Regulatory Status & Partner Disclosure

Version 9.0 applies from 2 November 2026, together with version 9.0 of the Terms of Service; for an existing customer the fee collection it describes starts once that customer has accepted version 9.0 of the Terms of Service on sign-in, and on 1 December 2026 at the latest (clause 26.9). Version 8.0 is kept unchanged in the archive .

This page sets out CashXChain’s own regulatory status, the licensed institutions through which the regulated parts of our service are provided, and who issues the stablecoins used where an Order is settled via a Stablecoin.

Every authorisation stated below links to the public register entry of the competent authority, so that each can be checked independently. Where a register cannot be linked directly, the entry names the source it rests on.

1. Our regulatory status

CashXChain Inc. is registered with FinCEN  as a Money Services Business. As a financial institution for purposes of the U.S. Bank Secrecy Act , it is subject to U.S. federal anti-money-laundering regulation under FinCEN ’s regulations for money services businesses (31 CFR Chapter X ), and it maintains a written Anti-Money Laundering Compliance Program under them. Its registration is set out in full below.

CashXChain UG (haftungsbeschränkt) operates the CashXChain platform and is the contracting party for every customer agreement. It is a technology infrastructure provider. It is not a bank, credit institution, payment institution, e-money institution, crypto-asset service provider, broker, investment firm or financial advisor, and it is not authorised or supervised as such under PSD2 , MiCAR , KWG , ZAG  or any other financial services regulation (all sources retrieved 19 August 2026).

Funds and advice. Neither company holds, transmits or custodies customer funds, and neither provides financial, investment, tax or legal advice. All regulated payment services, crypto-asset conversions, fiat on/off-ramps, custody and settlement are executed exclusively by licensed and regulated partner institutions in their own names and under their own regulatory authorisations. Use of the CashXChain platform does not constitute a financial services relationship with CashXChain UG (haftungsbeschränkt) or CashXChain Inc.

How we collect our own fees. Where you pay our fees from your account balance, the transfer is executed by Sokin, not by us: on an instruction we give under the payment mandate in clause 13.5 of the Terms of Service, Sokin transfers the amount due from your account to the account of CashXChain UG (haftungsbeschränkt) on the platform. Where the amount is taken from a Stablecoin balance, the Partner that holds it for you as custodian transfers the Stablecoin to our own wallet with a Partner, never to or from a self-hosted wallet. What arrives there is payment of our own fees and belongs to us from that moment; any conversion of it is ours. At no point do we hold, safeguard or pass on funds of yours, and a collection never goes to anyone other than us. Where your balance does not cover the amount, the rest is charged to your card or other payment method through Stripe.

FinCEN registration. CashXChain Inc. is a Delaware corporation and a financial institution for purposes of the U.S. Bank Secrecy Act, registered with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, as a Money Services Business (MSB) and money transmitter under FinCEN MSB Registration Number 31000341178304. CashXChain Inc. is publicly listed in FinCEN’s MSB Registrant Search .

CashXChain Inc. is located at 48 Wall Street, Suite 1100, PMB 1024, New York, NY 10005, United States of America.

Check it yourself. Search the registration number in FinCEN’s MSB Registrant Search  (retrieved 27 September 2026), or read the registration record as published by FinCEN (PDF, dated 27 September 2026), reproduced here unaltered.

CashXChain Inc. does not currently provide money transmission services. U.S. payment services are provided by licensed Partners. CashXChain Inc. maintains a written Anti-Money Laundering Compliance Program in accordance with the Bank Secrecy Act and applicable FinCEN regulations.

Registration with FinCEN as a Money Services Business is a federal registration requirement. It does not constitute a licence, approval, certification, endorsement or authorisation by FinCEN, and it does not replace any licence that may be required under applicable U.S. state law. CashXChain Inc. currently holds no U.S. state money transmitter licences and does not conduct activities for which such a licence is required.

CashXChain Inc. does not contract with, and does not maintain customer relationships with, users of the CashXChain platform. Use of the CashXChain platform does not, by itself, establish a customer relationship with CashXChain Inc. Customer agreements relating to the CashXChain platform are entered into with CashXChain UG (haftungsbeschränkt) or the applicable CashXChain operating entity, as specified in the relevant agreement.

