Terms and Conditions

These Terms and Conditions ("Terms") govern your access to and use of the XEBT website, mobile or web applications, platform, accounts, wallets, payment services, digital asset services, card-related services and other products or services made available by XEBT from time to time (collectively, the "Services").

The Services are provided by XEBT Pay Inc., a company incorporated in Canada and operating under the XEBT brand ("XEBT", "we", "us" or "our").

By registering for an account, accessing the XEBT platform or using any of the Services, you confirm that you have read, understood and agreed to be bound by these Terms and any additional terms applicable to a particular Service.

If you do not agree with these Terms, you must not access or use the Services.

1. About XEBT

XEBT is a financial technology platform providing eligible individuals and businesses with access to payment, foreign exchange, digital asset and related financial technology services.

Depending on your location, eligibility and the Services made available to you, XEBT may facilitate:

• Fiat account and wallet functionality;
• Receiving and sending fiat payments;
• Domestic and cross-border payments;
• Multi-currency balances;
• Foreign exchange;
• Digital asset wallets and related custody functionality;
• Digital asset transfers;
• Fiat-to-digital-asset and digital-asset-to-fiat conversion;
• Supported digital asset exchange functionality;
• Payment card services; and
• Other payment and financial technology services made available through the XEBT platform.

XEBT is not a bank.

Certain Services may be provided, facilitated or supported through third-party banks, financial institutions, payment service providers, card issuers, card networks, custodians, liquidity providers, digital asset infrastructure providers and other regulated or authorized service providers.

The availability and structure of each Service may differ depending on the user's jurisdiction, account type, eligibility, currency, digital asset and applicable regulatory requirements.

2. Regulatory Status

XEBT Pay Inc. is registered as a Money Services Business ("MSB") with the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC").

XEBT maintains an anti-money laundering and anti-terrorist financing ("AML/ATF") compliance framework designed to meet applicable obligations under Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA") and associated regulations.

Registration with FINTRAC does not constitute an endorsement, recommendation or approval of XEBT, XEBT Pay Inc., or its products or Services by FINTRAC.

Where XEBT is subject to additional payment-services regulatory requirements, including requirements applicable under Canada's Retail Payment Activities Act ("RPAA"), XEBT will comply with such requirements to the extent applicable to the relevant activities.

Nothing on the XEBT platform should be interpreted as representing XEBT as a bank, deposit-taking institution, investment dealer or other type of regulated financial institution unless XEBT expressly holds the relevant authorization.

3. Eligibility

To create and maintain an XEBT account, you must:

• Be at least 18 years old or the applicable age of majority in your jurisdiction;
• Have legal capacity to enter into a binding agreement;
• Be located or established in a jurisdiction in which the relevant Services are available;
• Provide complete, accurate and current information;
• Successfully complete all required identity, business and compliance verification;
• Use the Services only for lawful purposes; and
• Comply with these Terms and any additional product-specific terms.

For business accounts, the individual opening or operating the account must have authority to act on behalf of the relevant entity.

XEBT reserves the right to determine eligibility for its Services based on applicable laws, regulatory requirements, risk considerations, partner requirements and XEBT's internal policies.

4. Account Registration and Verification

You must provide the information and documentation requested by XEBT to establish and maintain your account.

Depending on the nature of the account, this may include:

• Personal identification information;
• Government-issued identification;
• Residential or business address;
• Contact information;
• Business registration documents;
• Directors and authorized representatives;
• Beneficial ownership information;
• Nature and purpose of the business relationship;
• Expected account activity;
• Source of funds;
• Source of wealth; and
• Other information reasonably required for legal, regulatory, compliance, fraud-prevention or risk-management purposes.

XEBT may use third-party service providers to verify information and conduct identity, business, fraud and financial crime checks.

You agree to keep your information accurate and up to date and to notify XEBT promptly of material changes.

5. AML, Sanctions and Financial Crime Compliance

XEBT maintains controls designed to prevent its Services from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud or other unlawful activity.

