Terms of Use

Effective Date - 20 January, 2026

Last Updated - 30 March, 2026

These TERMS OF USE (the “Terms”) establish the legal framework governing access to and use of the Axora platform, a technology/API brand owned by Axora Payments LLC, Delaware, USA (“Axora”, “Platform”, “we”, “us”, “our”), services, and application programming interfaces (APIs). The Platform serves as a technology infrastructure layer that provides modular APIs for ledger and sub-account mapping, know-your-customer (KYC) and anti-money laundering (AML) orchestration, wallet management, and integration with banking and financial services partners.

By accessing, using, or integrating with the Platform, application programming interfaces, website, or any related services (collectively, the “Services”), the Users (“Users”, “you”, your”) acknowledge that you have read, understood, and agree to be bound by these Terms. If you do not agree to these Terms, you must immediately cease use of the Services. These Terms apply to all users, including but not limited to authorized business partners, licensees, API integrators, and customer-facing platforms that leverage Axora's technology infrastructure.

Axora and Users shall be referred to as “Parties” collectively, and “Party” individually.

Definitions

For the purposes of these Terms, the following terms shall have the meaning as set forth below:

“Axora”, “we”, “us”, or “our” refers to Axora Payments LLC, a company incorporated in Delaware, USA. Where regulated financial services are delivered through licensed affiliated entities, including Codepulse Innovations Sp. z o.o. (Poland), Nova Fintech LLC (USA), or Nova Financial Tech Ltd. (Canada), those entities operate independently under their own terms, licences, and regulatory frameworks and are not party to these Terms. References in these Terms to "licensed affiliates" or "regulated entities" refer to such entities in their separate capacity as independent licensed service providers.

“Platform” or “Services” refers to the Axora technology infrastructure, including but not limited to the API gateway, ledger management systems, wallet infrastructure, KYC/AML orchestration tools, virtual sub-account mapping, and related technical services provided to business customers.

“User”, “Customer”, “you”, or “your” refers to any business entity, financial services provider, licensed operator, partner, or authorized representative that accesses, integrates with, or uses the Services under a commercial or API arrangement with Axora.

“Content” refers to any data, information, code, documentation, transaction details, or other materials provided by or generated through the Services.

“Confidential Information” refers to all non-public information disclosed by one party to the other in connection with these Terms, including but not limited to technical specifications, business processes, financial information, and proprietary methodologies.

“Data Subject” refers to any natural person whose personal data is processed through the Services, including but not limited to retail customers, corporate clients, authorized signers, ultimate beneficial owners (UBOs), and vendors.

Scope Of Services

Axora provides technology infrastructure and middleware services designed to support financial services operations across multiple jurisdictions, including the European Union, United Kingdom, United States, and Canada. The Services are provided on a business-to-business (B2B) basis and are not intended for direct retail consumer use.

The Services Specifically Include, But Are Not Limited To

Application programming interfaces for ledger and transaction management;

Virtual sub-account creation and mapping; know-your-customer (KYC) and anti-money laundering (AML) orchestration and integration;

Wallet infrastructure and management;

Settlement and transaction processing support;

Integration with banking partners and electronic money institution (EMI) providers;

Cross-border payment facilitation; and

Compliance monitoring and reporting functionalities.

Axora operates as a technology provider and does not itself provide regulated financial services, hold customer funds, or directly onboard retail users.

The Services are designed to be integrated with and support licensed financial entities, regulated money services businesses, and other compliance-approved partners.

All end-user interactions and regulated service delivery occur through our licensed affiliates and partners, including Codepulse Innovations Sp. z o.o. (a registered Virtual Asset Service Provider in Poland) and regulated entities in other target jurisdictions.

Liquidity and Settlement Infrastructure: Where the Services include liquidity management or settlement support functionality:

Axora provides ONLY the technology infrastructure for routing, allocation, and settlement processing;

Actual custody, execution, and regulatory authorization for such services reside exclusively with licensed entities (Codepulse/Nova Fintech);

Any references to "liquidity pools," "settlement balances," or similar terminology refer to ledger management functionality provided by Axora's technology, NOT to funds or assets held by Axora;

The licensed entity (Codepulse/Nova Fintech) maintains exclusive custody and control of all digital assets and fiat currency; and

Axora's role is limited to providing the technical infrastructure that enables the licensed entity to perform regulated activities.

Nature Of Services

Axora is a financial technology and infrastructure platform providing software, orchestration, and compliance tooling for regulated financial service providers. Axora acts solely as a technology and infrastructure service provider.

