Legal

Important – The Additional T&Cs stated in this section reflects the risk warnings and relevant disclosures pertaining to various aspects of the StraitsX Services. 

User advisory - Before using any of our StraitsX Services, you should carefully review the Risk Warnings, Notices and Disclosures in this Additional T&Cs to ensure that you fully understand the risk warnings and the disclosures it contains. You are solely responsible for understanding the risks associated with our StraitsX Services and you should assess whether such risks are appropriate for your particular use or circumstances. 

RISK WARNING ON DIGITAL PAYMENT TOKEN SERVICES 

1. StraitsX is required by the Monetary Authority of Singapore to provide this risk warning to you as a customer of a digital payment token service provider. Before you: (a) pay StraitsX Payment Services Pte Ltd (i.e. SPSPL) any money or digital payment token; or (b) pay a third party any money or digital payment token under an arrangement by SPSPL, you should be aware of the following. 
   
   1. SPSPL is licensed by the Monetary Authority of Singapore to provide digital payment token services. Please note that this does not mean you will be able to recover all the money or digital payment tokens you paid to SPSPL or any other third party referred to above, if SPSPL’s or the third party’s business fails.
   2. You should be aware that the Monetary Authority of Singapore does not supervise or regulate SPSPL for the provision of unregulated services. This includes any service of trading digital payment token derivatives such as futures. 
   3. You should not transact in the digital payment token if you are not familiar with this digital payment token. This includes how the digital payment token is created, and how the digital payment token you intend to transact is transferred or held by SPSPL.
   4. You should be aware that the value of digital payment tokens may fluctuate greatly. You should buy digital payment tokens only if you are prepared to accept the risk of losing all of the money you put into such tokens. 
   5. You should be aware that SPSPL, as part of its licence to provide digital payment token services, may offer services related to digital payment tokens which are promoted as having a stable value, commonly known as “stablecoin”. 
      

NOTICE FOR NON-SINGAPORE RESIDENTS

1. Xfers Pte Ltd (i.e. XPL) is licensed by the Monetary Authority of Singapore to provide e-money issuance services. Please note that this does not mean you will be able to recover all the money you paid to XPL if XPL’s business fails.

DISCLOSURES RELATING TO RESERVE BACKING OF XSGD AND XUSD

Reserve backing for XSGD and XUSD 

1. In accordance with the upcoming stablecoin regime designed by the Monetary Authority of Singapore and/or regulatory requirements imposed by them, STX XSGD and STX XUSD are required to ensure that XSGD and XUSD are fully backed by Reserve Assets equivalent to at least 100% of the par value of all outstanding StraitsX Tokens in circulation at all times. These Reserve Assets are held by STX XSGD (for XSGD) and STX XUSD (for XUSD) in segregated accounts belonging to and on trust for the XSGD and XUSD token-holders, separate from the assets of STX XSGD and STX XUSD. The composition of the Reserve Assets is within the sole control and at the sole and absolute discretion of STX XSGD and STX XUSD, and these Reserve Assets may be held in interest-bearing accounts or other yield-generating assets or instruments. The XSGD and XUSD token-holders are not entitled to any interest or other returns earned by the Reserve Assets.
2. In this regard, STX XSGD and STX XUSD will be holding the Reserve Assets on behalf of  XSGD and XUSD token-holders in trust accounts maintained with CIMB Bank Berhad Singapore Branch (“CIMB”), DBS Bank Ltd (“DBS”) and Standard Chartered Bank (Singapore) Ltd (“SCB”) or any other financial institutions that are permitted by MAS (collectively to be known as Permitted FIs”), which are distinguishable and maintained separately from any other account in which we may deposit our own assets. You acknowledge that StraitsX may open such trust accounts with these Permitted FIs from time to time without any prior notice to you or amendments to these StraitsX T&Cs.  
3. You acknowledge that maintaining the Reserve Assets in a trust account on behalf of XSGD and XUSD token-holders does not guarantee that the Permitted FIs can meet all claims related to redemptions of XSGD and XUSD. Depositing money to back the XSGD and XUSD in circulation into such trust accounts also does not ensure full satisfaction of each token-holder’s claim. The Permitted FIs will not be liable to compensate a token-holder where the funds in that trust account are insufficient to cover their claim. 
   