XEBT may conduct:

• KYC and KYB verification;
• Beneficial ownership verification;
• Customer risk assessments;
• Sanctions screening;
• Politically exposed person ("PEP") screening;
• Adverse information checks where appropriate;
• Transaction monitoring;
• Digital asset and blockchain analytics;
• Source-of-funds and source-of-wealth reviews;
• Enhanced Due Diligence ("EDD"); and
• Ongoing monitoring and periodic reviews.

You agree to provide information or documentation reasonably requested by XEBT in connection with these controls.

Where permitted or required by law, XEBT may delay, restrict, place under review, reject or refuse to process a transaction or may restrict or terminate an account where financial crime, sanctions, fraud, regulatory or other material risks are identified.

XEBT is not required to disclose confidential monitoring criteria, internal risk scores, investigation methods, reporting decisions or information that XEBT is legally prohibited from disclosing.

6. Fiat Accounts and Balances

Where available, XEBT may provide users with functionality to receive, hold, transfer, convert and withdraw supported fiat currencies.

Fiat account details or payment instructions made available through XEBT may be provided through XEBT's banking, payment or financial institution partners.

Such functionality does not mean that XEBT itself is a bank or that an XEBT balance constitutes a traditional bank deposit.

Users may only use account details provided through XEBT for permitted purposes and in accordance with any restrictions communicated through the platform.

XEBT may impose transaction limits, currency restrictions, funding restrictions or other controls where required for operational, compliance, partner or regulatory purposes.

7. Safeguarding of Fiat Funds

Where XEBT holds end-user fiat funds and safeguarding requirements apply, XEBT will maintain arrangements designed to safeguard those funds in accordance with applicable legal and regulatory requirements.

The precise safeguarding arrangement may depend on the relevant payment service, currency, jurisdiction and account structure.

XEBT will maintain records necessary to identify applicable end-user balances and distinguish customer funds from XEBT's corporate operating funds where required by law.

Unless expressly confirmed otherwise, funds accessible through XEBT should not be assumed to constitute bank deposits or to qualify for government deposit insurance.

Information regarding applicable safeguarding arrangements may be made available to users through the platform or relevant product documentation.

8. Payments and Transfers

XEBT may enable users to send and receive payments through supported payment methods and networks.

Payments may be subject to:

• Transaction limits;
• Currency availability;
• Recipient eligibility;
• Banking and payment-network operating hours;
• Compliance screening;
• Fraud controls;
• Partner requirements;
• Regulatory restrictions;
• Technical availability; and
• Additional information requirements.

XEBT may refuse or delay a payment where reasonably necessary for compliance, fraud prevention, security, operational or regulatory purposes.

You are responsible for verifying beneficiary and payment details before confirming a transaction.

XEBT is not responsible for losses resulting from incorrect payment information supplied by you, except where responsibility cannot legally be excluded.

9. Cross-Border Payments

XEBT may facilitate cross-border payments in supported countries, currencies and payment corridors.

The availability of a particular country or payment corridor does not mean that XEBT is independently licensed or authorized as a financial institution in every jurisdiction through which a transaction passes or in which a beneficiary is located.

Cross-border transactions may involve correspondent institutions, local payment providers, banking partners or other intermediaries.

Processing times may therefore vary depending on currency, destination, intermediary institutions, regulatory screening, operating hours and other circumstances.

Any estimated settlement or processing time is indicative unless expressly guaranteed in writing.

10. Foreign Exchange

XEBT may provide or facilitate conversion between supported fiat currencies.

Before confirming an exchange transaction, users may be shown the applicable exchange rate, fees or other relevant transaction information.

Foreign exchange rates may change between quotation and execution where a rate has not been expressly locked or guaranteed.

XEBT may obtain liquidity or execution services through third-party providers.

XEBT does not guarantee that its exchange rate will be identical to rates displayed by banks, market-data providers or other financial services.

11. Digital Asset Services

XEBT may support certain digital assets and blockchain networks.

Available Services may include:

• Receiving supported digital assets;
• Holding supported digital assets;
• Sending supported digital assets;
• Digital asset wallet functionality;
• Fiat-to-digital-asset conversion;
• Digital-asset-to-fiat conversion; and
• Conversion between supported digital assets where available.