No Regulated Financial Services

Axora Does Not

(a) Provide regulated financial services of any kind;

(b) Offer custody of funds, fiat currency, or digital assets;

(c) Execute financial transactions on its own behalf;

(d) Hold itself out as a Virtual Asset Service Provider (VASP), Crypto-Asset Service Provider (CASP), Electronic Money Institution (EMI), bank, payment service provider (PSP), or money services business (MSB).

Regulatory Responsibility

All regulated financial services including customer onboarding, custody of assets, transaction execution, and compliance decision-making are performed exclusively by appropriately licensed financial institutions, including but not limited to:

Codepulse Innovations Sp. z o.o. (Poland) - registered Virtual Asset Service Provider under Polish VASP regulations and MiCA framework;

Nova Fintech LLC (Montana, USA) - registered Money Services Business;

Nova Financial Tech Ltd. (Canada) - registered with FINTRAC; and

Other authorized banking, EMI, or payment service partners as applicable to specific jurisdictions.

Fiat Account and Payment Services

All fiat account services, payment processing, and fund settlement are provided by licensed banks, electronic money institutions (EMIs), or payment service providers (PSPs) contracted by the relevant regulated entity. Axora does not hold, process, or settle fiat currency on its own behalf.

User Acknowledgment

By Accessing Or Using The Services, You Acknowledge And Agree That

You understand Axora's role as a technology provider only;

Your contractual relationship for regulated services is with the applicable licensed entity, not with Axora;

Axora's liability is limited to the technology services it provides; and

You will look solely to the licensed entity for matters relating to custody, fund safety, regulatory compliance, and financial service delivery.

Eligibility And Authorization

By using the Services, you represent and warrant that you are duly authorized to enter into these Terms on behalf of your organization, that your organization is in good legal standing, and that you possess the legal capacity to bind your organization to these Terms.

You represent that you are not incorporated, organized, or resident in any jurisdiction restricted by applicable international sanctions or export control regulations, and that your organization does not engage in or facilitate money laundering, terrorism financing, sanctions violations, or other illegal activities.

You represent that your organization does not operate in or conduct business with residents or entities from eighteen identified high-risk jurisdictions maintained on Axora's restricted markets list. If your organization's circumstances change, you must notify Axora immediately.

Business users must maintain valid business registration documents, tax identification numbers, and compliance certifications appropriate to their jurisdiction of operation.

If you are acting as an authorized representative of a financial services provider, you warrant that you have obtained all necessary internal authorizations to execute these Terms, and integrate the Services with your systems.

The Services are not available to, and may not be used on behalf of, retail consumers or end-users who are residents of the United States of America, regardless of nationality or citizenship. This restriction reflects the current licensing position of Axora's regulated affiliates. Business entities incorporated and operating in the United States may access the Services solely for B2B technology integration purposes and may not use the Services to onboard or serve US-resident retail consumers. If your organization's circumstances change such that US-resident retail consumer exposure arises, you must notify Axora immediately.

License And Use Of Services

Subject to your compliance with these Terms and applicable law, Axora grants you a limited, non-exclusive, non-transferable license to access and use the Services for your authorized business purposes. This license is granted for the duration of your engagement with Axora and may be terminated at any time in accordance with these Terms.

You May Not

Sublicense, resell, redistribute, lease, or otherwise make the Services available to unauthorized third parties without prior written consent from Axora;

Reverse-engineer, decompile, disassemble, or attempt to derive the source code, algorithms, or technical specifications underlying the Services; or

Remove, alter, or obscure any proprietary notices, labels, or marks contained within the Services or documentation.

Your use of the Services must comply with all applicable laws and regulations, including but not limited to anti-money laundering (AML), know-your-customer (KYC), sanctions screening, data protection, consumer protection, and financial services regulations in your jurisdiction of operation and in jurisdictions where data subjects reside.

You are solely responsible for obtaining all necessary licenses, permits, and regulatory approvals required to offer services using the Axora infrastructure.

Compliance And Regulatory Obligations

Axora operates under and complies with General Data Protection Regulation (GDPR), UK-GDPR, Personal Information Protection and Electronic Documents Act (PIPEDA), and California Consumer Privacy Act (CCPA), as applicable to the jurisdictions in which it operates.

As a user of the Services, you acknowledge and agree that your use must comply with all applicable anti-money laundering (AML), counter-terrorism financing (CTF), sanctions screening, and know-your-customer (KYC) requirements.

