution price may differ from the indicative or expected price. This may occur in particular during periods of high volatility, low liquidity, market disruption, large transaction sizes or delayed settlement.

The Client bears the risk of adverse price movements between order placement, execution and settlement.

9. Settlement Risk

Settlement of Crypto Assets, fiat currencies or stablecoins may be delayed, incomplete or fail. Payment and delivery may not occur simultaneously.

The Client may deliver fiat currency, Crypto Assets or stablecoins before receiving the corresponding asset or payment. This may result in loss, delay or counterparty exposure.

10. Foreign Exchange Risk

Transactions involving different fiat currencies or conversions between fiat currencies and Crypto Assets are exposed to foreign exchange risk. Exchange rates may fluctuate between order placement, execution and settlement.

The Client bears all risks arising from currency fluctuations.

11. Stablecoin Risk

Stablecoins may not maintain their intended peg. A stablecoin may lose value due to insufficient reserves, illiquid reserves, issuer default, regulatory action, redemption restrictions, operational failure, market panic, smart contract vulnerabilities or failure of the relevant blockchain network.

The Client may not be able to redeem stablecoins at par value or at all.

12. Issuer and Counterparty Risk

Certain Crypto Assets may depend on an issuer, sponsor, protocol developer, custodian, exchange, liquidity provider, bridge operator, validator, administrator or other third party.

If such party fails to perform, becomes insolvent, is hacked, ceases operations, is subject to regulatory action or acts fraudulently, the value, transferability or availability of the relevant Crypto Asset may be adversely affected.

13. Custody Risk

Custody of Crypto Assets involves operational, technical, legal and cybersecurity risks. Loss, theft, destruction, compromise or unavailability of private keys, MPC infrastructure, access credentials or custody systems may result in permanent loss or unavailability of Crypto Assets.

Even where institutional custody technology is used, no custody solution can eliminate all risks.

14. Individualized Crypto Custody Risk

Crypto Assets held in Individualized Crypto Custody are intended to remain attributable to the relevant Client. However, the treatment of such assets in insolvency or similar proceedings remains subject to applicable law, the decisions of competent authorities and courts, and the technical and operational circumstances at the relevant time.

There may be delays, costs or restrictions in returning such assets to the Client.

15. Omnibus Crypto Custody Risk

Where Crypto Assets are held in Omnibus Crypto Custody, i.e. in collective custody, they may be held on an aggregated basis together with Crypto Assets of other clients. In such cases, the Client may have a contractual claim for the relevant type and amount of Crypto Assets rather than a claim to specifically identifiable units.

Omnibus Crypto Custody may expose the Client to additional operational, legal, settlement, allocation and insolvency risks. The Client may not benefit from segregation rights to the same extent as in Individualized Crypto Custody and may be exposed to claims of AXENTE’s creditors.

16. Insolvency Risk

In the event of bankruptcy, insolvency, liquidation or similar proceedings affecting AXENTE, a custodian, sub-custodian, bank, payment service provider, liquidity provider, exchange or other third party, the Client may suffer loss, delay, restricted access or inability to recover fiat funds, Crypto Assets or stablecoins.

Fiat funds held by AXENTE or through AXENTE may form part of AXENTE’s bankruptcy estate and do not benefit from depositor protection, deposit guarantee, banking privilege or similar statutory protection.

17. Third-Party Provider Risk

AXENTE may rely on third-party providers, including banks, payment service providers, custodians, execution venues, liquidity providers, technology providers, blockchain analytics providers, cloud providers and outsourcing partners.

Failures, outages, insolvency, misconduct, cyber incidents, operational errors or regulatory restrictions affecting such third parties may adversely affect the Services.

18. Blockchain Network Risk

Blockchain networks may suffer congestion, high transaction fees, delays, validator or miner failures, consensus failures, software bugs, chain reorganizations, censorship, forks or attacks.

Such events may delay, prevent, reverse or otherwise affect deposits, withdrawals, transfers, confirmations or settlements.

19. Finality and Irreversibility

Blockchain transactions are generally final and irreversible once confirmed. Transactions sent to an incorrect, incompatible, inaccessible or unsupported address may result in permanent loss.

AXENTE may not be able to recover Crypto Assets sent to the wrong address, wrong blockchain, unsupported network or incompatible smart contract.