XEBT determines which digital assets and blockchain networks it supports and may add, restrict, suspend or discontinue support where reasonably necessary.

Support for a digital asset does not constitute an endorsement, recommendation or representation regarding its value, stability, legality or suitability.

12. Digital Asset Custody and Wallet Infrastructure

Digital asset wallet and custody functionality may be provided using XEBT infrastructure and/or specialized third-party custody, wallet or blockchain technology providers.

Users acknowledge that digital asset services involve risks associated with blockchain technology, private-key infrastructure, smart contracts, network congestion, protocol changes, forks and other technical events.

XEBT may temporarily suspend deposits, withdrawals or transfers where reasonably necessary due to:

• Blockchain maintenance;
• Network congestion;
• Security incidents;
• Protocol changes or forks;
• Custody-provider maintenance;
• Compliance reviews;
• Sanctions requirements; or
• Other circumstances affecting safe processing.

Users must ensure that the correct wallet address, blockchain network, token and other transaction information are selected before submitting a transfer.

Digital asset transfers may be irreversible once broadcast or confirmed on the relevant blockchain.

Sending an unsupported asset, using an unsupported network or providing an incorrect wallet address may result in permanent loss of assets.

13. Digital Asset Risks

Digital assets may experience significant price volatility.

You acknowledge that:

• Digital asset values can increase or decrease rapidly;
• A digital asset may lose some or all of its value;
• Liquidity may become limited;
• Blockchain transactions may be irreversible;
• Network fees may fluctuate;
• Blockchain networks may experience delays or disruptions;
• Regulatory treatment may change; and
• Third-party issuers or protocols may fail.

XEBT does not guarantee the value, stability, liquidity or future performance of any digital asset.

Unless expressly stated otherwise, XEBT does not provide investment, financial, tax or legal advice.

14. Stablecoins

XEBT may support stablecoins or other digital assets designed to maintain a reference value.

Stablecoins supported by XEBT may be issued by independent third-party issuers.

XEBT does not issue or guarantee a third-party stablecoin merely because that asset is supported on the XEBT platform.

The reserves, redemption arrangements, terms, financial condition and regulatory obligations associated with a third-party stablecoin remain subject to the relevant issuer's arrangements and applicable law.

Users should review the relevant issuer's terms and risk disclosures before using a stablecoin.

15. Travel Rule and Transfer Information

For certain fiat and digital asset transfers, XEBT may be legally required to collect, verify, retain, transmit or receive information concerning the originator, beneficiary and transaction.

You authorize XEBT to process and, where legally required, transmit such information to relevant financial institutions, virtual asset service providers, payment providers or other transaction participants.

XEBT may delay, reject or request additional information concerning a transfer where required information is incomplete or where processing the transaction could result in a breach of applicable law or regulatory requirements.

16. Card Services

Where available, XEBT may provide access to physical or virtual payment card functionality.

Cards may be issued or supported by an authorized third-party card issuer, programme manager, processor or payment network.

Card Services may therefore be subject to separate:

• Cardholder terms;
• Issuer requirements;
• Fees;
• Spending limits;
• Geographic restrictions;
• Merchant restrictions;
• ATM limits;
• Foreign exchange charges; and
• Card-network rules.

Where separate cardholder terms apply, you must accept those terms before using the relevant Card Service.

XEBT does not represent itself as the issuing bank unless XEBT is expressly identified as the issuer of the relevant card.

XEBT or the relevant card provider may restrict or decline transactions where required for fraud prevention, sanctions, compliance, security or other legitimate reasons.

17. Third-Party Service Providers

XEBT relies on third parties to provide or support certain aspects of the Services.

These may include:

• Banks and financial institutions;
• Payment processors;
• Payment networks;
• Card issuers and processors;
• Custody and wallet infrastructure providers;
• Blockchain networks;
• Liquidity providers;
• Identity-verification providers;
• Compliance and blockchain analytics providers; and
• Technology and infrastructure providers.

The use of third-party infrastructure does not necessarily create a contractual relationship between you and each infrastructure provider.