2. What this means for you

When you use CashXChain, you are using a technology platform that connects and orchestrates regulated services. The regulated payment, currency-conversion, custody and settlement steps are carried out by our licensed Partner institutions, each in its own name and under its own authorisation. Your funds are never held by CashXChain.

3. At a glance

Circle is an issuer, not a Partner: where an Order is routed via a Stablecoin, settlement may use a token Circle issues, but you enter into no contract with Circle through us. The rows marked in use below it are Partners, and you enter into a contractual relationship with each of them in addition to your contract with us. Which Partner terms you accept, and how, is set out in clause 6 of the Terms of Service and is not repeated here. The entries marked under evaluation provide no part of the service today.

4. Stablecoin issuer

Circle

Entity. In the European Economic Area, both USDC and EURC are issued by Circle Internet Financial Europe SAS, Circle’s French subsidiary. Outside the EEA, USDC is issued by Circle Internet Financial, LLC.

Role. Issues the stablecoins used where an Order is settled via a Stablecoin, redeems them, and holds the reserves that back them. Circle is a stablecoin issuer, not a payment or custody Partner of CashXChain.

Regulatory status — EEA. Circle Internet Financial Europe SAS is licensed as an electronic money institution by the Autorité de contrôle prudentiel et de résolution (ACPR), the French prudential authority attached to the Banque de France, with effect from 1 July 2024 under the EU E-Money Directive (EMD2 ), and is entitled to provide payment services under PSD2  as part of that authorisation. The authorisation is listed in the French REGAFI register  (retrieved 27 August 2026), which is where it can be checked.

Regulatory status — elsewhere. Circle holds a New York BitLicense from the New York State Department of Financial Services  (since 2015; retrieved 19 August 2026), is a FinCEN -registered money services business, and holds money transmitter licences across the United States, which Circle lists state by state on its own licences page  (retrieved 27 August 2026). On 10 July 2026 Circle received final OCC approval  (retrieved 19 August 2026) to operate Circle National Trust, a federally regulated national trust bank providing fiduciary digital-asset custody, with further authorisations in the United Kingdom, Singapore, Bermuda and Canada.

How MiCAR  treats these tokens. Both USDC and EURC are electronic money tokens and are therefore governed by Title IV of MiCAR , not Title III. Title III applies to asset-referenced tokens, which reference a basket rather than a single official currency, and neither USDC nor EURC is one. Two consequences of Title IV matter to a holder, and both can be checked rather than assumed:

• The issuer must publish a crypto-asset white paper. Circle publishes one for each token: MiCA USDC White Paper  and MiCA EURC White Paper  (both retrieved 27 August 2026).
• A holder has a right of redemption at par value, at any time. Circle’s MiCA Redemption Policy  (retrieved 27 August 2026) sets out how that right is exercised.

Reserves. Circle publishes the composition of the reserves and monthly third-party attestations at circle.com/transparency  (retrieved 27 August 2026).

Why this matters to you. Where an Order is routed via a Stablecoin, the token’s issuer and the rules it answers to are part of your risk picture even though you never contract with it. An electronic money token under Title IV is redeemable at par from a supervised issuer — which is why the Stablecoins used on our platform are electronic money tokens and not tokens that offer neither.

Documents. Licences  · EEA Terms of Use  · USDC Terms  · EURC Terms  · MiCA Redemption Policy  · Privacy Policy  · Transparency and reserves  (all retrieved 27 August 2026)

5. Our regulated Partners

Each licensed institution below performs regulated steps in our service under its own authorisation, in its own name and on its own regulatory responsibility.

Sokin

Entity. Plata Capital Canada Inc., trading as Sokin. 333 Bay Street, Suite 2400, Toronto ON M5H 2T6, Canada. Sokin is a trading name used by companies in the Plata Capital group. The group company that holds the name is Plata Capital Limited, registered in England and Wales under company number 10958599, registered office c/o Mishcon de Reya, Africa House, 70 Kingsway, London WC2B 6AH (Companies House , retrieved 26 August 2026). The entity that contracts with you is the Canadian one.

Role. Accounts in your own business name, local and international payments, and currency conversion.

Regulatory status. Plata Capital Canada Inc., operating as Sokin, is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business. FINTRAC’s Money Services Business Registry  lists it as Registered under registration number N300000117, first approved on 10 April 2019 and valid until 6 February 2028, for foreign exchange, money transferring, virtual currency and payment services (retrieved 8 October 2026). As Sokin sets out on its regulation page  (retrieved 8 October 2026), Plata Capital Canada Inc. is also registered with the Bank of Canada under the Retail Payment Activities Act (RPAA); registered payment service providers are listed in the Bank of Canada’s PSP registry  (retrieved 8 October 2026).