20. Wallet Address Risk

The Client is solely responsible for verifying wallet addresses, blockchain networks, tags, memos and other transaction details before initiating any transfer.

The use of an incorrect, outdated, unsupported, inaccessible or compromised wallet address may result in permanent loss of assets.

21. Private Key and Access Credential Risk

Access to Crypto Assets may depend on private keys, seed phrases, passwords, API credentials, access rights, MPC key shares or other authentication mechanisms.

Loss, theft, compromise or destruction of such credentials may result in permanent loss of Crypto Assets or unauthorized transactions.

22. Cybersecurity Risk

Crypto Assets, wallets, platforms and communication channels are frequent targets of hacking, phishing, malware, social engineering, AI-generated fraud, SIM swapping, credential theft, denial-of-service attacks and other cyber threats.

The Client must maintain appropriate cybersecurity measures and secure its own systems, devices, credentials and communication channels.

23. Smart Contract Risk

Crypto Assets may depend on smart contracts. Smart contracts may contain coding errors, design flaws, vulnerabilities, malicious functions, oracle dependencies or upgrade mechanisms that may be exploited or changed.

Interactions with smart contracts may be complex and irreversible and may result in loss of assets.

24. Protocol and Governance Risk

Blockchain protocols may be modified by developers, validators, miners, governance participants or other stakeholders. Protocol changes may affect the functionality, supply, transferability, security, rights or value of Crypto Assets.

AXENTE has no control over such protocol changes.

25. Forks, Airdrops and Token Events

Blockchain networks may undergo hard forks, soft forks, airdrops, token migrations, token swaps, redenominations or other protocol events.

AXENTE may decide, at its sole discretion, whether or not to support any such event. Unsupported assets, rights or benefits may not be credited to the Client and may become inaccessible.

26. Replay Attack Risk

Forks may create a risk that transactions valid on one chain are replayed on another chain. This may result in unintended transfers or loss of Crypto Assets.

27. Network Attack Risk

Certain blockchain networks may be exposed to 51 percent attacks, double-spending attacks, censorship attacks, dusting attacks, denial-of-service attacks or other malicious activity.

Such attacks may affect transaction finality, value, transferability or security of Crypto Assets.

28. Open-Source Software Risk

Many Crypto Assets and blockchain protocols rely on open-source software. Such software may contain bugs, vulnerabilities or deliberately embedded defects. Development may be discontinued or delayed.

This may negatively affect the security, usability or value of Crypto Assets.

29. Quantum Computing and Cryptography Risk

Advances in quantum computing or cryptanalysis may weaken or compromise cryptographic algorithms used by blockchain networks, wallets or Crypto Assets.

Such developments may result in theft, loss of access, reduced security or loss of value.

30. Tainted Asset Risk

Crypto Assets may be traceable through blockchain analytics. Assets previously linked to illicit activity, sanctioned persons, hacks, fraud, scams or other suspicious activity may be considered tainted by service providers, authorities or counterparties. This also applies to Crypto Assets that went through a mixer.

Such assets may be frozen, rejected, seized, blocked or become difficult or impossible to use, transfer or convert.

31. Regulatory and Legal Risk

The legal and regulatory treatment of Crypto Assets varies across jurisdictions and may change over time. A Crypto Asset may be classified as a payment token, utility token, asset token, security, financial instrument, e-money token, stablecoin or other regulated instrument.

Changes in law, regulation, supervisory practice or enforcement may affect the legality, transferability, value, custody or availability of Crypto Assets or Services.

AXENTE is a financial intermediary affiliated with a Swiss self-regulatory organization (SRO) for anti-money laundering purposes. AXENTE is not prudentially supervised or regulated by the Swiss Financial Market Supervisory Authority (FINMA) as a bank, securities firm, asset manager, portfolio manager or other prudentially supervised financial institution. Accordingly, Clients do not benefit from the same level of regulatory oversight and supervisory scrutiny that may apply to FINMA-supervised institutions. The Client acknowledges and accepts the risks associated with conducting business with a financial intermediary that is supervised solely for compliance with applicable anti-money laundering requirements through an SRO framework.

32. Sanctions Risk

Sanctions laws and restrictions may apply to persons, entities, jurisdictions, wallets, transactions, blockchain addresses, tokens or counterparties.

AXENTE may refuse, suspend, block, freeze, reverse or delay transactions or Services where required or deemed appropriate for sanctions, AML/CFT, compliance or risk management reasons.