Where a third-party service requires separate terms, those terms will apply to your use of that service.

XEBT remains responsible for its obligations under applicable law but is not responsible for events outside its reasonable control, subject to any rights or liabilities that cannot lawfully be excluded.

18. Fees and Charges

Fees may apply to the Services.

These may include:

• Transfer fees;
• Foreign exchange fees or spreads;
• Digital asset transaction fees;
• Blockchain network fees;
• Card-related fees;
• Withdrawal fees; and
• Other fees disclosed in connection with a Service.

Applicable XEBT fees will be disclosed through the platform, fee schedule or relevant transaction interface.

Third-party institutions, intermediary banks, card networks or blockchain networks may impose additional charges outside XEBT's control.

Where permitted, you authorize XEBT to deduct applicable fees from your available balance.

19. Transaction Limits

XEBT may establish limits for deposits, payments, withdrawals, foreign exchange, digital asset transfers, card transactions or other Services.

Limits may vary according to:

• Customer type;
• Verification level;
• Customer risk profile;
• Transaction type;
• Currency or asset;
• Jurisdiction;
• Regulatory requirements; and
• Third-party provider requirements.

XEBT may modify applicable limits where reasonably necessary.

20. Prohibited and Restricted Activities

You must not use XEBT to engage in unlawful, fraudulent, abusive or prohibited activities.

Prohibited activities include, without limitation:

• Money laundering;
• Terrorist financing;
• Proliferation financing;
• Sanctions evasion;
• Fraud or scams;
• Transactions involving proceeds of crime;
• Unauthorized or unlawful financial services;
• Circumvention of regulatory controls;
• Market manipulation or other unlawful trading activity;
• Unauthorized access to another person's account;
• Use of XEBT to facilitate prohibited goods or services; or
• Any activity prohibited under applicable law.

Certain industries, countries, assets, merchants, counterparties or transaction types may also be restricted under XEBT's risk-management framework.

XEBT may update its restrictions as laws, sanctions requirements and financial crime risks evolve.

21. Transaction Monitoring and Reviews

Transactions may be monitored using automated systems, manual reviews or a combination of both.

Where a transaction requires additional review, XEBT may request information including:

• Purpose of transaction;
• Source of funds;
• Source of wealth;
• Relationship with the counterparty;
• Supporting invoices or agreements;
• Evidence concerning a wallet or digital asset transaction; or
• Other documentation reasonably required to complete the review.

Processing may be delayed while a review is conducted.

XEBT does not guarantee that a transaction will be approved merely because similar transactions were previously processed.

22. Account Security

You are responsible for maintaining the confidentiality and security of your:

• Passwords;
• Authentication credentials;
• Devices;
• Security keys;
• One-time passwords; and
• Other account-security information.

You must notify XEBT promptly if you suspect unauthorized access, credential compromise, fraud or an unauthorized transaction.

You must not share your account with another person or permit unauthorized persons to access the Services.

XEBT may implement additional authentication or security controls where necessary.

23. Instructions and Authorized Users

XEBT may rely on instructions submitted through your authenticated account.

For business accounts, you are responsible for ensuring that only properly authorized representatives are granted access.

You are responsible for managing user permissions and notifying XEBT promptly when an authorized person's authority changes or ends.

XEBT may require additional authorization for certain high-risk or material transactions.

24. Errors and Unauthorized Transactions

You should review your transaction history regularly.

You must notify XEBT promptly if you identify:

• An unauthorized transaction;
• An incorrect transaction;
• A duplicate transaction;
• An incorrect balance; or
• Other suspected account error.

XEBT will review reported issues in accordance with applicable law, relevant payment-network rules and any applicable product-specific terms.

25. Suspension, Restriction and Termination

XEBT may restrict, suspend or terminate an account or particular Service where reasonably necessary because of:

• A breach of these Terms;
• Suspected fraud;
• Financial crime concerns;
• Sanctions exposure;
• Legal or regulatory requirements;
• Security concerns;
• Failure to provide requested information;
• Material misrepresentation;
• Abuse of the Services;
• Third-party provider requirements;
• Unacceptable risk; or
• Discontinuation of a product or Service.

