Risk Disclosure Statement

Last Revised: 01.10.2026

BTY Digital AG (“BTY”, “we”, “us” or “our”) provides certain Digital Asset, payment, account, currency-conversion, card-related and other financial technology services to eligible Personal Clients and Business Clients, subject to Applicable Law, regulatory requirements, product eligibility and third-party provider arrangements.

This Risk Disclosure Statement (the “Statement”) describes certain material risks associated with the use of BTY’s Services. It is not intended to describe every possible risk and does not constitute investment, legal, tax or financial advice.

Different Services involve different risks. Clients should read this Statement together with the BTY Digital AG General Terms and Conditions, applicable product-specific terms, fee schedules and other information made available in connection with the relevant Service.

1. VOLATILITY AND MARKET RISK

Digital Assets and certain other instruments or currencies may be highly volatile.

Prices may change materially within short periods and may be affected by, among other things:

  • market liquidity;

  • trading activity;

  • supply and demand;

  • macroeconomic conditions;

  • market sentiment;

  • technological developments;

  • regulatory developments; and

  • other factors outside BTY’s control.

The value of a Digital Asset may decrease significantly, including potentially to zero.

Transactions involving Digital Assets or Currency Conversion may therefore result in significant losses.

Past performance is not indicative of future performance. BTY does not guarantee any profit, return or preservation of value.

2. LIQUIDITY AND EXECUTION RISK

The availability and execution price of a transaction may depend on market liquidity and the availability of liquidity or execution providers.

Quoted, estimated or displayed prices may change before execution, particularly during volatile or illiquid market conditions.

Transactions may:

  • be delayed;

  • be rejected;

  • be partially executed where applicable;

  • be executed at a different price from an earlier indication; or

  • become temporarily or permanently unavailable.

Spreads, network fees, execution costs, card-related conversion costs and third-party charges may also vary.

Where BTY executes or routes transactions through third-party liquidity or execution providers, execution remains subject to the availability, pricing, operational performance and other conditions of those providers.

3. DIGITAL ASSET AND BLOCKCHAIN RISK

Digital Assets depend on blockchain networks, protocols, smart contracts and related technologies.

Blockchain networks and related technologies may experience:

  • congestion;

  • outages;

  • protocol changes;

  • forks;

  • chain reorganisations;

  • validator or node failures;

  • changes in network fees;

  • software defects;

  • smart-contract vulnerabilities or exploits;

  • cybersecurity incidents; or

  • other technical events.

These events may affect the availability, transferability, functionality or value of a Digital Asset.

Changes to a blockchain protocol, token, smart contract or related infrastructure may occur without BTY’s control and may have unexpected consequences.

A Digital Asset or blockchain network may also cease to be supported by BTY or a relevant third-party provider.

4. TRANSACTION FINALITY AND INCORRECT TRANSACTIONS

Blockchain transactions are generally irreversible once submitted to and confirmed by the relevant network.

A Digital Asset transferred to an incorrect, unsupported or incompatible wallet address or blockchain network may be permanently lost.

Similarly, certain fiat payments may be difficult or impossible to reverse once submitted to the relevant payment system.

The Client is responsible for carefully verifying transaction details before submitting an instruction, including:

  • destination address;

  • blockchain network;

  • payment details;

  • beneficiary information;

  • amount;

  • currency; and

  • other relevant transaction information.

BTY may not be able to cancel, reverse or recover assets or funds transferred using incorrect information.

5. CUSTODY AND SAFEKEEPING RISK

Where Digital Assets are held, stored, administered or controlled in connection with the Services, including through third-party custody, wallet or infrastructure providers, the relevant arrangements involve custody and safekeeping risks.

These risks may include:

  • loss or compromise of private keys or signing credentials;

  • unauthorised access;

  • cyberattacks;

  • operational errors;

  • technology failures;

  • third-party failures;

  • loss of access to wallet infrastructure;

  • insolvency of a relevant provider; and

  • uncertainty concerning the treatment of Digital Assets in insolvency or enforcement proceedings.

Where third-party custody, wallet or infrastructure providers are used, the Client may be exposed to additional counterparty, operational, technological and jurisdictional risks.

