Transfer Services Policy

1. General principles

This policy establishes a comprehensive framework for managing transfer services in relation to crypto-assets, ensuring clarity, consistency, and robust protection for users. It aligns with regulatory expectations to promote transparency, safeguard users’ rights, and uphold best practices in service delivery. The policy addresses key principles, such as providing accessible and detailed information about transfer services, implementing measures to mitigate risks associated with crypto-asset transactions, and ensuring accountability in the event of errors or disputes. By adopting this policy, the Company aims to enhance trust, streamline processes, and foster a secure and resilient operational environment for all stakeholders.

2. Applicable Laws, Regulations and Standards

This Policy is issued in compliance with, but not limited to, the following:

• Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937;
• Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849;
• Commission Delegated Regulation (EU) 2025/1140 of 27 February 2025 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying records to be kept of all crypto-asset services, activities, orders and transactions undertaken; and
• ESMA Guidelines on the procedures and policies, including the rights of clients, in the context of transfer services for crypto-assets.

3. Definitions

4. Agreement to provide transfer services

The provision of transfer services shall be subject to an agreement between BlockNodes and the users specifying the Company’s duties and responsibilities. Such agreement shall be part of the general Terms and Conditions and shall include:

• The address of the Company’s head office and its means of communication, including electronic mail address;
• The name of the national competent authority in charge of supervising the Company;
• Information about the means of communication agreed upon and the language of communication;
• A description of the modalities of the transfer services to be provided;
• A description of the security systems used by the Company;
• The fees applied to the service;
• The user’s right to terminate the agreement and the procedures for doing so; and
• The applicable law.

5. Information to be provided upon the initiation of the service

Before the User enters into any agreement for the provision of transfer services for crypto-assets, they shall be provided with the following information through the general Terms and Conditions:

• Service Characteristics: A clear description of the main features of the transfer service for crypto-assets.
• Transfer Initiation and Consent: Detailed procedures for initiating or consenting to a crypto-asset transfer, withdrawing instructions or consent, and the required information from the user (e.g., authentication methods).
• Rejection Conditions: The circumstances under which the Company may reject a transfer instruction.
• Time of Receipt: The procedure for determining the time of receipt for a transfer instruction or consent and any applicable cut-off times.
• Supported Networks: For each crypto-asset, an explanation of the distributed ledger technology (DLT) network supported for transfers.
• Execution Time: The maximum execution time for completing the transfer service.
• Irreversibility Details: Reasonable estimates of the time or number of block confirmations required for the transfer to become irreversible or sufficiently irreversible, considering the DLT network’s rules and conditions.
• Fraud Notifications: The secure procedure for notifying clients of suspected or actual fraud or security threats.
• Error Reporting: The means and timeframe for clients to report unauthorized or incorrect transfers, along with the service provider’s liability and any limitations.

6. Information to be provided on individual transfers for crypto-assets

6.1 Pre-execution information requirements

After receiving an instruction to transfer crypto-assets but before executing the transfer, users shall be provided with the following information:

• A concise, standardized warning indicating their transaction becomes irreversible once they order a transfer through the SwissBorg App.
• A detailed breakdown of any charges payable by the user for the transfer, distinguishing between network-related fees (e.g., gas fees) and service fees charged by the provider.

Before initiating or executing any transfers of crypto-assets, the Company shall ensure compliance with the TFR and record the information required by that regulation, as set out by the Record-keeping and management of orders and transactions Policy.

6.2 Post-execution information requirements

Following the execution of a crypto-asset transfer, the user shall be promptly provided with the following information through the SwissBorg App:

• The names of the originator and beneficiary of the transfer.
• The distributed ledger address or crypto-asset account number for both the originator and beneficiary.
• A unique reference to identify the transfer.
• The type and amount of crypto-assets transferred or received.
• The debit or credit value date of the transfer.
• A detailed breakdown of any charges, fees, or commissions incurred during the transfer.

6.3 Handling rejections, returns and/or suspensions

In cases where a transfer is rejected, returned, or suspended, the user is promptly informed of the following through e-mail:

• The reason for the rejection, return, or suspension: technical reasons, security vulnerabilities and/or checks and other risk factors.
• Any steps the user can take to remedy the situation, if applicable under the specific circumstances.
• A detailed account of any charges or fees incurred, including whether these may be reimbursed.

7. Execution and Cut-Off times

The Company has set the following rules when it comes to execution and cut-off times in relation to transfer services for crypto-assets:

• Cut-Off Times: Cut-off times are not applicable to the transfer services provided by the Company, since transaction services operate 24/7. A transfer order will be considered executed on the same calendar day as per the user’s time zone.
• Maximum Execution Times: Once a transfer order is submitted, the transaction is signalled and broadcast to the relevant blockchain. The transfer then remains in the blockchain’s memory pool until mined. Actual execution times will depend on network congestion and/or priority fees. The average execution time is 8 seconds.
• Irreversibility Estimates: The number of nodes/confirmations for a transfer to become irreversible depends on the specific blockchain. On average, taking into account the crypto-assets for which the Company allows transfers, the number of nodes necessary for a transfer to become confirmed or irreversible is 1.

8. Internal Control of the Policy

This Policy is subject to the Company’s internal control framework, based on the principle of three lines of defence:

• The risk taking and first mitigation are conducted by the first level teams: Payments Product Managers and Engineering team;
• The control of the first level is conducted by the second level team: Legal and Regulatory team;
• The internal auditor is the third line of defence.

The person responsible for this Policy is the Company’s Compliance Officer.

9. Approval and entry in Force

The Policy shall enter into force on the date below. This Policy must be approved by the Company’s Board of Directors. Any change made to this Policy, unless it is only a change in wording or has no consequence on the principles set in this Policy, must be priorly submitted to the Company’s Risk Committee. The Risk Committee will propose an opinion to the Board of Directors, and the Board of Directors will make a decision to approve or disapprove the suggested change.