The rest of the group. Sokin operates through a different company in each jurisdiction, and the authorisations differ accordingly. The table follows Sokin’s regulation page  (retrieved 30 September 2026). It is here so that a reference you come across elsewhere can be placed — none of these entities other than the Canadian one is your counterparty, and no authorisation of theirs is relied on in our service.

Acceptance. You accept Sokin’s Terms and Conditions through us, when you accept our Terms of Service, and the record of that acceptance goes to Sokin with your onboarding documents. Sokin then runs its own business verification before your accounts are opened.

Operational limits. Card acceptance and card issuing are not available through the embedded solution. Stablecoin support is limited to USDT and USDC on the Ethereum and Tron networks. Accounts in your own business name are available in GBP, EUR, USD and CAD; other currencies are held in pooled accounts in Sokin’s name with a reference that identifies you.

Banks behind your account details. The account details Sokin issues for you — IBAN, account and sort code, ABA routing, institution number, SWIFT — are details at the banks below, through which Sokin receives the transfers it holds for you. They are named so that a payer, an auditor or an authority can identify where a transfer lands. None of them is your counterparty: your contract for the account is with Plata Capital Canada Inc. This disclosure makes no statement that your balance is a deposit with any of these banks or that a deposit guarantee scheme covers it. The details shown for your account in the platform are authoritative; the table reflects them as at 2 November 2026.

SWIFT details at BMO Bank National Association, and the details of currencies held in pooled accounts, work with your Customer Reference Number: a payer must quote it, or the transfer cannot be credited to your account. All sources retrieved on 2 November 2026.

Why we work with Sokin. Sokin provides accounts in your own business name in GBP, EUR, USD and CAD across the corridors we operate and settles on local rails in each of them. In every case, the funds are held by Sokin, not by us.

Documents. Platform Terms & Conditions  (PDF, dated March 2026) · Privacy Policy  · How Sokin is regulated  (retrieved 30 September 2026; the others 27 August 2026)

Where Sokin needs further information about a payment or about you, it may request it through us.

Collection of our fees. Under Sokin’s Terms and Conditions, a platform through which you access Sokin is an Integrated Partner and counts as an Authorised Person on your Sokin account (clause 3.2), and Sokin may rely on its instructions, including fee instructions (clause 3.5) (retrieved 2 November 2026). Beyond transmitting your own instructions, we use that position for one purpose only: to collect what you owe us under the payment mandate in clause 13.5 of the Terms of Service, by instructing Sokin to transfer the amount due from your accounts to ours. Sokin executes the transfer under its own registration; the funds pass from your account to ours without being held by us in between. The mandate covers only amounts due to us; it extends to Stablecoin balances a Partner holds for you as custodian, but only to Stablecoins within the meaning of the Terms of Service (electronic money tokens) and never to other crypto-assets; and you can revoke it at any time.

Stablegate

Entity. STGG AG, operating under the brand name Stablegate. Dammstrasse 16, 6300 Zug, Switzerland. Commercial Register of the Canton of Zug, CHE-282.984.669.

Role. Stablecoin transit and settlement.

Regulatory status. A Swiss financial intermediary that carries out customer due diligence, monitoring and reporting under the Swiss Anti-Money Laundering Act (AMLA) . Its Terms of Business state that it is a member of a FINMA-recognised self-regulatory organisation  (retrieved 27 August 2026) under member No. 101275. It is not directly licensed by FINMA, and it is not authorised under MiCAR  or by any EU or EEA financial supervisory authority. SRO membership is supervision for anti-money-laundering purposes; it is not a licence to provide financial services.

Contracting entity. STGG AG, the Swiss company named above. Stablegate’s own onboarding and its Terms of Business govern your contract with it, including the law that applies to that contract.

Why we work with Stablegate. Moving between official currency and a stablecoin needs a counterparty that is supervised for anti-money-laundering purposes and settles on both SEPA and public networks. Stablegate does both under one contract.