Your right of redemption in the event of insolvency

4. In the event of insolvency of STX XSGD and/or STX XUSD, general insolvency procedures under the law will follow. As the Reserve Assets are held on trust for the XSGD and XUSD-token holders, they will not be distributed to other unsecured creditors of STX XSGD and/or STX XUSD. Law and practice suggests that the token-holders will be required to file for a proof of debt with the liquidator. Distribution of Reserve Assets to the XSGD and XUSD-token holders will begin once the liquidator obtains concurrence from the court or committee of inspection (whichever is applicable).

DISCLOSURES RELATING TO CUSTODY AND SAFEGUARDING OF YOUR STRAITSX TOKENS AND NON-STRAITSX TOKENS

StraitsX will hold your assets on behalf of you in a trust account maintained by SPSPL and an external custodian

1. As a holder of a Major Payment Institution Licence under the Payment Services Act 2019, SPSPL is required to safeguard any Relevant Money received from you, or any StraitsX Tokens and Non-StraitsX Tokens (to be singularly or collectively in any combination called “assets” depending on the context) received from you by depositing them into a trust account maintained either by SPSPL or an external third-party custodian (to be known as the “Custodial Safeguarding Person”). As such, you will continue to retain a beneficial ownership interest in the assets held with StraitsX or with the Custodial Safeguarding Person. For the avoidance of doubt, our obligation to safeguard your StraitsX Tokens and Non-StraitsX Tokens only relates to the amount of digital assets that have been minted and received from you. 
   

Safeguarding your cash on behalf of you in a trust account maintained by SPSPL 

2. Any cash received from you but not used to mint StraitsX Tokens will be safeguarded as Relevant Money by depositing them into segregated trust accounts maintained with a Safeguarding Institution, which are distinguishable and maintained separately from any other account in which we may deposit our own assets. The disclosures in clause 5 (see below) will similarly apply to the safeguarding of such cash received from you. 
   

Safeguarding assets on behalf of you in a trust account maintained by SPSPL and an external custodian

3. We will be holding your assets (i.e StraitsX Tokens and Non-StraitsX Tokens) on your behalf in trust accounts that are maintained by SPSPL and with a Custodial Safeguarding Person. These trust accounts are distinguishable and maintained separately from any other account in which we may deposit our own assets.
4. Our current Custodial Safeguarding Person is BitGo, Inc. You acknowledge that this may be subject to change from time to time, as we may appoint other Custodial Safeguarding Persons in the future without any prior notice to you or any amendments to these StraitsX T&Cs. 
5. Where a Custodial Safeguarding Person is based outside of Singapore, this may mean that your assets may also be stored in devices located in that foreign jurisdiction. As such, you should take note that the laws and practices in these foreign jurisdictions may differ from those in Singapore. These differences in legal frameworks and practices could potentially affect your ability to recover your assets in the event of insolvency or other adverse circumstances. For example, there may be a substantial delay in the recovery process due to the need to obtain foreign regulatory approvals or there may be a need to partake in foreign court proceedings before your assets can be returned to you.
   

StraitsX will treat your assets deposited in the trust accounts as belonging to you subject to the StraitsX T&Cs and the following terms and conditions

6. StraitsX will treat and deal with your assets (i.e. the StraitsX Tokens and/or Non-StraitsX Tokens) deposited in the trust accounts as belonging to you and apply them in accordance to the terms and conditions of the StraitsX T&Cs, including the following terms and conditions:
   