Where legally and operationally permitted, XEBT will provide appropriate information concerning the restriction or termination.

XEBT may be prohibited from providing certain information where doing so would violate applicable law or compromise a regulatory or financial crime investigation.

26. Account Closure

You may request closure of your account subject to:

• Completion of pending transactions;
• Settlement of outstanding fees or liabilities;
• Resolution of compliance reviews;
• Applicable legal restrictions; and
• Any required retention of funds or records.

Closing an account does not affect rights, obligations or liabilities arising before closure.

XEBT may retain records after account closure where required by law.

27. Records

XEBT may maintain records relating to:

• Customer identification and verification;
• Account activity;
• Transactions;
• Beneficiaries and counterparties;
• Compliance reviews;
• Communications;
• Digital asset transfers;
• Payment instructions; and
• Other information required by applicable law.

Records will be retained for applicable statutory and regulatory retention periods.

28. Privacy and Personal Information

XEBT processes personal information in accordance with its Privacy Policy and applicable privacy and data-protection requirements.

Information may be processed for purposes including:

• Providing the Services;
• Identity and business verification;
• Payment processing;
• Fraud prevention;
• AML/ATF compliance;
• Sanctions screening;
• Transaction monitoring;
• Regulatory reporting;
• Security;
• Customer support; and
• Compliance with legal obligations.

Where necessary to provide the Services, information may be shared with service providers, financial institutions, payment providers, card providers, custodians or competent authorities in accordance with applicable law.

Please review the XEBT Privacy Policy for further information.

29. Intellectual Property

All rights in the XEBT platform, website, applications, trademarks, logos, software, designs, text and other proprietary materials belong to XEBT Pay Inc. or its licensors unless otherwise stated.

You receive a limited, revocable, non-exclusive and non-transferable right to use the platform solely for accessing the Services in accordance with these Terms.

You must not copy, reverse engineer, reproduce, distribute, modify or commercially exploit XEBT's intellectual property except where expressly permitted by law.

30. Service Availability

XEBT aims to provide reliable Services but does not guarantee uninterrupted availability.

Services may be interrupted or delayed because of:

• Scheduled maintenance;
• Technical failures;
• Cybersecurity events;
• Banking outages;
• Payment-network disruptions;
• Blockchain-network conditions;
• Third-party provider outages;
• Regulatory requirements;
• Force majeure events; or
• Other circumstances outside XEBT's reasonable control.

Where reasonably practicable, XEBT will seek to restore affected Services as soon as possible.

31. No Investment Advice

Unless expressly agreed otherwise in writing, information provided through XEBT is for informational and transactional purposes only.

XEBT does not provide investment, legal, accounting or tax advice.

Nothing displayed through the platform should be interpreted as a recommendation to purchase, sell, hold or transact in a particular digital asset, currency or financial product.

You are responsible for evaluating whether a transaction or asset is appropriate for your circumstances.

32. Limitation of Liability

To the maximum extent permitted by applicable law, XEBT will not be liable for indirect, incidental, special, consequential or punitive losses arising from use of the Services.

XEBT will not be responsible for losses resulting solely from circumstances outside its reasonable control, including blockchain failures, telecommunications failures, third-party infrastructure outages or incorrect transaction information provided by a user.

Nothing in these Terms excludes or limits liability where such exclusion or limitation is prohibited by applicable law, including liability arising from fraud, wilful misconduct or other liability that cannot legally be excluded.

33. Indemnification

To the extent permitted by applicable law, you agree to indemnify XEBT Pay Inc. against reasonable losses, liabilities, claims and expenses arising directly from:

• Your material breach of these Terms;
• Your unlawful use of the Services;
• Fraudulent activity conducted through your account; or
• Your infringement of the rights of another person.

This provision does not apply to losses caused by XEBT's own breach, negligence, wilful misconduct or other circumstances for which liability cannot legally be excluded.

34. Complaints

If you have a complaint regarding XEBT or the Services, please contact:

• XEBT Customer Support Email: support@xebt.com

Complaints will be reviewed in accordance with XEBT's applicable complaint-handling procedures.