You agree to implement and maintain appropriate compliance controls, including but not limited to customer identification and verification, beneficial ownership verification, transaction monitoring, reporting of suspicious activities, and sanctions list screening.

Axora provides KYC/AML orchestration capabilities through integrated third-party service providers for identity verification, blockchain analytics, and transaction monitoring.

You acknowledge that final compliance determinations, customer acceptance or rejection, and transaction authorization decisions remain your responsibility or that of the licensed financial entity through which Services are being delivered.

You agree to implement and maintain comprehensive compliance policies addressing AML/CFT obligations, sanctions compliance, and data protection requirements. You agree to conduct periodic compliance audits and testing. You agree to maintain records of all transactions and compliance determinations as required by applicable law, for a minimum period of ten (10) years following transaction completion, or such longer period as may be required by applicable regulatory requirements in the relevant jurisdiction.

If Axora becomes aware of potential compliance violations, sanctions issues, or suspicious activity involving your use of the Services, we may immediately suspend or terminate your access to the Services, and may report such matters to relevant regulatory authorities as required by law.

Prohibited Uses

In addition to the restrictions set out elsewhere in these Terms, you may not use the Services to:

Facilitate, process, or enable transactions for or on behalf of any person or entity subject to applicable sanctions restrictions;

Process transactions involving proceeds of criminal activity, including fraud, theft, extortion, or any predicate offence under applicable AML law;

Circumvent, disable, or interfere with any security, compliance, or access control feature of the Services;

Introduce malicious code, viruses, or any software designed to disrupt, damage, or gain unauthorized access to Axora's systems or data;

Use the Services to provide financial services to retail consumers without holding the applicable regulatory authorization in the relevant jurisdiction;

Misrepresent your organization's identity, licensing status, or regulatory approvals to Axora or any third party in connection with the Services; or

Aggregate, scrape, mine, or otherwise extract data from Axora's platform or API infrastructure beyond what is strictly necessary for your authorized integration.

Axora reserves the right to immediately suspend or terminate access to the Services if it reasonably suspects a breach of any of the above restrictions, without liability to you.

Data Protection And Privacy

Axora processes personal data including identity information, transaction metadata, account details, and contact information necessary to deliver the Services. Your use of the Services constitutes acknowledgment that personal data will be processed in accordance with our Privacy Policy, and applicable data protection laws.

You grant Axora permission to collect, process, store, and share personal data as necessary to deliver the Services, including cross-border transfers. Where data is transferred internationally, including between the European Economic Area and the United States, Canada, or other jurisdictions, Axora implements Standard Contractual Clauses (SCCs), UK Addendum, or other appropriate legal mechanisms as required by law.

Axora engages third-party service providers (processors) to assist in delivering the Services. All processors are bound by written Data Processing Agreements (DPAs) incorporating appropriate security and confidentiality obligations. For a detailed list of processors, data retention practices, and international transfer mechanisms, please refer to our Privacy Policy or contact privacy@axorastack.com.

Intellectual Property Rights

We retain all intellectual property rights in the Services, Platform, APIs, documentation, code, tools, and any derivative works or improvements thereof. You acknowledge that you do not acquire any ownership interest in the Services through your use or integration.

All documentation, technical specifications, training materials, and other content provided by Axora are proprietary and confidential. You may use such materials only for purposes directly related to your authorized use of the Services. You may not copy, reproduce, modify, translate, or create derivative works based on such materials without prior written consent.

Any feedback, suggestions, or improvements you provide to Axora concerning the Services may be used by Axora for any purpose, including incorporation into future service enhancements, without compensation or attribution to you.

Fees And Payment Terms

We charge fees for access to and use of the Services according to the pricing model and fee schedule established in your individual service agreement or purchase order. Fees may be charged on a monthly, quarterly, or annual basis, or on a transaction-based model, as specified in your engagement terms.

You agree to pay all applicable fees in full within thirty (30) days of invoice date, unless alternative payment terms are specified in your service agreement. Payments must be made via the payment methods specified by Axora. If payment is not received by the due date, Axora may impose a late payment fee of up to two percent (2%) per month on the outstanding balance, or the maximum rate permitted by applicable law, whichever is lower.

All fees are exclusive of applicable sales taxes, value-added taxes (VAT), goods and services taxes (GST), or similar taxes. You are responsible for payment of all such taxes, or for providing valid tax exemption documentation if applicable.

