Regulatory Status & Partner Disclosure

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 that settle across our rails.

Every authorisation stated below links to the public register entry of the competent authority, so that none of it has to be taken on our word. Where we have not been able to confirm something against the register itself, the entry says so and names whose statement it rests on instead.

1. Our regulatory status

CashXChain UG (haftungsbeschränkt) and CashXChain Inc. are technology infrastructure providers only. Neither entity is a bank, credit institution, licensed payment institution, e-money institution, broker, investment firm, or financial advisor, and neither is regulated as such under PSD2 , MiCAR , KWG , ZAG , or any other financial services regulation (all sources retrieved 19 August 2026). Neither entity holds, transfers, or custodies 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.

Group structure. CashXChain Inc. (Delaware, USA) is the parent holding company of the CashXChain group and holds the group’s intellectual property. CashXChain UG (haftungsbeschränkt) is currently the sole operating entity. As part of ongoing corporate restructuring, CashXChain UG (haftungsbeschränkt) will be converted into a GmbH and will become a wholly owned subsidiary of CashXChain Inc.; until that reorganisation is completed, CashXChain Inc. holds no equity in CashXChain UG (haftungsbeschränkt). Additional local subsidiaries in other jurisdictions are planned as the platform expands.

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: you hold a token it issues, but you enter into no contract with Circle through us. The four rows 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 two 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 that settle across our rails, redeems them, and holds the reserves that back them. Circle is a stablecoin issuer, not a payment or custody Partner of CashXChain, and this disclosure keeps the two roles apart.

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. Settlement runs over a token, so 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 the reason we settle over these two and not over a token that offers 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. Sokin states, in its Platform Terms & Conditions and on its regulation page, that Plata Capital Canada Inc. is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business under registration number M19963277, and with the Bank of Canada under the Retail Payment Activities Act. Unlike the other authorisations on this page, we have not been able to confirm those registrations against the registers themselves, so this entry records what Sokin states rather than what we have checked.

The rest of the group. Sokin operates through a different company in each jurisdiction, and the authorisations differ accordingly. The table is reproduced from Sokin’s own regulation page  (retrieved 27 August 2026); we have not verified the entries against the individual registers. It is here so that a reference you encounter 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.

Why we work with Sokin. An account in the customer’s own name, rather than a share of a pooled account, is what keeps funds with the licensed institution and us out of the flow. Sokin issues those accounts across the corridors we operate and settles on local rails in each of them.

Documents. Platform Terms & Conditions  (PDF, dated March 2026) · Privacy Policy  · How Sokin is regulated  (all retrieved 27 August 2026)

Sokin does not deal with your own customers directly. Where it needs more information about a payment or about you, it asks us, and we come to you.

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. Represented by Boris Mozer, Director.

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, and we state it that way rather than letting a FINMA reference imply more than it carries.

Contracting entity. Under the Terms of Business, Stablegate designates the contracting entity during onboarding, and it may be either STGG AG in Switzerland or Coinder sp. z o.o., Romana Dmowskiego 3/9, 50-203 Wrocław, Poland (KRS 0001019528), a registered virtual asset service provider. Which one you get is Stablegate’s choice, made in its own onboarding, and it decides which law governs your contract with them.

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)

As part of Stablegate’s own onboarding you may be asked to give a reverse-solicitation declaration. That declaration is between you and Stablegate; we neither collect it nor hold it.

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.

6. Under evaluation

Neither of the two below provides any part of our service today. They are listed because they are under active evaluation and because we would rather name what is being considered than let it appear later without explanation. No authorisation of either is claimed or relied upon anywhere in this disclosure. 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, the contracting Binance legal entity and its authorisation are all unsettled, so there is nothing here to state or to link.

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.

One thing is worth separating out, because it is already true: Coinbase, Inc. and Coinbase Crypto Services, LLC process personal data for us today in the v1 and v2 validation environments — internal, pre-production environments that carry no customer transactions. That processing is disclosed in our Sub-processor List. It is a data-processing relationship, not a regulated Partner relationship, and it confers no authorisation on anything in our live service.

7. Our technology providers

The following provide infrastructure only and perform no regulated financial step: Cloudflare (network, security and cookieless analytics), Amazon Web Services (cloud hosting, Frankfurt), Resend (transactional email), 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 UG (haftungsbeschränkt) and CashXChain Inc. do not themselves hold financial-services licences. 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 or removed here before the change reaches the service. Questions can be sent to compliance@cashxchain.com or legal@cashxchain.com.