Citypay.io UZ

POLICY ON RISK WARNINGS RELATED TO CRYPTO-ASSET TRANSACTIONS

Tashkent August 11, 2026

1 GENERAL PROVISIONS

1.1. This Policy on Risk Warnings Related to Crypto-Asset Transactions (hereinafter —the “Policy”) has been developed in accordance with the legislation of the Republic of Uzbekistan and is intended to inform Clients of the principal risks that may arise when using the services of «CITY PAY GATE” JV LLCand transacting with crypto-assets.

1.2. «CITY PAY GATE” JV LLC (hereinafter — the “Company”) is a resident legal entity in the Republic of Uzbekistan, conducting activities in the sphere of crypto-asset turnover on the basis of a license to conduct crypto-shop activities No. CS 0012 and a license to conduct crypto-depository activities No. CD 0004, issued by the National Agency for Prospective Projects of the Republic of Uzbekistan.

1.3. This Policy is an integral part of the Company’s Public Offer and applies in conjunction therewith, the list of supported crypto-assets and blockchain networks, and other Company documents regulating the procedure for providing services to Users.

1.4. By accepting the Company’s Public Offer in the manner prescribed by its terms, including when using the Company’s services via an application or a partner’s information system, the User confirms that:

prior to accepting the Company’s Public Offer, the User was afforded an opportunity to read this Policy;
the User has read the contents of this Policy in full;
the User understands the nature and possible consequences of the risks associated with using the Company’s services and transacting with crypto-assets;
the User makes the decision to use the Company’s services and to transact with crypto-assets independently and consciously.

Failure by the User to read this Policy, provided that the opportunity to do so was made available, does not release the User from compliance with the requirements of the Company’s Public Offer and shall not serve as grounds for imposing liability on the Company for the consequences of risks that have been properly disclosed in this Policy.

1.5. The purpose of this Policy is to disclose to Users information on the principal financial, market, technological, operational, legal, regulatory, compliance, sanctions, and other risks associated with using the Company’s services and transacting with crypto-assets.

This Policy is aimed at ensuring that the User makes independent and informed decisions, taking into account the nature of the respective transaction, the User’s knowledge, experience, financial position, objectives for engaging in transactions, and ability to bear potential losses.

1.6. This Policy applies to the services and transactions available to the User in accordance with the legislation of the Republic of Uzbekistan, the Company’s Public Offer, the list of supported crypto-assets and blockchain networks, and other applicable documents of the Company, including:

storage of crypto-assets;
receipt of crypto-assets to the crypto-wallet addresses provided to the User;
internal and external transfers of crypto-assets;
purchase and/or sale of crypto-assets — in the cases and to the extent provided for by the respective public offer or other agreement;
use of the Platform and related software, technical, and information solutions.

1.7. The Company’s services are provided solely with respect to crypto-assets and blockchain networks supported by the Company and expressly specified in the relevant list posted on the Platform or annexed to the Company’s Public Offer.

The display on the Platform of a name, designation, or address of a particular crypto-asset, blockchain network, crypto-wallet address, technical function, or other information does not, by itself, signify that the Company supports any tokens, coins, protocols, or other digital units operating in that blockchain network.

The User shall, prior to conducting a transaction, independently verify that the chosen crypto-asset and blockchain network are supported by the Company and correspond to the information indicated on the Platform and in the list of supported crypto-assets and blockchain networks.

1.8. For the purposes of this Policy, the Platform means the totality of websites, mobile applications, personal accounts, software interfaces, information systems, and integrated technical solutions through which the User is granted access to the Company’s services, including via applications and information systems of the Company’s partners.
The Platform is a technical means of providing access to the Company’s services and does not act as an independent party to the legal relationship between the Company and the User.

1.9. Terms used in this Policy with initial capital letters and not defined directly herein shall be used in the meanings established by the legislation of the Republic of Uzbekistan, the Company’s Public Offer, and other Company documents regulating the provision of services to Users.

1.10. By acknowledging familiarity with this Policy through the acceptance of the Company’s Public Offer, the User confirms that they:

have been given access to information on the principal risks associated with using the Company’s services and transacting with crypto-assets;
understand the nature and specific characteristics of the crypto-asset transactions the User intends to perform;
realize that the value of crypto-assets may change significantly within a short period of time, and transactions with them may result in the total or partial loss of invested funds;
independently assess the acceptability of the relevant risks, taking into account the User’s knowledge, experience, financial position, objectives for the transactions, and ability to bear potential losses;
will not engage in a transaction if the User does not understand its essence, the terms of its execution, or the associated risks;
bear responsibility for independently made decisions regarding the purchase, sale, storage, or receipt and sending of crypto-assets.

1.11. The Company does not engage in asset trust management activities for Users and does not provide investment, financial, tax, or legal advice regarding the advisability of acquiring, selling, storing, or transferring a particular crypto-asset.

Information posted on the Platform, including data on crypto-assets, their current or historical value, exchange rate changes, transaction volumes, characteristics of blockchain networks, and other informational materials:

is provided for informational purposes only;
does not constitute an individual recommendation or an inducement to carry out a specific transaction;
shall not be regarded as a guarantee of profitability, preservation of value, or achievement of a certain financial result;
does not relieve the User of the need to independently assess the risks of an intended transaction.

6.12. The Company does not guarantee:

an increase in or preservation of the value of crypto-assets;
the User’s receipt of profit or any other economic result;
the ability to sell a crypto-asset at any time and at the price desired by the User;
the absence of losses, delays, technical limitations, or other adverse consequences when performing transactions;
the immutability of the characteristics, operating rules, or availability of the relevant crypto-asset or blockchain network.
Past performance of a crypto-asset, its historical returns, popularity, liquidity, and other indicators are not a guarantee that such indicators will be maintained in the future.