We reserve the right to adjust fees upon thirty (30) days' prior written notice. If you do not accept revised fees, you may terminate your engagement in accordance with these Terms. Continued use of the Services after the effective date of a fee increase constitutes acceptance of the revised fees.

You explicitly authorize Axora to instruct its regulated affiliates to deduct applicable Transaction Fees, Platform Fees, and other agreed charges from your Settlement Balance held with such affiliates, in accordance with the fee schedule set out in your individual Order Form or Service Agreement. This authorization supplements and does not replace any separate deduction authority required under the terms of the applicable regulated entity.

In the event of any discrepancy between the balance displayed on the Axora Dashboard and the internal ledger maintained by the Regulated Entity (Codepulse/Nova Fintech), the records of the Regulated Entity shall serve as the final and authoritative record.

Access to financial settlement services is strictly conditioned upon your acceptance of and compliance with the Terms of Use of our regulated affiliates (Codepulse Innovations Sp. z o.o. or Nova Fintech LLC). A breach of the regulated entity's terms constitutes a material breach of these Terms.

Service Availability And Support

Axora strives to maintain continuous availability of the Services and endeavors to provide reliable, secure infrastructure. However, we do not guarantee uninterrupted service availability. The Services may be subject to scheduled maintenance, emergency maintenance, upgrades, or other system modifications that may cause temporary unavailability or degradation of service.

We will make reasonable efforts to provide advance notice of planned maintenance. Emergency maintenance to address security vulnerabilities or critical system failures may be undertaken without advance notice.

Support for the Services is provided during specified business hours via email and support channels designated by Axora. Response times and support level commitments, if any, shall be specified in your service agreement or support addendum. Standard technical support does not include custom development, integration assistance beyond documentation, or support for your systems or platforms that integrate with Axora.

Axora reserves the right to modify, update, enhance, or discontinue any feature, functionality, or component of the Services at any time, provided that:

Axora will use reasonable efforts to provide thirty (30) days' prior written notice of any material modification that materially reduces core functionality;

Emergency modifications required to address security vulnerabilities, regulatory requirements, or critical system integrity may be implemented without advance notice;

Where a modification materially and adversely affects your ability to use the Services, you may terminate your engagement with thirty (30) days' written notice, without penalty, provided such notice is given within thirty (30) days of the effective date of the modification.

Axora shall not be liable for any loss or damage arising from changes made to the Services in accordance with this clause.

Support for the Services is provided during standard business hours via email at operations@axorastack.com and support channels designated in your individual service agreement. Response times and support level commitments, if any, are specified in your service agreement or support addendum.

Limitation Of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, AXORA SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOST PROFITS, LOST REVENUE, LOST DATA, BUSINESS INTERRUPTION, OR COST OF SUBSTITUTE GOODS OR SERVICES, EVEN IF AXORA HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

AXORA'S TOTAL LIABILITY ARISING OUT OF OR RELATED TO THESE TERMS AND YOUR USE OF THE SERVICES SHALL NOT EXCEED THE TOTAL FEES PAID BY YOU TO AXORA IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO LIABILITY, OR IF NO FEES HAVE BEEN PAID, ONE THOUSAND USD ($1,000).

These limitations of liability shall not apply to either our or your liability for fraud, willful misconduct, gross negligence, or violations of applicable law that cannot be limited by contract, provided that they shall apply to the maximum extent permitted by applicable law.

Indemnification

You agree to indemnify, defend, and hold harmless Axora and its officers, directors, employees, and agents from and against any and all claims, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising out of or resulting from:

Your breach of these Terms or applicable law;

Your use of the Services in violation of applicable regulations or our instructions;

Your processing of data through the Services in violation of data protection laws or consumer protection regulations;

Claims by third parties alleging that your use of the Services infringes their intellectual property rights;

Your failure to obtain necessary licenses, permits, or regulatory approvals; or

Your engagement in money laundering, sanctions violations, terrorism financing, or other illegal activities.

Axora shall provide you with prompt written notice of any claim subject to indemnification and shall reasonably cooperate with you in defense of such claim. You shall have sole control of the defense and settlement, provided that you do not settle any claim in a manner that admits liability on behalf of Axora or imposes obligations on Axora without its prior written consent.

Representations And Warranties

By The User - You Represent And Warrant That

You have the legal authority to enter into these Terms;

Your organization is in good standing and duly organized under applicable law;

Your use of the Services shall comply with all applicable laws and regulations;

You will obtain all necessary internal approvals, licenses, and regulatory authorization before using the Services;

You will not use the Services for any illegal, fraudulent, or prohibited purpose; and

All information you provide to Axora is accurate and complete.