The legal treatment of Digital Assets in an insolvency or enforcement proceeding may differ depending on the relevant Digital Asset, custody structure, provider, jurisdiction, contractual arrangement and Applicable Law.

6. SEGREGATED AND OMNIBUS ACCOUNT STRUCTURES

Depending on the Service and relevant provider arrangement, Client Assets may be attributable to an individual Client account, blockchain address or other arrangement, or may be held or processed through an omnibus account for operational, settlement, liquidity, conversion, payment, card-related or other purposes.

An omnibus account may contain assets or funds attributable to multiple Clients.

BTY maintains records of Client entitlements in accordance with its applicable operational and contractual arrangements.

The legal treatment and protection of Client Assets may depend on the relevant account structure, contractual arrangements, provider arrangements, Applicable Law and the circumstances of any insolvency or enforcement proceeding.

The use of an individual account identifier, blockchain address or internal ledger entry does not by itself constitute a guarantee of legal segregation, safeguarding or insolvency protection.

7. CYBERSECURITY AND OPERATIONAL RISK

Using BTY’s Services involves cybersecurity, technology and operational risks.

BTY’s systems, applications, APIs, blockchain infrastructure, payment infrastructure and relevant third-party systems may be affected by:

  • hacking;

  • malware;

  • phishing;

  • unauthorised access;

  • credential compromise;

  • data breaches;

  • software defects;

  • human error;

  • network congestion;

  • telecommunications failures;

  • system outages;

  • maintenance; or

  • other disruptions.

These events may delay, prevent or impair transactions, access to accounts or availability of Services.

Although BTY maintains measures designed to protect its systems and Services, no technological or operational system can be guaranteed to operate without interruption or error.

BTY does not guarantee uninterrupted, continuous or error-free operation of the Services.

8. FRAUD, SCAM AND SOCIAL ENGINEERING RISK

Clients may be targeted by fraudsters or other third parties through:

  • phishing;

  • impersonation;

  • social engineering;

  • investment or cryptocurrency scams;

  • fraudulent websites or applications;

  • false payment or wallet instructions;

  • account-takeover attempts;

  • malicious links or software; or

  • other deceptive practices.

A transaction that the Client personally authorises as a result of fraud, deception or social engineering may be difficult or impossible to reverse or recover, particularly where Digital Assets have been transferred to an external wallet.

Clients should carefully verify payment, beneficiary and wallet information before authorising a transaction and should not disclose passwords, authentication credentials, verification codes, private keys or other security information to unauthorised third parties.

If the Client suspects fraud, unauthorised access or compromise of an account or security credentials, the Client should contact BTY promptly through the available support channels.

9. THIRD-PARTY PROVIDER AND COUNTERPARTY RISK

Certain Services depend on third-party providers, including:

  • banks;

  • payment institutions;

  • electronic money institutions;

  • custodians;

  • wallet and blockchain infrastructure providers;

  • card issuers and programme partners;

  • liquidity and execution providers;

  • technology providers; and

  • other service providers.

The availability, performance, financial condition, operational resilience, regulatory status, contractual terms or decisions of such providers may affect BTY’s ability to provide Services or complete transactions.

A third-party provider may suspend, restrict, terminate or modify its services or impose additional conditions or limitations.

Where a Service depends on a third-party provider, the Client may therefore be exposed to counterparty, operational, financial, regulatory, technological or other risks arising from that provider.

10. FIAT PAYMENT AND BANKING INFRASTRUCTURE RISK

Fiat Payment Accounts and related payment services may be provided or supported through third-party banks, payment institutions, electronic money institutions or other providers.

Accordingly, account availability, payment execution, settlement times, safeguarding arrangements, account restrictions and service continuity may depend on the relevant provider and payment infrastructure.

Payments may be:

  • delayed;

  • rejected;

  • returned;

  • blocked;

  • subject to additional verification;

  • subject to transaction limits; or

  • subject to additional fees or restrictions.

The contractual and legal relationship concerning a third-party account or payment service may also be governed by the terms of the relevant provider.