1.13. The list of risks provided for in this Policy is not exhaustive.

Additional risks may arise as a result of:

changes in legislation and law enforcement practice;
changes in the market situation;
changes in the characteristics or value of crypto-assets;
changes in the operating rules of blockchain networks and software protocols;
forks, updates, migrations, or other changes to the respective protocols;
actions or omissions of issuers, developers, validators, information system operators, service providers, and other third parties;
cyberattacks, fraud, technical failures, and other circumstances that the Company cannot always reasonably foresee or control.

1.14. The Company takes the organizational and technical measures provided for by the legislation of the Republic of Uzbekistan, the Company’s Public Offer, and internal documents aimed at ensuring the proper provision of services and mitigating the associated risks.

At the same time, the adoption of such measures by the Company cannot fully eliminate the risks inherent to the nature of crypto-assets, blockchain technologies, information systems, market processes, and actions of third parties.

1.15. In the event of any inconsistency between this Policy and the Company’s Public Offer regarding the rights, obligations, and liability of the Company and the User, the provisions of the Company’s Public Offer shall prevail unless otherwise provided by the legislation of the Republic of Uzbekistan.

2 GENERAL RISK WARNING

2.1. Transactions with crypto-assets are associated with a high level of risk and may not correspond to the financial position, knowledge, experience, objectives, and acceptable risk level of individual Users.

Prior to conducting a transaction, the User shall independently assess the nature of the relevant transaction, the risks associated with it, the User’s financial position, and ability to bear potential losses.

2.2. The value of crypto-assets may change significantly within a short period of time, both upward and downward. Changes in the market situation, demand, liquidity, and other circumstances may lead to a significant decrease in the value of a crypto-asset, including to zero.

As a result of transacting with crypto-assets, the User may lose, in whole or in part, the value of the crypto-assets acquired, stored, or transferred.

2.3. The User should transact with crypto-assets only to the extent of the value of funds the total or partial loss of which the User is able to bear without a material deterioration in their financial position and without breaching obligations to third parties.

It is not recommended that the User acquire crypto-assets using borrowed funds or funds required to meet obligations or essential living needs.

2.4. The provision by the Company of services in respect of a particular crypto-asset, the inclusion of such crypto-asset in the list of supported crypto-assets and blockchain networks, and the Company’s possession of the relevant licenses do not constitute:

a recommendation to purchase, sell, store, or send and receive such crypto-asset;
confirmation of the reliability, stability, or investment attractiveness of such crypto-asset;
a guarantee of the preservation or increase of its value, the existence of sufficient liquidity, or the possibility of its subsequent sale;
a guarantee of the absence of financial, technological, legal, regulatory, and other risks.

2.5. The Company does not determine whether a specific transaction is consistent with the User’s financial position, knowledge, experience, objectives, and acceptable risk level.

The User independently makes the decision to carry out each transaction with crypto-assets and bears the risks and consequences of such a decision to the extent provided for by the legislation of the Republic of Uzbekistan, the Company’s Public Offer, and this Policy.

3 MAIN RISK CATEGORIES

3.1. Market Risk

The value of crypto-assets is formed under the influence of supply and demand and may change significantly within a short period of time.

The value of crypto-assets may be affected by economic, political, technological, legal, regulatory, and other factors, including:

changes in the general situation on the crypto-asset market;
actions of large market participants;
changes in supply and demand volumes;
dissemination of information, news, forecasts, and rumors;
actions or statements of state authorities;
changes in the characteristics of the relevant crypto-asset or blockchain network;
actions or omissions of issuers, developers, and other third parties;
cyberattacks, fraud, and other unforeseen events.

The value of a crypto-asset may decline regardless of its past performance, recognition, capitalization, trading volume, or circulation period.

3.2. Liquidity Risk

At certain times, demand for or supply of a particular crypto-asset may be insufficient to execute a transaction in the desired volume or at the price expected by the User.

Insufficient liquidity may lead to:

an increase in the spread between the purchase price and the sale price of the crypto-asset;
execution of the transaction at a less favorable price;
inability to execute the transaction in full;
delay in the execution of the transaction;
temporary restriction or suspension of certain transactions involving the relevant crypto-asset.

The presence of a crypto-asset in the list of supported crypto-assets and blockchain networks does not guarantee the constant availability of sufficient liquidity or the possibility of its purchase or sale at any time and in any volume.

3.3. Quotation Change and Transaction Terms Risk

The price, rate, quantity of crypto-assets, and other calculation parameters of a transaction may change as a result of changes in the market situation, liquidity, transaction volume, and other circumstances.

A quotation provided to the User prior to confirmation of the transaction may have a limited validity period. Upon expiry of the quotation validity period or in the event of a material change in market conditions, the User may be offered a new quotation.

The display on the Platform of the preliminary, current, estimated, or historical value of a crypto-asset does not guarantee the execution of a transaction at such value. A transaction is executed at the price and on the terms confirmed by the User in the manner provided for by the respective public offer.

3.4. Blockchain Network Risk

The functioning of blockchain networks is not under the exclusive control of the Company and depends on the operation of the respective protocols, validators, network nodes, developers, and other participants.

Transactions with crypto-assets may be delayed, unconfirmed, or otherwise affected as a result of:

congestion or temporary unavailability of the blockchain network;
an insufficient number of confirmations;
technical failures or protocol errors;
updates, changes, or discontinuation of support for the respective protocol;
a fork, migration, or split of the blockchain network;
changes in the rules for confirming and processing transactions;
an attack on the blockchain network or a breach of the consensus mechanism;
blockchain reorganization, reversal, or change in the status of previously obtained confirmations;
other circumstances related to the functioning of the respective blockchain network.

Until the required number of confirmations has been obtained, a transaction may be deemed incomplete, and the respective crypto-asset may be unavailable for further use.