   1. Whenever you confirm a transaction involving your assets held in the trust account, you hereby represent and warrant that you are making such a transaction on your own behalf. If another person is making that transaction on your behalf, you represent and warrant that that the other person has been granted the authority to do so by you, and that in all cases we are entitled to treat the transaction as being made by you.
   2. Your assets held in the trust accounts are generally not considered a form of collateral. However, by agreeing to the StraitsX T&Cs, you agree that StraitsX has the right of lien, right of retention, and/or sale over your assets held by us on your behalf in the trust accounts to meet any liabilities, debts, or obligations (e.g. unpaid fees, invoices, damages or any financial obligation) you owe to StraitsX or any member of our corporate group pursuant to the terms and conditions of the StraitsX T&Cs.
   3. Your assets (i.e. the StraitsX Tokens and/or Non-StraitsX Tokens), that are deposited in the above-mentioned trust accounts, may be deposited or commingled with assets belonging to other StraitsX users and may not be identifiable by separate certificates, or other physical documents or equivalent electronic records. The fact that your assets may be held in the same trust accounts as those of other StraitsX users does not impact your ownership or control over your assets. We will also maintain, in our independent records, your identity and share of the assets that have been deposited in the trust accounts. 
   4. You agree that where you have instructed us, agreed verbally or in writing, including your agreement to the terms of these StraitsX T&Cs, or where the circumstances are clear such that you are deemed to have given consent to us, or where we are required by any Applicable Law, we are authorized to sell, redeem, transfer, set-off, burn, loan or otherwise alienate your assets in your StraitsX Digital Assets Account.
   5. Where there is any change in our self-maintained trust accounts or those maintained with the Custodial Safeguarding Person, you also agree and authorise StraitsX and/or the previous Custodial Safeguarding Person to transfer your assets to the new trust accounts. 
   6. The assets held with SPSPL and the Custodial Safeguarding Person shall be registered in the name of SPSPL, who is entitled to claim and receive any rewards or entitlements accruing to you in relation to the StraitsX Tokens and Non-StraitsX Tokens held on your behalf. SPSPL is also empowered to exercise any rights and powers arising from the ownership of these assets strictly in accordance with the instructions received from you. 
   7. You may request for information relating to the safeguarding of your assets, which we may furnish at our discretion.
   8. While there may be fees applicable for the use of our StraitsX Services, there are no standalone fees to be incurred by you in relation to the safeguarding of your assets with StraitsX and/or the Custodial Safeguarding Person. 
      

Loss of assets

7. In the event that any of our appointed Custodial Safeguarding Person default in the safeguarding arrangements, StraitsX commits to making every effort to recover and protect your assets. However, StraitsX will not be able to guarantee the full recovery of all of your assets in the event of a custodian default. As stated in the StraitsX T&Cs, and except as may be required by Applicable Laws, StraitsX will also not be liable for any loss you may suffer as a result of any act or omission of that Custodial Safeguarding Person. You acknowledge and accept the inherent risks associated with holding assets with an external third-party custodian. 
8. In all other situations, StraitsX’s liability to compensate users for loss of assets held with StraitsX or its Custodial Safeguarding Person will be determined in accordance with Applicable Laws (including MAS regulatory requirements), the StraitsX Compensation Policy, and/or the StraitsX T&Cs. Unless required by Applicable Laws, StraitsX will generally not be liable for any loss caused by your action (fraudulent or otherwise), contributory negligence or omission, including but not limited to: (i) transactions carried out on the instructions of a third party or allowing a third party remote access to your device while logged in to your StraitsX Accounts; or (ii) compromised login credentials or API keys. 
9. To lodge a claim for a compensation payment, please lodge a support ticket with StraitsX and provide all requested information with sufficient details and clarity. Once the support ticket is lodged, StraitsX will aim to provide an initial response within 5 business days.
10. Do take note that StraitsX’s liability is capped at the amount or value of lost assets at the time of the incident. Please visit the StraitsX Compensation Policy for more details.
    

Consequences for you in the event of StraitsX’s insolvency or the Custodial Safeguarding Person’s insolvency

11. In the event of either SPSPL’s or the Custodial Safeguarding Person’s insolvency, general insolvency procedures under the law will follow. As you are the beneficial owner of your assets, you will be able to claim ownership of your assets (e.g. StraitsX Tokens) held with StraitsX and/or the Custodial Safeguarding Person.
12. These assets will not be used to pay off the debts of either SPSPL or the Custodial Safeguarding Person, nor will be liable to be taken under or pursuant to an enforcement order or a process of any court. However, law and practice suggests that you will generally be required to file for a proof of debt with the liquidator, and asset distribution will commence once the liquidator receives the necessary concurrence from the court or committee of inspection.
    