11. PAYMENT CARD RISK

Payment Cards may be issued, processed or operated through third-party card issuers, programme partners, processors and other providers.

Card transactions may be declined, reversed, delayed or restricted.

Cards may also be suspended, restricted or terminated by BTY or a relevant card provider where permitted under the applicable terms, including for legal, regulatory, compliance, security, fraud-prevention or operational reasons.

Where a Payment Card transaction requires Currency Conversion, the applicable exchange rate, spread, fee and timing of conversion may affect the amount ultimately charged to the Client.

Clients should also review the applicable cardholder terms and conditions and relevant fee information.

12. CURRENCY CONVERSION RISK

Currency Conversion involves exchange-rate risk.

The exchange rate available at the time of execution may differ from a rate previously displayed, estimated or available at another time.

This may apply to:

  • fiat-to-fiat conversions;

  • Digital Asset-to-fiat conversions;

  • fiat-to-Digital Asset conversions; and

  • automatic conversions associated with Payment Card transactions.

The Client may receive less value than expected due to market movements, spreads, fees, network costs, third-party charges or other applicable costs.

13. STABLECOIN AND TOKEN-SPECIFIC RISK

Stablecoins and other Digital Assets that are designed or represented as maintaining a reference value may not always maintain that value.

A stablecoin or other token may be affected by:

  • market conditions;

  • liquidity;

  • reserve or backing arrangements;

  • issuer risk;

  • counterparty risk;

  • redemption restrictions;

  • technological failures;

  • protocol or smart-contract failures;

  • regulatory developments; or

  • loss of market confidence.

The value of a stablecoin may therefore deviate materially from its reference currency or asset and may, in extreme circumstances, lose a substantial part or all of its value.

Other Digital Assets may have additional risks arising from their specific design, issuer, protocol, governance, underlying technology or market.

The legal and regulatory framework applicable to Digital Assets, payment services, custody, Currency Conversion and related services continues to develop across jurisdictions.

Changes in:

  • laws;

  • regulations;

  • regulatory interpretations;

  • sanctions regimes;

  • supervisory expectations; or

  • licensing, registration or authorisation requirements

may affect the availability, scope, pricing, functionality or terms of BTY’s Services or particular Digital Assets.

BTY may therefore be required to introduce additional controls, request additional information, restrict or suspend Services, reject transactions or discontinue particular Services where necessary to comply with Applicable Law or applicable regulatory requirements.

15. REGULATORY STATUS AND CLIENT PROTECTION RISK

BTY’s regulatory status differs from that of a Swiss bank or other prudentially supervised financial institution.

BTY is affiliated with VQF, a self-regulatory organisation recognised by the Swiss Financial Market Supervisory Authority (“FINMA”) under the Swiss Anti-Money Laundering Act.

BTY’s VQF affiliation relates to its applicable AML/CFT obligations. It does not constitute a Swiss banking licence and does not, by itself, mean that BTY is subject to the same prudential regulatory framework as a Swiss bank.

Where Services are provided or supported through a third-party bank, payment institution, electronic money institution, card issuer or other regulated provider, the regulatory status and protections applicable to that provider are separate from BTY’s own regulatory status.

Clients should not assume that Client Assets held, processed or made available in connection with BTY’s Services are protected in the same manner as deposits held with a Swiss bank.

Any applicable safeguarding, segregation, insolvency protection, deposit protection or other protection depends on the relevant Service, provider, account or custody structure, contractual arrangements and Applicable Law.

16. JURISDICTIONAL RISK

The availability of Services may depend on:

  • the Client’s country of residence or incorporation;

  • place of business;

  • nationality;

  • beneficial owners;

  • authorised users;

  • transaction counterparties;

  • payment routes;

  • blockchain networks; and

  • other jurisdictional factors.

Services may therefore be unavailable or restricted in certain jurisdictions.

BTY may introduce or change geographic restrictions where reasonably required for legal, regulatory, sanctions, compliance or risk-management reasons.

17. COMPLIANCE, AML/CFT AND SANCTIONS RISK

BTY applies customer due diligence, transaction monitoring, sanctions controls and other compliance measures in connection with its Services.