3.5. Technological and Operational Risk

The provision of the Company’s services depends on the proper functioning of software, hardware, telecommunications networks, data centers, software interfaces, information security systems, and other technical means.

Technical or operational failures may lead to:

temporary unavailability of the Platform or individual services;
inability to create, send, or confirm a User’s instruction;
delay in processing or displaying a transaction;
temporary discrepancy between the information displayed on the Platform and the data contained in the relevant blockchain network;
the need to conduct an additional technical review of a transaction;
temporary restriction of certain functions of the Platform.

The provision of services may also be affected by failures in the operation of banks, payment organizations, the Company’s partners, software providers, telecommunications operators, and other third parties involved in supporting the respective transaction.

3.6. Irreversibility Risk

A transaction sent to a blockchain network and having received the required number of confirmations generally cannot be canceled, modified, or revoked by either the Company or the User.

Prior to confirming an external transfer, the User shall independently verify:

the recipient’s crypto-wallet address;
the name and designation of the crypto-asset;
the selected blockchain network;
the amount of the crypto-asset to be transferred;
an additional identifier, tag, memo, or other details, if their specification is required for the respective transaction.

A User’s error in specifying the address, selecting the crypto-asset or blockchain network, entering an additional identifier, or other details may result in the irretrievable loss of crypto-assets or the impossibility of crediting them to the recipient.

3.7. Wrong Blockchain Network Risk

The same crypto-asset may function on multiple blockchain networks. At the same time, the Company may support the respective crypto-asset only on one or several expressly indicated blockchain networks.

The coincidence or external similarity of address formats on different blockchain networks does not signify their compatibility and does not confirm the possibility of crediting crypto-assets sent via an unsupported blockchain network.

Sending a crypto-asset via a blockchain network not supported by the Company for that particular crypto-asset may result in the impossibility of its automatic crediting, reflection in the User’s balance, or return.

3.8. Risk of Unsupported and Incorrectly Identified Crypto-Assets

The Company provides services solely in respect of supported crypto-assets and blockchain networks specified in the relevant list in the Company’s Public Offer.

The name, designation, logo, or other external features of a token do not by themselves confirm that such token is a crypto-asset supported by the Company. Various tokens with identical or similar names and designations may exist within the same blockchain network.

A crypto-asset is determined, inter alia, by its unique technical identifier, including the smart contract address, token issuance address, or other applicable identifier.

Sending to a crypto-wallet address displayed on the Platform:

an unsupported crypto-asset;
a crypto-asset with a different unique technical identifier;
a token imitating the name or designation of a supported crypto-asset;
a crypto-asset via an unsupported blockchain network;
other digital units not included in the list of supported crypto-assets and blockchain networks, may result in the impossibility of automatic detection, accounting, crediting, use, or return of the respective asset.
The receipt of an unsupported crypto-asset at an address displayed on the Platform does not by itself signify the Company’s acceptance of such crypto-asset for storage and does not create an obligation to credit the User with the corresponding amount of a supported crypto-asset, or to pay its value or other equivalent.

3.9. Stablecoin Risk

The value of a stablecoin may be pegged to the value of a certain currency, another asset, or an index. Such peg does not exclude the risk of the market value of the stablecoin deviating from the stated value or the complete loss of the respective peg.

Loss of or change to the peg may occur as a result of:

insufficiency, unavailability, or change in the composition of the issuer’s reserves;
restriction or cessation of redemption of the stablecoin by the issuer;
a decline in market liquidity;
changes in legislation or the imposition of restrictive measures;
technical failures, cyberattacks, or smart contract errors;
loss of market participants’ trust in the issuer;
other circumstances beyond the Company’s control.
The Company is not the issuer of the supported stablecoins and does not guarantee the maintenance of their peg, the adequacy of reserves, the possibility of redemption by the issuer, or the stability of their market value.

3.10. Custody and Unauthorized Access Risk

Despite the organizational and technical measures taken by the Company, the use of custody and transfer services for crypto-assets is associated with the risks of cyberattacks, unauthorized access, account compromise, malicious software, phishing, substitution of details, and other unlawful actions.

Compromise of a device, phone number, email address, password, confirmation code, or other means of User identification may result in third parties gaining access to the account and performing unauthorized transactions.

After crypto-assets have been transferred to an external crypto-wallet, their further storage and security depend on the owner of such wallet, the software used by the owner, and the safekeeping of the relevant access credentials. The Company does not have the technical ability to manage an external crypto-wallet, to cancel transactions carried out in its favor, or to restore the User’s lost access credentials to such wallet.

3.11. Third-Party Risk

The provision of certain services may depend on the activities of crypto-asset issuers, blockchain protocol developers, validators, liquidity providers, banks, payment organizations, information system operators, the Company's partners, and other third parties.

Actions, omissions, insolvency, cessation of activities, technical failures, or changes in the operating terms of such persons may affect:

the availability of certain crypto-assets and services;
the processing time of transactions;
the liquidity and value of crypto-assets;
the ability to purchase, sell, store, or send and receive crypto-assets;
the accuracy and timeliness of obtaining certain market or technical data.

3.12. Legal and Regulatory Risk

Legislation and law enforcement practice in the sphere of crypto-asset turnover are subject to change.

Changes in legislation, requirements of authorized state bodies, the legal status of a particular crypto-asset, blockchain network, or type of transaction may lead to:

changes in the procedure and terms of service provision;
imposition of additional requirements for User identification and verification;
restriction or suspension of certain transactions;
removal of a crypto-asset or blockchain network from the list of supported ones;
restriction of access to services for certain categories of Users;
discontinuation of certain services;
other legal, financial, or tax consequences.
The availability of a crypto-asset, service, or transaction on a foreign platform or in a foreign state does not mean that such crypto-asset, service, or transaction is permitted or available in the territory of the Republic of Uzbekistan.