DISCLOSURES RELATING TO SAFEGUARDING OF YOUR RELEVANT MONEY

StraitsX will safeguard all Relevant Money it receives from you at all times by depositing them into a trust account maintained with a Safeguarding Institution 

1. As a holder of a Major Payment Institution Licence under the Payment Services Act 2019, XPL is required to safeguard Relevant Money that it receives from you, or on your account, with a Safeguarding Institution. 
2. In this regard, XPL will be safeguarding the aggregate Relevant Money by depositing them into trust accounts maintained with CIMB, DBS, SCB and any other Safeguarding Institution, which are distinguishable and maintained separately from any other account in which we may deposit our own assets. You acknowledge that XPL may open such trust accounts with these Safeguarding Institutions from time to time without any prior notice to you or amendments to these StraitsX T&Cs. You are not entitled to any interest or other returns earned by the safeguarding of Relevant Money.
3.  You acknowledge that maintaining the Relevant Money in a trust account on behalf of you does not guarantee that StraitsX will be able to satisfy any and all claims by you in relation to the Relevant Money, and that the Safeguarding Institution will not be liable to compensate you where the funds in the trust accounts are insufficient to satisfy your claim against us.
   

Commingling of Relevant Moneys and risks of commingling 

3. Any Relevant Moneys received by XPL from you, or on your account, and deposited in these trust accounts will be commingled with Relevant Money received on account of other users. Consequently, it will not be possible to identify any portion of the Relevant Money in the trust account(s) as specifically belonging to you, and money in the trust accounts could be withdrawn to meet the obligations of other users. 
   

Consequences for you in the event of StraitsX’s insolvency or the Safeguarding Institution’s insolvency

4. In the event of either XPL’s or the Safeguarding Institution’s insolvency, general insolvency procedures under the law will follow. As you are the beneficial owner of the Relevant Money, you will be able to claim ownership of the Relevant Money held with the Safeguarding Institution. 
5. As the Relevant Money is held on trust for you, they will not be distributed to other unsecured creditors of XPL and/or the Safeguarding Institution. Law and practice suggests that you will be required to file for a proof of debt with the liquidator. Distribution of Relevant Money to you will begin once the liquidator obtains concurrence from the court or committee of inspection (whichever is applicable). 
6. You acknowledge and agree that Relevant Money will not include any moneys paid to us that will be used to defray any fees or charges imposed by us in connection with these StraitsX T&Cs, or any money used to reduce the amount owed by you to us.
   

DISCLOSURES RELATING TO STRAITSX EARN 

1. Before participating in the StraitsX Earn, you should carefully assess your financial situation, risk tolerance and investment objectives. It is important to fully understand the possible outcomes, including the potential loss of principal and/or rewards. By participating in the StraitsX Earn service, you acknowledge and accept that there are significant risks involved and that XIPL or StraitsX will not be liable for any losses (direct or indirect) that you may incur by your participation in the StraitsX Earn. Please read below for the key disclosures.

Key Risks

1. The use of StraitsX Tokens or Non-StraitsX Tokens for yield generation carries inherent risks, including the possibility of losing the principal amount invested. There is no guarantee of returns, and past performance is not indicative of future results. Also, XIPL reserves the right to vary rewards rates as deemed necessary, and users should be aware that rewards rates offered may change over time.
2. The ability to withdraw funds may be subject to processing times (up to 7 business days) and may vary depending on the specific Earn product.
3. You are also exposed to counterparty risks, as XIPL may deploy tokens through third-party counterparties (e.g. third party platforms or lending arrangements). In the event of counterparty insolvency, default, operational failure or financial loss, you may lose all or part of your deployed tokens. XIPL’s ability to return the principal and rewards is contingent upon the performance of these counterparties, and you acknowledge that there may be situations where recovery is not possible.
4. Additionally, the underlying deployment platforms may experience security incidents, technical disruptions, maintenance periods, or outages, which could affect or result in the loss of your principal and/or rewards, either wholly or partially. Such incidents may also impact XIPL’s ability to process your withdrawals in a timely manner.
5. You should also be aware of concentration risks. If a significant portion of the tokens are deployed with a single counterparty or strategy, the impact of a single point of failure could be substantial, leading to a higher risk of loss in the event of counterparty default or operational issues.