Transactions, Services or accounts may be delayed, restricted, suspended or terminated where:

  • required information is incomplete;

  • identity or beneficial ownership cannot be satisfactorily verified;

  • transaction information cannot be verified;

  • activity raises compliance concerns;

  • sanctions restrictions apply;

  • fraud or unlawful activity is suspected; or

  • BTY is otherwise required or permitted to take action under Applicable Law or applicable contractual terms.

BTY may request additional information or supporting documentation from the Client before or during the Client relationship.

BTY may not always be legally permitted to disclose whether a particular compliance review is taking place or the reasons for a particular compliance action.

18. TAX RISK

Transactions involving Digital Assets, fiat currencies, Payment Cards or other Services may have tax consequences in one or more jurisdictions.

Tax treatment may depend on the Client’s individual or business circumstances, jurisdiction, residence, nature of the transaction and Applicable Law.

Tax rules, interpretations and reporting requirements may change.

BTY does not provide tax advice and does not determine the Client’s tax obligations except where required by Applicable Law.

The Client is responsible for obtaining appropriate independent tax advice where necessary and for complying with applicable tax and reporting obligations.

Unless expressly agreed otherwise, BTY does not provide investment, legal, tax or financial advice.

General market data, pricing information, Digital Asset information, product information, educational materials or other general information made available through BTY is provided for informational purposes.

Unless expressly stated otherwise, such general information does not constitute:

  • investment advice;

  • a personal investment recommendation;

  • legal or tax advice;

  • a guarantee of performance or return; or

  • an endorsement of a particular Digital Asset, transaction or investment strategy.

The availability of a Digital Asset or other functionality through the Services should not by itself be understood as a recommendation or endorsement by BTY.

BTY does not assess whether a particular transaction is suitable or appropriate for the Client unless such assessment is expressly required by Applicable Law or otherwise agreed.

The Client remains responsible for its own decisions and should obtain independent professional advice where appropriate.

20. CLIENT-SPECIFIC RISK

The risks applicable to a particular Client may differ depending on:

  • the Client’s individual or business circumstances;

  • the Services used;

  • the Digital Assets involved;

  • transaction size;

  • jurisdiction;

  • account or custody structure;

  • third-party providers;

  • payment methods; and

  • other relevant factors.

A risk that is not specifically described in this Statement may nevertheless apply to a particular Service, Digital Asset or transaction.

Clients should review the information and contractual documentation provided for the relevant Service before using it.

21. NO GUARANTEE AGAINST LOSS

BTY does not guarantee that the Client will avoid losses arising from use of the Services.

In particular, BTY does not guarantee:

  • preservation of the value of Digital Assets;

  • profitability or investment returns;

  • availability of liquidity;

  • uninterrupted access to Services;

  • successful execution of every transaction;

  • recovery of incorrectly transferred assets or funds;

  • availability of a particular Digital Asset;

  • availability or continued operation of a particular blockchain network; or

  • continued availability of any particular Service.

Nothing in this Section excludes or limits any responsibility or liability that cannot lawfully be excluded or limited under Applicable Law.

22. ACKNOWLEDGEMENT OF RISK

By accessing or using BTY’s Services after this Statement has been made available, the Client acknowledges that they have had an opportunity to review and consider the risks relevant to the Services they use.

The Client understands that the risks described in this Statement are not exhaustive and that additional risks may apply to particular Digital Assets, transactions, products or Services.

This Statement does not modify or replace the BTY Digital AG General Terms and Conditions, applicable product-specific terms, fee schedules or other contractual documentation.

Nothing in this Statement limits any mandatory rights or protections available to the Client under Applicable Law.

23. UPDATES TO THIS STATEMENT

BTY may update this Risk Disclosure Statement from time to time to reflect changes in:

  • its Services;

  • technology;

  • Digital Assets or blockchain networks;

  • third-party providers;

  • Applicable Law;

  • regulatory requirements; or

  • identified risks.

The current version will be made available through the relevant Brighty website, application or other appropriate communication channel.

Where required by Applicable Law, BTY will provide appropriate notice of material changes.