The Company is entitled to change the availability of services and supported crypto-assets in order to comply with the legislation of the Republic of Uzbekistan and the mandatory requirements of authorized state bodies.

4 RISKS ASSOCIATED WITH COMPLIANCE CHECKS AND INTERNAL CONTROL MEASURES

4.1. In accordance with the requirements of the legislation of the Republic of Uzbekistan, the Company carries out internal control, including identification and due diligence of Users, risk level assessment, transaction monitoring, detection of suspicious transactions, and taking other measures to counter the legalization of proceeds from criminal activity, the financing of terrorism and the financing of the proliferation of weapons of mass destruction.

4.2. The User's transactions may be subject to ongoing and subsequent review, including prior to their execution, during processing or after completion.

The review may be carried out by the Company using automated systems, specialized blockchain transaction analysis tools, open and official sources of information, information provided by the User, as well as information received from the Company’s partners and other third parties in accordance with the legislation of the Republic of Uzbekistan.

4.3. As part of the review, the Company is entitled to analyze:

information about the User and other participants in the transaction;
the crypto wallet addresses of the sender and the recipient;
the origin and subsequent destination of the crypto assets;
the transaction history associated with the relevant crypto wallet addresses;
the volume, frequency and nature of the transactions performed;
the conformity of the transaction with the information about the User and the User’s previous transactions;
the economic sense and purpose of the transaction;
other circumstances relevant to assessing the risk level and complying with the requirements of the legislation of the Republic of Uzbekistan.

4.4. The Company is entitled to request from the User information and documents necessary for identification, additional or repeated verification, confirmation of the origin of crypto assets, the economic sense of a transaction, as well as the ownership and lawfulness of the use of the relevant crypto wallet addresses.

Such information and documents may include:

documents confirming the User’s identity and place of residence;
information on the source of origin of the crypto assets;
documents confirming the acquisition or receipt of crypto assets;
information on the sender, recipient and purpose of the transaction;
documents confirming that the relevant crypto wallet belongs to the User or that there are lawful grounds for its use;
information and documents confirming the economic sense of the transaction;
other information and documents necessary for the Company to comply with the requirements of the legislation of the Republic of Uzbekistan and the Company’s internal documents.

4.5. The User is obliged to provide the information and documents requested by the Company within the time limit set by the Company. The information and documents provided must be complete, reliable, up-to-date and must not mislead the Company.

The Company is entitled to verify the authenticity, reliability and relevance of the provided information and documents, including through the use of available state information systems, databases and other lawful sources of information.

4.6. Depending on the results of the review, the established risk level, the nature of the transaction and the requirements of the legislation of the Republic of Uzbekistan, the Company is entitled to:

suspend or delay the processing of a transaction pending completion of the review;
request additional information and documents;
conduct additional or repeated identification and verification of the User;
impose additional restrictions on the execution of certain transactions;
temporarily restrict access to certain services or functions of the Platform;
refuse to execute a transaction;
refuse to establish or continue a business relationship with the User;
terminate contractual relations with the User in the manner provided for by the Company’s Public Offer;
enhance monitoring of the User’s transactions;
suspend transactions or freeze crypto assets in the cases and in the manner provided for by the legislation of the Republic of Uzbekistan;
send information and documents to the specially authorized state body, the National Agency for Prospective Projects of the Republic of Uzbekistan, law enforcement or other competent state bodies in the cases provided for by the legislation of the Republic of Uzbekistan;
take other measures provided for by the legislation of the Republic of Uzbekistan, the Company’s Public Offer and the Company’s internal documents.

4.7. The Company’s determination of a high risk level with respect to the User, a transaction, a crypto wallet address or the source of receipt of crypto assets may result in enhanced due diligence and the application of additional internal control measures.

Assigning a high risk level does not require the mandatory establishment of the fact of committing a crime or other offense and is carried out by the Company for the purpose of complying with the requirements of the legislation of the Republic of Uzbekistan and reducing the risks of using the Company’s services for unlawful purposes.

4.8. The receipt of crypto assets at a crypto wallet address provided to the User by the Company does not preclude the possibility of a subsequent review of such crypto assets and transactions associated with them.

The reflection of a crypto asset on the User’s balance or the display of a transaction on the Platform does not in itself mean the final completion of all internal control procedures and does not preclude the application by the Company of the measures provided for in this section upon the subsequent identification of circumstances of increased risk.

4.9. If circumstances are identified that prevent the crediting or further use of the received crypto assets, the Company shall determine the procedure for further actions in accordance with the legislation of the Republic of Uzbekistan, the Company’s Public Offer and other applicable documents of the Company.

4.10. Conducting compliance checks may lead to an increase in the transaction processing time, temporary restriction of access to crypto assets or to certain services of the Company, as well as to the impossibility of the User executing the intended transaction.

The duration of the review depends on the nature of the transaction, the established risk level, the completeness and timeliness of the provision of the requested information and documents by the User, the need to obtain information from third parties or state bodies, as well as other circumstances of the relevant case.

4.11. Failure by the User to provide the requested information or documents, violation of the time limit for their provision, provision of incomplete, unreliable, contradictory or questionable information may result in:

refusal to execute the transaction;
restriction of access to certain services of the Company;
revision of the User’s risk level;
enhanced monitoring of the User’s transactions;
suspension of service;
termination of contractual relations;
application of other measures provided for by the legislation of the Republic of Uzbekistan and the Company’s Public Offer.

4.12. The User understands that crypto assets may have a direct or indirect connection to crypto wallet addresses, transactions, persons or resources that have been assigned an elevated or high risk level.

The User’s lack of information about the previous movement history of crypto assets does not preclude the Company from conducting a review and applying the measures provided for in this section.