By Axora - We Represent And Warrant That

We have the right to enter into these Terms and grant the license herein;

The Services will be performed in a professional and workmanlike manner in accordance with industry standards; and

Axora will comply with all applicable laws, including data protection, anti-money laundering, and sanctions regulations.

Disclaimer Of Other Warranties

EXCEPT AS EXPRESSLY PROVIDED HEREIN, AXORA MAKES NO OTHER WARRANTIES, EXPRESS OR IMPLIED. THE SERVICES ARE PROVIDED ON AN “AS-IS” AND “AS-AVAILABLE” BASIS. AXORA DISCLAIMS ALL OTHER WARRANTIES, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, OR NON-INFRINGEMENT.

Confidentiality

Each party acknowledges that it may receive Confidential Information from the other party in connection with these Terms. Confidential Information shall be protected and used only for purposes directly related to this engagement. Each party agrees to maintain Confidential Information in strict confidence and to limit access to employees and authorized representatives who have a need to know.

Confidential Information Does Not Include Information That

Is or becomes publicly available through no breach of these Terms;

Was lawfully received by the receiving party prior to disclosure without a duty of confidentiality;

Is independently developed by the receiving party without access to Confidential Information; or

Is rightfully received by the receiving party from a third party without restriction on use.

Each Party may disclose Confidential Information to the extent required by applicable law, court order, or regulatory authority, provided that the disclosing party provides prompt notice to the other party to allow the other party to seek protective measures.

Termination

Termination for Convenience

Either party may terminate this engagement upon thirty (30) days' prior written notice to the other party.

Upon termination, you shall cease all use of the Services, and Axora shall cease providing Services to you.

Termination for Cause

Axora May Terminate Your Access To The Services Immediately, Without Notice, If

You violate any material provision of these Terms and do not cure such violation within ten (10) business days of written notice;

You engage in illegal activity, money laundering, sanctions violations, or terrorism financing;

Regulatory authorities direct Axora to terminate service;

You are incorporated or organized in, or conduct business with, a restricted or sanctioned jurisdiction; or

You breach any compliance representation or warranty.

Effect of Termination

Upon termination or expiration of these Terms, your license to use the Services immediately terminates. You shall promptly return or destroy all Confidential Information and shall cease all use of the Services.

Sections 6 (Data Protection), 7 (Intellectual Property), 10 (Limitation of Liability), 11 (Indemnification), 13 (Confidentiality), 16 (Dispute Resolution), and 17 (General Provisions) shall survive termination.

Data Retention And Destruction

Upon termination of your access to the Services, Axora shall retain your data (including transaction records, KYC/AML documentation, and compliance records) in accordance with applicable legal requirements for seven (7) to ten (10) years. Such data shall be retained for compliance, legal, and regulatory purposes and shall be protected in accordance with applicable data protection laws.

Axora shall not be obligated to destroy your data if retention is required by applicable law or regulatory authority directive. Any personal data retained shall be processed only for legally required purposes and shall be subject to appropriate security and confidentiality safeguards.

Dispute Resolution

Governing Law

These Terms shall be governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of law principles.

However, if your organization is incorporated or principally operates in the European Union, UK, or Canada, the data protection and compliance provisions of these Terms shall also be governed by the applicable regulations in your primary jurisdiction of operation, including GDPR, UK-GDPR, PIPEDA, or other applicable laws.

Jurisdiction and Venue

Each Party irrevocably consents to the exclusive jurisdiction and venue of the courts located in the State of Delaware, United States for resolution of any disputes arising out of or relating to these Terms.

Dispute Resolution

Prior to initiating formal legal proceedings, the parties agree to attempt to resolve disputes through good faith negotiation and discussion between senior representatives of each party. If the dispute is not resolved within thirty (30) days of written notice, either party may pursue legal remedies as provided herein or as permitted by law.

General Provisions

Entire Agreement

These Terms, together with any service agreements, DPAs, Order Form etc., constitute the entire agreement between you and Axora regarding the subject matter hereof and supersede all prior and contemporaneous agreements, understandings, and negotiations, whether written or oral.

In the event of any conflict or inconsistency between these Terms and any individual service agreement, Order Form, or Statement of Work executed between the parties, the terms of the individual service agreement or Order Form shall prevail to the extent of the inconsistency, unless the individual agreement expressly states otherwise.

