AML/CTF Policy

1. Company and product

Terius LLC is a software company registered in Georgia (country), identification number 406490177, registered address: 5 Police Lane I, Floor 2, N4a, Samgori district, Tbilisi, Georgia. That registration is not a license to provide financial services, virtual-asset exchange, or fiat exchange.

The Company develops and operates Terius, a non-custodial cryptocurrency wallet. Users generate and store private keys and seed phrases on their own devices. The Company never holds, custodies, controls, or has access to user funds or private keys, and cannot initiate, reverse, or block a user transaction. The Company does not operate an exchange, does not convert virtual assets to fiat or fiat to virtual assets, does not transfer virtual assets on behalf of users, and does not provide custody.

2. Licensing

The Company’s business is software development and operation of non-custodial wallet software. Under the Law of Georgia on Virtual Asset Service Providers, and consistent with FATF guidance on virtual assets and U.S. FinCEN interpretive guidance FIN-2019-G001, a provider of non-custodial wallet software that never takes control of user value is not a virtual-asset service provider and is not required to hold a VASP registration or a financial license for that activity.

Terius LLC therefore does not hold, and is not required to hold, a license for virtual-asset services or for fiat exchange. No such license exists, so there is no copy and no public register entry to provide. Where the application offers fiat exchange, it is carried out by the fiat provider named in the Terms of Use. At present that provider is Guardarian, under Guardarian’s own license and compliance program, and not by Terius.

3. Risk-based approach

Cryptocurrency software can be misused. Because the product is non-custodial, the Company cannot intercept or freeze a user’s funds. The Company can only limit risk in ways it actually controls. Exchange and fiat are offered only through independent providers, which carry out their own checks. Address screening is built in. Guardarian’s service is not offered where Guardarian’s terms do not allow it. Use that violates applicable sanctions is prohibited. The Company keeps technical records of an exchange started in the application so that it can answer a lawful request.

4. Exchange providers and fiat

Cryptocurrency exchange in the application is performed by the independent exchange providers named in the Terms of Use. Terius does not exchange the assets, does not set the rate, and does not hold them.

Where available, buying or selling cryptocurrency for fiat is carried out by the fiat providers named in the Terms of Use. The current provider is Guardarian, and Guardarian’s own terms apply. The Company does not execute the fiat transaction, does not collect or store identity documents, and does not decide whether the provider accepts the user. Guardarian’s terms are set out in Section 7.

5. Address screening

The application integrates blockchain address screening provided by GetBlock, a service of 365cash OÜ (registry code 14397478, Estonia) at getblock.net. A user can screen a wallet address for exposure to illicit activity. The Company keeps a record of the check (address, date, and result) for at least 12 months. Screening results are informational. They are not a legal or compliance opinion, and they are not a decision by Terius to block a transaction: the Company cannot block a non-custodial transaction. GetBlock applies its own terms to the check.

6. Sanctions

The Company complies with applicable sanctions of the European Union, the United States (OFAC), and the United Kingdom. The Terms of Use prohibit use of the Services by a person located in, ordinarily resident in, or a national of a jurisdiction subject to comprehensive sanctions or embargoes, and by a person on an applicable sanctions list. The Company may restrict access where that is required to comply with applicable law.

Guardarian’s terms, including the jurisdictions in which its service is not offered, are set out in Section 7. Those terms apply to Guardarian only. They do not restrict the Wallet or cryptocurrency exchange.

7. Exchange through Guardarian

Use of Guardarian is subject to Guardarian’s own terms. Guardarian does not offer its service in the jurisdictions listed below. If Guardarian updates the list, the updated list applies. You may not circumvent these restrictions.

These terms apply to Guardarian only. They do not restrict the Wallet or cryptocurrency exchange. Any other fiat provider would be subject to its own list. Terius LLC is registered in Georgia, and the Wallet remains available there.

Afghanistan, Åland Islands, Albania, Algeria, American Samoa, Andorra, Angola, Anguilla, Antarctica, Antigua and Barbuda, Aruba, Bahamas, Bahrain, Bangladesh, Barbados, Belarus, Belize, Bermuda, Bolivia, Bonaire, Botswana, Bouvet Island, British Indian Ocean Territory, Burkina Faso, Burundi, Cambodia, Cameroon, Cayman Islands, China, Christmas Island, Cocos (Keeling) Islands, Cook Islands, Côte d’Ivoire, Cuba, Curaçao, Democratic People’s Republic of Korea, Democratic Republic of the Congo, Egypt, Eritrea, Ethiopia, Falkland Islands (Malvinas), Faroe Islands, French Guiana, French Polynesia, French Southern Territories, Georgia, Gibraltar, Greenland, Guadeloupe, Guam, Guernsey, Haiti, Heard Island and McDonald Islands, Holy See, India, Iran, Iraq, Isle of Man, Israel, Jamaica, Jersey, Kenya, Kosovo, Lebanon, Libya, Macao, Malawi, Malaysia, Mali, Martinique, Mauritius, Mayotte, Monaco, Mongolia, Montserrat, Morocco, Mozambique, Myanmar, Namibia, Nepal, New Caledonia, Nicaragua, Nigeria, Niue, Norfolk Island, North Macedonia, Northern Mariana Islands, Pakistan, Palau, Palestine, Panama, Philippines, Pitcairn, Puerto Rico, Qatar, Réunion, Russia, Saint Barthélemy, Saint Helena, Ascension and Tristan da Cunha, Saint Kitts and Nevis, Saint Martin (French part), Saint Pierre and Miquelon, Saudi Arabia, Senegal, Singapore, Sint Maarten (Dutch part), Somalia, South Africa, South Georgia and the South Sandwich Islands, South Korea, South Sudan, Sudan, Svalbard and Jan Mayen, Syria, Taiwan, Tanzania, Tokelau, Trinidad and Tobago, Turks and Caicos Islands, U.S. Virgin Islands, United Arab Emirates, United States Minor Outlying Islands, Vanuatu, Venezuela, Virgin Islands (British), Wallis and Futuna, Western Sahara, Yemen, Zimbabwe.

U.S. states where Guardarian’s fiat service is not offered: Alabama, Alaska, Hawaii, Illinois, Louisiana, Nevada, New Mexico, New York, Ohio, Rhode Island, Vermont.

8. Record keeping

For an exchange initiated through the application, the Company retains the order or transaction identifier issued by the provider, the asset pair and amounts, the wallet addresses involved, the IP address, device and application information (including user-agent where applicable), and language settings. These records are kept for at least 12 months and may be disclosed to a competent authority on a valid legal request, or to an integrated provider where its partner terms require it for an investigation of abuse of the application.

9. Cooperation

The Company responds in good faith to valid legal requests from law-enforcement and regulatory authorities. It also cooperates with the compliance teams of integrated providers when they investigate suspected abuse of the application. Cooperation cannot extend to user private keys, seed phrases, or funds, which the Company does not possess.

10. Responsible person and review

Oversight of this Policy sits with a director of Terius LLC. Compliance inquiries: support@terius.com. This Policy is reviewed at least annually and when the product, applicable law, or a partner’s requirements change materially.