4.13. The Company is not obliged to disclose to the User:

internal criteria, algorithms and threshold values for risk assessment;
information on the operation of the monitoring and analysis systems used;
the risk level assigned to the User, the transaction or the crypto wallet address;
the content and results of the internal review;
the fact, content or grounds for sending information to competent state bodies;
information the disclosure of which is prohibited or restricted by the legislation of the Republic of Uzbekistan.

In cases provided for by the legislation of the Republic of Uzbekistan, the Company is entitled to apply the relevant restrictions without prior notice to the User and without disclosing the specific grounds for their application.

5 RISKS ASSOCIATED WITH HIGH-RISK SOURCES OF ORIGIN OF CRYPTO ASSETS

5.1. The User is not entitled to use the Company’s services to receive, store, buy, sell or send and receive crypto assets if the User knows or has reasonable grounds to believe that such crypto assets:

were obtained as a result of criminal or other unlawful activity;
are used to finance criminal or other unlawful activity;
belong to a person in respect of whom prohibitions or restrictions are established by law;
are associated with transactions aimed at concealing their origin, owner, sender, recipient or economic purpose;
otherwise have an illegal or dubious origin.

5.2. The User is obliged to exercise reasonable diligence when choosing counterparties, external crypto wallets, platforms, exchange services and other persons with whom the User conducts transactions with crypto assets.

Before receiving or sending crypto assets, the User should, to the extent of the information available to them, assess the lawfulness of the intended transaction, the purpose of the transfer, information about the counterparty and the service used, as well as other circumstances that may indicate an elevated or high risk level.

5.3. High-risk sources, persons, resources and types of activities may include, inter alia:

persons and organizations included in the lists of persons involved or suspected of involvement in terrorist activities or the proliferation of weapons of mass destruction;
persons, organizations, territories and crypto wallet addresses subject to sanctions or other restrictive measures taken into account by the Company in accordance with the legislation of the Republic of Uzbekistan, contractual obligations and internal documents of the Company;
darknet markets, illegal trading platforms and other resources used for the sale of prohibited goods or services;
fraudulent projects, financial pyramids, investment fraudulent schemes and other projects based on misleading persons or unlawfully taking possession of their property;
phishing resources, fake websites, applications and other means of unlawfully obtaining data or access to crypto assets;
crypto wallet addresses and other resources associated with the theft of crypto assets, extortion, malicious software, cyber attacks, hacks, exploitation of vulnerabilities or other unlawful actions;
crypto assets in respect of which there is information about their theft, unlawful possession or other illegal receipt;
services for mixing or concealing the movement of crypto assets, including mixers, tumblers and other similar services or technologies used for the purpose of making it difficult to establish the origin, sender, recipient or further movement of crypto assets;
persons and services carrying out activities in the sphere of crypto assets turnover without a license, permit or other legal basis, if such a license, permit or legal basis is required by applicable law;
service providers operating in states or territories where measures to counter the legalization of criminal proceeds, the financing of terrorism and the financing of the proliferation of weapons of mass destruction are absent or insufficiently effectively applied;
resources associated with illegal gambling, illegal trafficking of goods, extortion, human trafficking, financing of terrorism or other unlawful activity;
crypto wallet addresses, persons, services and transactions that have been assigned a high risk level by the Company in accordance with the legislation of the Republic of Uzbekistan and the Company’s internal documents.

5.4. The list provided for in clause 5.3 hereof is not exhaustive.

The Company is entitled to take into account other risk factors, including the history of the movement of crypto assets, the nature and frequency of transactions, information about related crypto wallet addresses, the technologies used, the jurisdiction of the relevant persons and services, information from official and open sources, the results of specialized blockchain transaction analysis and other information relevant to the risk assessment.

5.5. A high risk level may be established not only upon the direct receipt of crypto assets from a high-risk source, but also if there is a direct or indirect connection of the relevant crypto assets, crypto wallet addresses or participants in the transaction with the persons, resources or types of activities specified in this section.

The number of intermediate crypto wallet addresses or transactions does not in itself exclude the existence of such a connection.

5.6. The User's lack of information about the full movement history of the received crypto assets does not preclude the Company from conducting a review and applying internal control measures.

At the same time, the Company’s determination of an elevated or high risk level with respect to crypto assets, a crypto wallet address or a transaction does not in itself mean a finding of the User’s guilt in committing a crime or other offense.

5.7. The User is prohibited from taking actions aimed at:

concealing the origin, ownership, sender, recipient or purpose of crypto assets;
circumventing restrictions, review procedures and internal control measures of the Company;
splitting one transaction into several transactions for the purpose of avoiding review or established restrictions;
using accounts, crypto wallets, documents or details of third parties to conceal the actual participant in the transaction;
providing the Company with false, unreliable, incomplete or misleading information about the origin of crypto assets, the participants and the purpose of the transaction.

5.8. The User’s use of a well-known, popular or licensed in a foreign state crypto platform, exchange service or other service provider does not in itself guarantee the lawfulness of the origin of the crypto assets received through it and the absence of risks associated with them.

5.9. If a direct or indirect connection of a transaction, crypto assets, a crypto wallet address or a participant in the transaction with high-risk sources is identified, the Company is entitled to conduct an additional review and apply the measures provided for in Section 4 hereof, the Company’s Public Offer and the legislation of the Republic of Uzbekistan.

5.10. The Company is not obliged to disclose to the User the internal criteria for classifying sources, crypto wallet addresses, transactions or participants in transactions as high-risk, the indicators, algorithms, threshold values and results of specialized analysis used, if the disclosure of such information could hinder the exercise of internal control or is restricted by the legislation of the Republic of Uzbekistan.

6 OBLIGATIONS AND LIABILITY OF THE USER

6.1. When using the Company’s services and conducting transactions with crypto assets, the User is obliged to comply with the requirements of the legislation of the Republic of Uzbekistan, the Company’s Public Offer, this Policy and other applicable documents of the Company.