Where applicable, users may also have rights to submit complaints to an appropriate regulatory, consumer-protection or dispute-resolution authority.

Nothing in these Terms prevents a user from exercising any statutory complaint or consumer right available under applicable law.

35. Communications

You agree that XEBT may communicate with you electronically regarding your account and the Services.

Communications may include:

• Transaction notifications;
• Security alerts;
• Regulatory notices;
• Changes to these Terms;
• Account notices;
• Service updates; and
• Other legally required communications.

You are responsible for maintaining accurate contact information.

36. Changes to the Services

XEBT may add, modify, suspend or discontinue a Service where reasonably necessary due to business, technical, security, regulatory or third-party provider considerations.

Where a material change adversely affects existing users, XEBT will provide notice where required by applicable law or contractual obligations.

37. Changes to These Terms

XEBT may update these Terms periodically to reflect:

• Changes in applicable law;
• Regulatory requirements;
• New products or Services;
• Changes to existing Services;
• Security requirements;
• Changes to third-party arrangements; or
• Other legitimate business requirements.

Where required, XEBT will provide reasonable notice of material changes.

The effective date of the latest version will be displayed at the beginning of these Terms.

38. Assignment

You may not transfer or assign your rights or obligations under these Terms without XEBT's prior written consent.

XEBT may assign or transfer its rights and obligations in connection with a merger, acquisition, corporate restructuring, sale of business or similar transaction, subject to applicable law and regulatory requirements.

39. Severability

If any provision of these Terms is determined to be invalid, unlawful or unenforceable, the remaining provisions will continue in full force and effect to the extent permitted by law.

40. No Waiver

If XEBT does not immediately enforce a provision of these Terms, this does not constitute a waiver of XEBT's right to enforce that provision later.

41. Entire Agreement

These Terms, together with the Privacy Policy and any product-specific terms, cardholder terms, fee schedules or other terms expressly incorporated by reference, constitute the agreement governing your use of the relevant XEBT Services.

Where product-specific terms conflict with these general Terms, the product-specific terms will prevail in relation to that particular Service unless stated otherwise.

42. Governing Law and Jurisdiction

These Terms are governed by and construed in accordance with the laws of the Province of British Columbia and the applicable federal laws of Canada.

Subject to any mandatory consumer rights or jurisdictional protections that cannot lawfully be excluded, any dispute arising out of or relating to these Terms or the Services shall be subject to the jurisdiction of the courts of British Columbia, Canada.

43. Contact Information

For questions regarding these Terms or the XEBT Services, please contact:

XEBT Pay Inc. Operating as XEBT

Registered Office: 1500 West Georgia, Suite 1300, Vancouver, British Columbia, V6G 2Z6, Canada

• Customer Support: support@xebt.com
• Compliance Enquiries: compliance@xebt.com
• Website: xebt.com

AML & Compliance

Our Commitment

XEBT is committed to maintaining high standards of financial crime compliance and protecting its platform from misuse for money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion and other illicit financial activities.

Our compliance framework applies a risk-based approach and is designed to meet applicable Canadian anti-money laundering and counter-terrorist financing requirements.

Regulatory Framework

XEBT Pay Inc., operating under the XEBT brand, is a Canadian Money Services Business (MSB) registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

XEBT's AML/CTF compliance framework is designed to comply with applicable requirements under Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations.

Registration with FINTRAC does not constitute an endorsement or approval of XEBT, XEBT Pay Inc., or its products and services by FINTRAC.

Customer Due Diligence

XEBT applies customer identification and due diligence measures appropriate to the nature and risk of the customer relationship.

These measures may include:

• Identity verification and Know Your Customer (KYC) checks
• Know Your Business (KYB) and beneficial ownership verification
• Sanctions and politically exposed person (PEP) screening
• Risk-based customer assessments
• Enhanced Due Diligence (EDD) where higher risks are identified
• Ongoing customer and transaction monitoring
• Periodic or event-driven reviews

XEBT may request additional information or supporting documentation where required to meet legal, regulatory or risk-management obligations.