Regulatory Status & No Protection

1. The StraitsX Earn service is offered by XIPL, who is not licensed by the Monetary Authority of Singapore. The StraitsX Earn service is not a regulated activity under the Payment Services Act 2019. As such, StraitsX Tokens or Non-StraitsX Tokens held within the Earn service are not safeguarded under any requirements applicable to entities licensed under the Payment Services Act 2019, as these requirements do not apply to XIPL.
2. XIPL is not a bank or deposit-taking company and does not maintain any bank accounts or any current, savings, or deposit accounts for StraitsX users. XIPL is also not engaged in moneylending or providing credit. The StraitsX Earn service is also not a deposit or savings account, and thus the tokens deployed under the StraitsX Earn service are not covered by the Deposit Insurance Scheme administered by the Singapore Deposit Insurance Corporation Limited or any insurance scheme generally.
   

DIGITAL ASSET STORAGE DISCLOSURES

StraitsX’s storage arrangements

1. StraitsX maintains a policy on digital asset storage arrangements that balances security with operational efficiency. Our approach involves using three distinct types of storage:
   
   1. “Users assigned deposit wallets” - where user’s deposited StraitsX Tokens or Non-StraitsX Tokens will be received. 
   2. “Hot wallets” - where a small portion of digital assets remains online to provide the liquidity needed for daily trading, withdrawal, and other transactions.
   3. “Cold Storage” - where the majority of digital assets are stored offline for enhanced security. These assets are held in environments not connected to the internet, reducing exposure to cyber risks.
2. StraitsX’s target allocation of assets in both users’ assigned deposit wallets and hot wallets (“ Settlement Wallets”) is rebalanced periodically to ensure compliance with applicable regulatory thresholds and operational needs. The assets allocated to the settlement wallet are carefully managed according to pre-set maximum and minimum balance thresholds.
3. When net asset inflows cause the Settlement Wallets to exceed a specified maximum balance, the excess funds are automatically moved to Cold Storage to reduce the balances in the Settlement Wallets to a designated threshold.
4. Conversely, if net asset outflows reduce the Settlement Wallet balance below a designated threshold, StraitsX will review transaction patterns and, where necessary, transfer additional assets from cold storage to meet liquidity requirements.
   

StraitsX’s storage controls 

5. StraitsX maintains a policy to restrict any StraitsX employee from solely authorising and effecting the movement, transfer or withdrawal of StraitsX user’s assets via access controls instituted on the wallets. Access controls are further complemented with hard-coded rules that restrict transfers of digital assets in Settlement Wallets and Cold Storage. 
   

Cybersecurity and Risk Mitigation Measures

6. StraitsX implements comprehensive measures to mitigate the risk of loss due to cyber threats. Measures taken comply with applicable regulations which cover practices that govern security over administrative accounts, application of security patches to address vulnerabilities, network perimeter defence, malware protection, and multi-factor authentication.
7. Additionally, the vast majority of customer assets are held in vault storage facilities that are offline, encrypted, and subject to stringent physical and digital security protocols. Private keys associated with settlement wallets are also secured in an isolated, encrypted system. These precautions aim to protect customer assets against potential cyber attacks.
8. Vulnerability assessment to identify security vulnerabilities together with regular penetration testing is carried out to ensure any vulnerabilities or gaps are surfaced on a timely basis, and rectified promptly. Additionally, some of our StraitsX entities are also ISO 27001 certified, which means that they undergo an annual evaluation of our security posture by the independent assessor to ensure that they continuously fulfill the requirement of the certification. 
   

CONFLICT OF INTEREST DISCLOSURES

1. The MAS requires StraitsX to identify, mitigate, and disclose all potential or actual conflicts of interest that may arise from providing our services. StraitsX has not identified any such conflicts of interest arising from the provision of digital payment token services to you.
2. Our operational model is designed to inherently minimise such occurrences. Nonetheless, we have implemented robust measures to identify, manage and mitigate any theoretical conflicts that may arise. These controls are part of our broader commitment to ensuring fair outcomes for users and maintaining trust in our services. Below, we outline the key safeguards and areas we continue to monitor as part of our conflict management programme.