6.2. The User is obliged to use the account exclusively personally and is not entitled to:

transfer account access data to third parties;
enable third parties to conduct transactions on behalf of the User;
use the account, documents, payment instruments or means of identification of another person;
conceal the person in whose interests or on whose instructions the transaction is actually conducted;
use the Company’s services as an intermediary to conduct transactions of third parties without lawful grounds and prior disclosure of the relevant circumstances to the Company.

6.3. When using external crypto wallets, the User is obliged to have lawful grounds for owning, managing or using the relevant crypto wallet.

If the User indicates that the external crypto wallet belongs to them or is under their control, such information must be reliable.

When transferring crypto assets to a third party’s address, the User is obliged to ascertain the lawfulness of the purpose of the transaction and the correctness of the recipient’s details, and, upon the Company’s request, to provide information on the recipient, the purpose of the transaction and the grounds for making the transfer.

6.4. Before confirming each transaction, the User is obliged to independently verify:

the name and designation of the crypto asset;
the blockchain network used to perform the transaction;
the crypto wallet address of the sender or recipient;
the quantity of the crypto asset;
the additional identifier, tag, memo or other mandatory requisite;
the amount of applicable fees and other terms of the transaction;
the conformity of the transaction with the User’s own intention.

The User must not confirm a transaction if there are errors, discrepancies or doubts regarding its terms and requisites.

6.5. The User is obliged to take reasonable measures to ensure the security of their account, device and authentication means, including:

ensuring the confidentiality of the login, password, confirmation codes and other access data;
preventing the transfer of access data to third parties;
using appropriate means of protecting the device and software;
verifying the authenticity of websites, applications, messages and other resources used to access the Company’s services;
preventing the installation of software from unknown or unreliable sources;
complying with the mandatory requirements of the Company in the field of information security.

8.6. The User is obliged to immediately notify the Company upon discovery of:

loss or compromise of access data;
unauthorized access to the account;
a transaction that the User did not perform or confirm;
loss of a device, phone number, email address or other means used to access the account;
substitution of a crypto wallet address or other transaction requisites;
other circumstances that may affect the security of the User’s account or crypto assets.

Until the Company receives the relevant notification and takes technically possible measures to restrict access, the User bears the risk of transactions being performed using their current access data.

6.7. When undergoing identification, additional or repeated verification, as well as when reviewing individual transactions, the User is obliged:

to provide complete, reliable and up-to-date information and documents;
not to conceal circumstances that are relevant to the assessment of the User or the transaction;
to provide the requested information and documents within the time limit set by the Company;
to notify the Company of any change in the previously provided information;
not to provide forged, altered, invalid or documents belonging to another person;
not to provide information that may mislead the Company.

6.8. The User is not entitled to:

use the Company’s services for unlawful purposes;
conduct transactions with crypto assets whose illegal or dubious origin is known to the User or should be obvious upon exercising reasonable diligence;
use the Company’s services to conceal the origin, ownership, sender, recipient or purpose of crypto assets;
attempt to circumvent identification, compliance checks, limits, restrictions and internal control measures of the Company;
split transactions or use multiple accounts, wallets or third parties for the purpose of evading established requirements and procedures;
hinder the Company’s conduct of reviews or provide knowingly false explanations regarding the nature and purpose of the transaction.

6.9. The User is responsible for:

the lawfulness of the origin of the funds and crypto assets belonging to them;
the existence of lawful grounds for owning, using and disposing of crypto assets;
the lawfulness of the purpose and designation of the transactions conducted;
the reliability of the information and documents provided to the Company;
the correctness of the transaction requisites indicated by them;
the safekeeping of their access data and authentication means;
decisions on the purchase, sale, storage and sending and receiving of crypto assets;
compliance with the requirements of the legislation applicable to the User.

When assessing the origin of the received crypto assets, information that the User possesses or should possess upon exercising reasonable diligence is taken into account. The User is not released from the obligation to provide the Company with the requested information and documents on the ground that they do not know the full movement history of the relevant crypto assets.

6.10. The User bears the risk of adverse consequences arising as a result of:

indicating an incorrect crypto wallet address or other requisites;
selecting an unsupported crypto asset or blockchain network;
sending an unsupported, erroneously identified or counterfeit token;
transferring access data to third parties;
using a compromised device or software;
untimely notification of the Company of the circumstances provided for in clause 6.6 hereof;
failure to provide or untimely provision of the information and documents requested by the Company;
violation of the requirements of the legislation of the Republic of Uzbekistan, the Company’s Public Offer or this Policy.

6.11. Violation by the User of the obligations provided for in this section may result in a delay or refusal to execute a transaction, restriction of access to certain services, conducting an additional review, revision of the risk level, suspension of service or termination of contractual relations in the manner provided for by the legislation of the Republic of Uzbekistan and the Company’s Public Offer.

7 LIMITATIONS OF LIABILITY OF THE COMPANY

7.1. The liability of the Company for non-performance or improper performance of obligations to the User is determined by the legislation of the Republic of Uzbekistan and the Company’s Public Offer.

The Company shall not be liable for losses, loss of crypto assets, delays, restrictions and other adverse consequences to the extent that they arose as a result of circumstances beyond the Company’s control and not caused by the Company’s breach of its assumed obligations.