Transaction & Digital Asset Monitoring

Transactions conducted through XEBT may be subject to automated and manual monitoring designed to identify unusual, suspicious or potentially prohibited activity.

Where digital assets are involved, XEBT may use blockchain analytics and other risk-assessment tools to identify exposure to sanctions, illicit activity and other financial crime risks.

Transactions may be delayed, restricted, rejected or subject to additional review where necessary to comply with applicable laws, sanctions requirements, regulatory obligations or XEBT's financial crime controls.

Sanctions Compliance

XEBT maintains controls designed to comply with applicable sanctions and restrictive-measures requirements.

Customers, counterparties, transactions and digital asset addresses may be screened against applicable sanctions lists and other relevant risk indicators.

XEBT does not knowingly facilitate transactions involving sanctioned persons, entities, jurisdictions or prohibited activities.

Suspicious Transaction Reporting

Where XEBT identifies activity that gives rise to reasonable grounds for suspicion of money laundering, terrorist financing or other reportable financial crime, the matter may be reported to the appropriate authority in accordance with applicable law.

XEBT does not disclose whether a specific transaction, customer or activity has been or will be reported to a competent authority where such disclosure is prohibited by law.

Record Keeping

XEBT maintains records relating to customer identification, transactions, compliance reviews and other regulatory requirements for the periods required under applicable laws and regulations.

Records are maintained with appropriate security and access controls.

Restricted & Prohibited Activity

XEBT does not permit its services to be used for unlawful or prohibited purposes. Access to certain products, services, assets or jurisdictions may be restricted based on applicable law, regulatory requirements, sanctions obligations and XEBT's risk-management framework.

XEBT reserves the right, subject to applicable law and contractual terms, to request additional information, restrict services, reject transactions or terminate relationships where necessary to meet its legal, regulatory or financial crime compliance obligations.

Compliance Governance

XEBT's AML/CTF framework is supported by designated compliance oversight, documented policies and procedures, risk assessments, employee training, monitoring controls, regulatory reporting processes and periodic reviews of the effectiveness of the compliance programme.

The framework is reviewed and updated as appropriate to reflect regulatory developments, changes to XEBT's products and services, emerging financial crime risks and changes to the business.

Contact

Questions relating to XEBT's AML and compliance framework may be directed to:

Compliance Team
XEBT Pay Inc

• Email: compliance@xebt.com

This page provides a general overview of XEBT's AML and financial crime compliance framework. It does not constitute legal advice and does not describe all internal compliance controls, procedures or regulatory obligations.

Cookie Policy

Introduction

This Cookie Policy explains how XEBT uses cookies, pixels, SDKs, local storage, device identifiers, and similar technologies on xebt.com and related services.

1. What Are Cookies?

Cookies are small files or identifiers stored on your browser or device. They help websites remember information, operate securely, measure performance, personalize content, and understand how services are used.

2. Types of Cookies We Use

3. Managing Cookies

You can manage cookies through our cookie banner or your browser settings. Blocking some cookies may affect login, security verification, payments, compliance checks, or other platform functionality.

Strictly necessary and security cookies may be required to provide the service.

4. Third-Party Cookies

Some service providers may use cookies or similar technologies when providing analytics, security, identity verification, support, payment, marketing, or infrastructure services.

We require service providers to handle data in accordance with contractual obligations and applicable law.

5. Updates

We may update this Cookie Policy as technologies, vendors, laws, or services change. The "Last Updated" date indicates when this policy was most recently revised.

REGULATORY INFORMATION

XEBT Pay Inc. is a Canadian Money Services Business registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), MSB Registration No. C100000372.

XEBT Pay Inc. is also registered as a Payment Service Provider under Canada's Retail Payment Activities Act (RPAA) and is subject to applicable regulatory requirements administered by the Bank of Canada.

Registered office: 1500 West Georgia, Suite 1300, Vancouver, British Columbia, V6G 2Z6, Canada.

Registration with FINTRAC or the Bank of Canada does not constitute an endorsement of XEBT Pay Inc. or its products and services.