Documents. Terms of Business  (retrieved 27 August 2026) · Privacy Policy  · Non-Serviced Countries  · Non-Serviced Business Sectors  · Document Requirements  (all retrieved 19 August 2026)

Stripe

Entity. Stripe Technology Europe, Limited. Address as recorded on the Central Bank of Ireland register: P.O. Box 559, Dublin 1, Ireland.

Role. Card acquiring and payment processing.

Regulatory status. Authorised as an electronic money institution under Regulation 9 of the European Communities (Electronic Money) Regulations 2011 (as amended), which implement EMD2  in Ireland, and supervised by the Central Bank of Ireland. The register records the entity type as “E-Money Institutions PSD2 ”, which carries passporting across the EEA.

Why we work with Stripe. Card acceptance requires an acquirer authorised in the EEA. Stripe covers the card rails our customers use and settles into the same corridors we operate.

Documents. Central Bank of Ireland register entry, reference C187865  (retrieved 27 August 2026) · Stripe legal pages (Ireland)  · Connected Account Agreement  · Services Agreement  · Privacy Policy  (all retrieved 19 August 2026)

Stripe’s Connected Account Agreement calls our contract with you the “Platform Provider Agreement”. Where you have no access to the Stripe Dashboard, that agreement directs you to contact us, not Stripe, for support on the Stripe services.

Stripe also processes the card and other payment-method charges with which you pay our own fees where your account balance does not cover them (clause 13.6 of the Terms of Service). For those charges CashXChain UG is Stripe’s customer as the merchant and you are the payer; the Connected Account Agreement does not govern them.

6. Under evaluation

None of the four below provides any part of our service today. They are listed because they are under active evaluation. No authorisation of any of them is claimed or relied upon anywhere in this disclosure. Where an entry sets out a public register record, it does so only so that a reference you come across elsewhere can be placed. If an engagement is agreed, it moves into the section above with its licensed entity, its role and its register entry, in the same form as the Partners there.

Binance

Under evaluation as a Partner. The scope of any engagement and the contracting Binance entity are not settled.

BitGo

Under evaluation as a Partner for qualified custody, wallet infrastructure and stablecoin settlement. The scope of any engagement and the contracting BitGo entity are not settled.

The public record. BitGo operates through a different company in each jurisdiction. The entries below were checked against the register named in each on 27 September 2026.

BitGo lists its other entities and authorisations on its own disclosures page  (retrieved 27 September 2026).

Bridge

Under evaluation as a Partner for stablecoin orchestration, issuance and on- and off-ramps. Bridge is a Stripe company: Stripe completed its acquisition of Bridge on 4 February 2025 (Stripe announcement , retrieved 8 October 2026). The scope of any engagement and the contracting Bridge entity are not settled.

The public record, as checked on 27 September 2026:

Bridge states that USDC and EURC — both electronic money tokens under MiCAR  — are the only stablecoins it supports for users in the EEA (Bridge documentation , retrieved 27 September 2026).

Coinbase

Under evaluation as a Partner for the Coinbase Developer Platform and embedded wallets. The contracting entity and the authorisation it would rely on are not settled.

Separately, Coinbase, Inc. and Coinbase Crypto Services, LLC act as sub-processors in our v1 and v2 validation environments only, as disclosed in our Sub-processor List. That is a data-processing relationship, not a regulated Partner relationship.

7. Our technology providers

The following provide infrastructure only and perform no regulated financial step: Cloudflare (network, security, hosting and edge compute, AI inference for the website assistant, and cookieless analytics), Amazon Web Services (cloud hosting, Frankfurt), Resend (email delivery), and Google Workspace (productivity and email). Full processing details, locations and transfer safeguards are in our Sub-processor List.

8. Intellectual property

The core methods behind our service are protected by utility models registered at the German Patent and Trade Mark Office (DPMA)  and searchable in DPMAregister  (both retrieved 26 August 2026); the full portfolio, with each register entry, is on IP & Copyright.

9. Licences and registrations

CashXChain Inc. is registered with FinCEN  as a Money Services Business (clause 1). Neither CashXChain company holds a banking, payment, e-money or crypto-asset service licence, and CashXChain Inc. holds no U.S. state money transmitter licence. Our corporate registrations are listed in our Licenses & Registrations overview.

10. Updates and contact

We keep this page current as our arrangements evolve, and a Partner is added here before it provides any part of the service, and removed promptly when it ceases to. Questions can be sent to compliance@cashxchain.com or legal@cashxchain.com.