7.2. The Company shall not be liable for adverse consequences arising as a result of:

changes in the market value, liquidity, demand or supply in respect of crypto assets;
loss of or change in the peg of a stablecoin to the corresponding currency, asset or other indicator;
the User’s independent decisions to purchase, sell, store or send and receive crypto assets;
the User’s incorrect assessment of financial, market, legal, technological or other risks;
the User’s indication of an incorrect, incomplete or outdated crypto wallet address or other transaction requisites;
the User’s selection of an incorrect or unsupported blockchain network;
sending an unsupported crypto asset, a counterfeit token or a crypto asset with a different unique technical identifier;
the User’s failure to provide a mandatory additional identifier, tag, memo or other transaction requisite;
the User’s violation of the requirements of the legislation of the Republic of Uzbekistan, the Company’s Public Offer, this Policy or the instructions posted on the Platform;
the User’s provision of incomplete, unreliable, outdated or misleading information and documents;
the User’s untimely provision of the information and documents requested by the Company;
the User’s performance of transactions using a compromised device, software, phone number, email address, access data or authentication means;
the User’s transfer of account access data, confirmation codes or other confidential information to third parties;
the User’s untimely notification of the Company of unauthorized access, loss of a device, compromise of access data or other circumstances threatening the security of the User’s account.

7.3. The Company shall not be liable for a delay, impossibility of performing or finally confirming a transaction, a change in its status or other adverse consequences caused by the specific features of the functioning of the relevant blockchain network, including:

overload or temporary unavailability of the blockchain network;
insufficient number of transaction confirmations;
a change in the blockchain network fee;
actions or omissions of validators, network nodes, developers or other participants in the blockchain network;
an update, change, suspension or termination of operation of the relevant protocol;
a fork, migration, reorganization or split of the blockchain network;
attacks on the blockchain network, protocol errors or disruption of the consensus mechanism;
other circumstances of the functioning of the blockchain network that are beyond the reasonable control of the Company.

7.4. The Company shall not be liable for the independent actions or omissions of external crypto wallets, crypto asset issuers, foreign crypto platforms, service providers in the sphere of crypto assets turnover, banks, payment organizations, telecommunications operators, software providers and other third parties that are not under the control of the Company, including:

blocking, rejection, suspension or delay of a transaction by such an entity;
restriction of the User’s access to the services or assets of such an entity;
an error, malfunction, termination of activity or insolvency of such an entity;
a change by such an entity of the rules, tariffs, limits or terms of service;
loss of crypto assets after their proper transfer to an external crypto wallet or a third-party platform.

The liability of the Company for the actions of entities engaged by the Company directly for the performance of its own obligations to the User is determined by the legislation of the Republic of Uzbekistan and the Company’s Public Offer.

7.5. The Company shall not be liable for the impossibility of executing a transaction, a delay in its processing, restriction of access to certain services or other consequences arising as a result of:

the adoption, amendment or application of regulatory legal acts;
compliance with mandatory requirements, decisions, orders or requests of authorized state bodies;
a change in the legal status of a crypto asset, a blockchain network or the relevant transaction;
the application of internal control measures, a compliance check, sanctions control or other mandatory procedures;
the suspension of transactions, freezing of crypto assets, refusal to execute a transaction or termination of service in cases provided for by the legislation of the Republic of Uzbekistan and the Company’s Public Offer, provided that the relevant actions of the Company were carried out in accordance with the legislation of the Republic of Uzbekistan and the Company’s Public Offer.

7.6. The Company does not guarantee the continuous and uninterrupted availability of the Platform and is entitled to temporarily restrict access to the Platform or certain of its functions in connection with the performance of technical, maintenance, recovery or other necessary works.

The Company shall take reasonable measures to restore the availability of the Platform and minimize possible adverse consequences.

7.7. The Company shall not be liable for a temporary delay in updating the information displayed on the Platform if such delay is due to the operation of the blockchain network, information systems or third-party data sources.

With respect to an external blockchain transaction, the information recorded in the relevant blockchain network, after obtaining the required number of confirmations, shall be decisive.

7.8. The User is obliged to take reasonable and available measures to prevent the occurrence of losses and to reduce their amount.

8 RISK MITIGATION RECOMMENDATIONS

8.1. For the purpose of reducing the risks associated with using the Company’s services and transacting with crypto-assets, it is recommended that the User follow the precautionary measures provided for in this section.

Compliance with the specified recommendations reduces the likelihood of adverse consequences, but cannot fully eliminate the financial, technological, operational, legal, and other risks associated with crypto-asset transactions.

8.2. To ensure account security, it is recommended that the User:

use two-factor authentication, if the relevant function is available;
set a unique and complex password that is not used to access other services;
not disclose the password, confirmation codes, and other account access credentials to third parties;
not save access credentials on publicly accessible or third-party-owned devices;
regularly update the operating system, applications, and protection tools of the device being used;
not install software from unknown or untrusted sources;
not grant third parties remote access to the device used to log into the Platform;
regularly check the transaction history and account activity information.

8.3. The User should access the Platform and interact with the Company exclusively through the Company’s official websites, applications, email addresses, and other communication channels.

Before following a link, entering access credentials, or confirming a transaction, it is recommended that the User verify the authenticity of the relevant website, application, message, or sender’s account.

The Company’s employees and representatives do not request from the User the password or the full two-factor authentication code.

8.4. Before confirming a transaction, it is recommended that the User additionally verify:e

the name and designation of the crypto-asset;
the selected blockchain network;
the presence of the relevant crypto-asset and blockchain network in the list of those supported by the Company;
the crypto-wallet address of the sender or recipient;
the amount of the crypto-asset to be transferred;
the additional identifier, tag, memo, or other mandatory detail;
the applicable fees and the expected transaction confirmation time;
the consistency of all displayed parameters with the User’s original intent.

The crypto-wallet address is recommended to be checked immediately before confirming the transaction, including after it has been copied and pasted, since malicious software may substitute the copied address.

8.5. When making the first transfer to a new crypto-wallet address, using a new blockchain network, or transferring a significant amount of crypto-assets, it is recommended that the User, if it is economically and technically feasible, first make a test transaction for a small amount of the crypto-asset.

Successful execution of a test transaction does not eliminate the need to re-check the details when making a subsequent transaction.