Amendments

Axora may amend these Terms at any time by posting the revised Terms on its website or by providing written notice to you.

Your continued use of the Services following such amendment constitutes acceptance of the amended Terms.

If you do not accept the amended Terms, you must cease use of the Services.

Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, and the remaining provisions shall remain in full force and effect.

Waiver

The failure of either Party to enforce any provision of these Terms shall not constitute a waiver of such provision or the right to enforce it at a later time.

Assignment

You may not assign, transfer, or sublicense these Terms or your rights and obligations hereunder without prior written consent from Axora.

Any attempted assignment in violation of this provision shall be void. Axora may assign these Terms to its affiliates or successors without your consent.

Third-Party Beneficiaries

These Terms are intended for the benefit of the Users and Axora only, and shall not create or be construed to create any rights or obligations for any third party.

Notice

Any notices required under these Terms shall be in writing and shall be deemed delivered when sent via email to the email addresses specified in the Terms, or when delivered by personal delivery, courier, or certified mail to the addresses of the parties.

You agree to receive notices and legal documents via email, and you consent to electronic service.

Force Majeure

Neither Party shall be liable for any failure or delay in performance under these Terms caused by events or circumstances beyond its reasonable control, including acts of God, war, terrorism, pandemics, government actions, or natural disasters.

The affected Party shall promptly notify the other party and make reasonable efforts to resume performance.

Regulatory Change

If any change in applicable law, regulation, regulatory guidance, or supervisory direction in any jurisdiction materially affects Axora's ability to provide all or any part of the Services:

Axora will notify you as soon as reasonably practicable of the nature of the regulatory change and its anticipated impact on the Services;

The parties will negotiate in good faith to agree appropriate modifications to the Services or these Terms to accommodate the regulatory change; and

If the parties are unable to agree modifications within thirty (30) days of notification, either party may terminate the affected portion of the Services without liability, subject to Axora's obligations to retain data as required by applicable law.

Axora shall not be liable for any loss or damage arising from a good-faith suspension or modification of the Services in response to a regulatory requirement or supervisory direction.

Electronic Execution And Acceptance

These Terms may be accepted and executed electronically. By accessing or using the Services, by executing an Order Form electronically, or by clicking an "I Agree" or equivalent acceptance mechanism, you agree that such electronic acceptance constitutes a legally binding execution of these Terms to the same effect as a physical signature. You waive any right to claim that these Terms are unenforceable solely on the basis that they were accepted electronically rather than by physical signature.

Specific Compliance And AML Provisions

Transaction Monitoring

You acknowledge that all transactions processed through the Axora platform are subject to monitoring and analysis for compliance purposes. Axora uses third-party analytics providers, including Scorechain for blockchain analytics and transaction monitoring. Unusual or high-risk transactions may be flagged for further review or investigation.

Sanctions Compliance

You represent that you and your organization, and all customers and beneficial owners you process through the Services, are not subject to economic sanctions, do not appear on sanctions lists maintained by the U.S. Office of Foreign Assets Control (OFAC), the EU Council, the United Nations Security Council, His Majesty's Treasury (UK), or any other applicable national or supranational sanctions authority in a jurisdiction relevant to your operations.

You agree to implement and maintain sanctions screening procedures and to promptly inform Axora if you become aware of sanctions violations.

Beneficial Ownership

Where the Services involve processing of corporate customers, you agree to obtain and verify information regarding ultimate beneficial owners (UBOs) in accordance with AML/KYC regulations and to update such information on a periodic basis or upon changes in beneficial ownership.

Restricted Jurisdictions

You acknowledge that Axora does not provide Services to customers located in or conducting business with jurisdictions identified on Axora's Restricted Markets List, as updated from time to time.

A current list of restricted jurisdictions is available upon request. You agree to screen your customers against this list and to notify Axora immediately if you become aware that any customer is located in a restricted jurisdiction.

Reporting Obligations

You acknowledge that Axora is subject to reporting obligations to financial intelligence units (FIUs), regulatory authorities, and law enforcement in the jurisdictions where it operates.

You agree that Axora may cooperate with regulatory authorities and law enforcement, and may disclose transaction information, customer records, and other data as required or authorized by law.

Contact Us

For questions, support requests, or inquiries regarding these Terms of Use, the Services, or your account, please contact Axora via the following channels:

Email - operations@axorastack.com

Mailing Address - 254 Chapman Rd, Ste 208 #23198, Newark, Delaware 19702 US