33. AML/CFT and Travel Rule Risk

AML/CFT and Travel Rule requirements may require the collection, verification and transmission of information relating to originators, beneficiaries, wallets, counterparties and transactions.

Missing, incorrect, inconsistent or incomplete information may result in delays, rejection, blocking, freezing, cancellation or reversal of transactions (where applicable).

34. Tax Risk

The Client is solely responsible for assessing and complying with all tax obligations arising from holding, transferring, converting, receiving, selling or otherwise transacting in Crypto Assets, fiat currencies or stablecoins.

Tax treatment may be uncertain and may change. AXENTE does not provide tax advice.

35. Payment Services Risk

Fiat payment services may be delayed, rejected, reversed, blocked or restricted due to banking cut-off times, intermediary banks, payment schemes, correspondent banks, sanctions screening, AML checks, technical failures, insufficient information or third-party restrictions.

AXENTE is not liable for delays or failures caused by banks, payment providers or other third parties.

36. On-Ramp and Off-Ramp Risk

Conversions between fiat currencies and Crypto Assets may be affected by market volatility, liquidity constraints, pricing discrepancies, banking delays, settlement failures, compliance checks and third-party provider restrictions.

The Client may receive less than expected or suffer losses due to adverse price or exchange rate movements.

37. Service Availability Risk

AXENTE or its third-party providers may suspend, limit or discontinue Services, deposits, withdrawals, trading, conversions, accounts, wallets, supported assets or blockchain networks for business, technical, operational, security, legal, regulatory or compliance reasons.

The Client remains exposed to market movements during any suspension or interruption.

38. Delisting and Unsupported Asset Risk

AXENTE may cease to support any Crypto Asset, blockchain network, wallet type or payment method. If the Client does not withdraw or convert the affected asset within the required timeframe, AXENTE may convert it into fiat currency or take other measures in accordance with the GT&CS.

Unsupported assets may become inaccessible or permanently lost.

39. Data and Communication Risk

Information transmitted by email, messaging services, online platforms or public networks may be delayed, intercepted, corrupted, incomplete or manipulated.

Even encrypted communications may reveal metadata, including sender and recipient information. AXENTE does not guarantee that public networks are secure or error-free.

40. Public Blockchain Privacy Risk

Transactions on public blockchains may be visible to the public and may be permanently recorded. Third parties may analyze blockchain data and potentially link wallet addresses to the identity of the Client or related persons.

The Client may therefore be exposed to confidentiality, profiling, cybersecurity and reputational risks.

41. Force Majeure Risk

Events outside AXENTE’s control may affect the Services, including natural disasters, war, terrorism, civil unrest, pandemics, power outages, internet failures, market disruptions, governmental actions, regulatory measures, cyber incidents or failure of third-party infrastructure.

Such events may cause delays, suspension, loss of access or inability to execute transactions.

42. Reputational Risk

Negative publicity, regulatory actions, cyber incidents, insolvencies, fraud or failures affecting AXENTE, third-party providers, Crypto Assets, issuers, execution venues or the broader digital asset industry may reduce market confidence and adversely affect liquidity, pricing or access to Services.

43. Sustainability and Environmental Risk

Certain blockchain networks may consume significant energy or have environmental impacts. Regulatory measures, public perception or sustainability concerns may negatively affect the use, value or availability of certain Crypto Assets.

44. Client Responsibility

The Client is solely responsible for understanding the risks of Crypto Assets and the Services, monitoring its positions, verifying transaction details, securing its own systems and credentials, complying with applicable laws, and seeking independent advice where necessary.

The Client acknowledges that it may suffer partial or total loss of its Crypto Assets, fiat funds or stablecoins.

45. No Liability for Disclosed Risks

To the fullest extent permitted by applicable law and subject to the GT&CS, AXENTE shall not be liable for losses, damages, delays, costs, missed opportunities or other adverse consequences resulting from the risks described in this Special Risk Disclosure Notice.

46. Amendments

AXENTE may amend this Special Risk Disclosure Notice at any time in accordance with the GT&CS. Unless the Client objects within the applicable objection period, the amended version shall be deemed accepted.

47. Client Acknowledgement

By entering into or continuing the Business Relationship with AXENTE and by using the Services, the Client confirms that it has read, understood and accepted this Special Risk Disclosure Notice and the risks described herein.