8.6. When using an external non-custodial crypto-wallet, it is recommended that the User:

store private keys and the secret recovery phrase in a secure place that excludes access by third parties;
not store private keys and the secret recovery phrase in plain text on the device, in email, cloud storage, or a messaging service;
not disclose private keys and the secret recovery phrase to third parties, including persons representing themselves as employees of the Company;
use software and hardware devices only from official and trusted sources;
ensure in advance the possibility of restoring access to the external crypto-wallet.

Loss of a private key or secret recovery phrase from an external non-custodial crypto-wallet may lead to a complete and irretrievable loss of access to the crypto-assets held on it. The Company does not have the technical ability to restore such data or access to an external crypto-wallet.

8.7. It is recommended that the User exercise special caution when receiving offers:

of guaranteed or unusually high returns;
to transfer crypto-assets to receive remuneration, unblock funds, or verify an account;
to pay a tax, fee, insurance premium, or other payment to an unknown person’s external crypto-wallet;
to participate in an investment project, financial pyramid, giveaway, or get-rich-quick scheme;
to transfer access credentials or install a remote device management program;
to urgently perform a transaction under the threat of blocking, a fine, loss of funds, or the occurrence of other adverse consequences.

Promises of guaranteed profit, demands for an urgent transfer of crypto-assets, refusal to provide verifiable information, and pressure on the User may be signs of fraud.

8.8. Before acquiring a crypto-asset or participating in a project, it is recommended that the User independently verify:

information about the issuer, developers, and other related persons;
the purpose and technical characteristics of the crypto-asset;
the unique technical identifier of the crypto-asset, if applicable;
the terms of issuance, circulation, and possible redemption of the crypto-asset;
information about the liquidity and availability of the crypto-asset;
the presence of reports of fraud, hacks, technical vulnerabilities, or restrictions;
the legal status of the relevant crypto-asset and the intended transaction.

The placement of information about a project on social networks, messengers, mass media, or well-known internet resources does not in itself confirm the reliability or legality of such a project.

8.9. It is recommended that the User:

use the services of providers operating on legal grounds and holding the necessary licenses or permits, if their availability is required by applicable legislation;
not use services intended to conceal the origin, sender, recipient, or movement of crypto-assets;
avoid receiving crypto-assets from unknown persons in the absence of a clear and lawful basis for the transaction;
retain documents and information confirming the acquisition, receipt, and origin of crypto-assets;
verify information about the counterparty and the purpose of the transaction to the extent of available information;
refuse to carry out a transaction if there are reasonable doubts regarding its legality, economic substance, or the origin of the crypto-assets.

8.10. Upon discovery of a suspicious transaction, unauthorized access, substitution of details, possible fraud, or other circumstances that may entail the loss of crypto-assets, it is recommended that the User:

immediately cease the execution of the transaction;
not transfer additional information, documents, confirmation codes, or crypto-assets to third parties;
if technically possible, change the account access credentials;
contact the Company’s support service through official communication channels;
if there are signs of unlawful actions, contact the relevant competent authorities.

8.11. The Company’s support service may provide the User with information on the procedure for using the Platform, supported crypto-assets and blockchain networks, the status of a transaction, and the applicable procedures of the Company.

Contacting the support service does not constitute investment, financial, tax, or legal advice and does not relieve the User of the independent assessment of risks and making a decision to conduct a transaction.

9 FINAL PROVISIONS
9.1. This Policy applies jointly with the Company’s Public Offer and is effective for the duration of the contractual relationship between the Company and the User.

The current version of this Policy is posted on the Company’s official website and is available to the User.

9.2. The Company is entitled to make amendments and supplements to this Policy, including in connection with:

changes in the legislation of the Republic of Uzbekistan and law enforcement practice;
changes in the requirements of authorized state bodies;
changes in the list, content, or procedure for providing the Company’s services;
changes in the composition of supported crypto-assets and blockchain networks;
the development of blockchain technologies, software, and information systems;
the emergence of new or changes to previously identified risks;
changes to the Company’s internal procedures;
the need to enhance the level of protection of the rights and legitimate interests of Users and the Company;
other circumstances affecting the content of the risks disclosed to Users.

9.3. The new version of this Policy shall be posted on the Company’s official website and shall enter into force on the date specified in such version.

9.4. The User’s acceptance of the Company’s Public Offer extends to the current version of this Policy.

Continued use of the Company’s services after the new version of this Policy enters into force signifies the User’s familiarization with such version and consent to its application in accordance with the procedure provided for by the Company’s Public Offer.

The User shall independently monitor the current version of this Policy posted on the Company’s official website.

9.5. If the User does not agree with the new version of this Policy, the User shall cease using the Company’s services and is entitled to terminate the contractual relationship with the Company in accordance with the procedure provided for by the Company’s Public Offer.

The User’s disagreement with the new version of this Policy does not release the User from the performance of obligations that arose prior to the termination of the contractual relationship with the Company.

9.6. If any provision of this Policy is held invalid, illegal, or unenforceable, this shall not entail the invalidity of the remaining provisions.

The invalid or unenforceable provision shall be applied to the maximum extent permitted by the legislation of the Republic of Uzbekistan or shall be replaced by a provision closest in meaning and legal purpose.

9.7. Matters not regulated by this Policy shall be governed by the Company’s Public Offer and the legislation of the Republic of Uzbekistan.

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The exclusive rights to the original content, structure and design of this document belong to JV LLC “City Pay Gate”. Any full or partial reproduction, copying, adaptation, distribution, publication or other use of this document without the prior written consent of JV LLC “City Pay Gate” is prohibited, except as expressly provided by the legislation of the Republic of Uzbekistan. Any infringement of these exclusive rights shall entail liability in accordance with the legislation of the Republic of Uzbekistan.