Employee-related conflicts of interest

1. To mitigate any risk of an employee-related conflicts of interest arising and affecting the provision of any Service to you, StraitsX implements multiple measures to mitigate these risks: (i) all employees adhere to internal guidelines on responsibilities and prohibiting conflicts of interest or inappropriate personal gain; (ii) internal controls to segregate duties in critical operational areas; (iii) strictly prohibiting employees from using confidential customer or non-public market information for personal gain.

Inter-group service offerings

1. To mitigate any risk of a specific StraitsX entity’s interest swaying business decisions and service offerings to you, StraitsX (i) maintains a dedicated operational and management team focused primarily on regulated digital payment token services which is distinct from other group business lines, and (ii) identifies which specific entity within the corporate group is providing a particular service when it is integrated with or linked from StraitsX’s platform.

Specific conflict of interest situations

1. StraitsX's operational model is designed to mitigate certain conflicts of interest. We do not operate a market for digital payment token services, acting solely as a distributor for SCS tokens. Furthermore, StraitsX does not function as a broker or agent, meaning we do not accept customer orders for transmission to other digital payment token service providers for fulfillment. While StraitsX does carry out OTC services, this activity is not performed concurrently with operating a market or acting as a broker/agent. Therefore, the specific conflicts of interest related to the concurrent execution of certain digital payment token activities, do not arise for StraitsX.

Issuance of own or related tokens

1. StraitsX issues its own digital assets (e.g. XSGD, XUSD). These are considered stablecoins that are designed to maintain a peg to an official currency. Regardless, unlike other digital assets in the broader market, StraitsX does not have the ability to influence the value or activities relating to these tokens due to the following:
   
   1. Stablecoin design - all StraitsX Tokens are designed to maintain a 1:1 peg with a specific fiat currency, which inherently limits price volatility; and
   2. No exchange function - StraitsX does not operate a digital assets exchange, meaning we do not facilitate secondary market trading where prices may be subject to market manipulation or speculative volatility.
2. Regardless, to further enhance user protection and transparency, StraitsX has implemented the following safeguards:
   
   1. Clear token identification - our issued StraitsX Tokens are explicitly identified and labelled across our platform and in all documentation, providing clear transparency of their origin.
   2. Regulatory alignment - Some of our StraitsX Tokens, such as the XSGD and XUSD, have been acknowledged by the Monetary Authority of Singapore to be compliant with the upcoming stablecoin regulatory framework (as published by them in the ‘Response to Public Consultation on Proposed Regulatory Approach for Stablecoin-related activities’ paper dated 15 August 2023). This means that XSGD and XUSD are fully backed by Reserve Assets equivalent to at least 100% of the par value of all outstanding StraitsX Tokens in circulation at all times. These Reserve Assets are held by STX XSGD (i.e. StraitsX SGD Issuance Pte Ltd) (for XSGD) and STX XUSD (i.e. StraitsX USD Issuance Pte Ltd) (for XUSD) in segregated accounts on trust for the XSGD and XUSD token-holders, separate from the assets of STX XSGD and STX XUSD. Please see the Additional T&Cs pertaining to Risk Warnings, Notices & Disclosures for the terms and conditions in relation to the safeguarding of the Reserve Assets backing the XSGD and XUSD.
   3. Public transparency - StraitsX has published whitepapers for the issued StraitsX Tokens (such as for XSGD and XUSD), which outline key technical, operational and risk features. These whitepapers are available on the StraitsX Website.
3. StraitsX inherently holds some of its issued digital assets for operational necessities, such as for managing operational floats. All such holdings are prudently managed following internal liquidity management policies.

Conflict of interest in providing support to Non-StraitsX Tokens

1. StraitsX does not receive any incentives, such as commission rebates or similar payments, directly from the issuers of Non-StraitsX Tokens or any third parties in connection with supporting these Non-StraitsX Tokens. Supported Non-StraitsX Tokens are evaluated based on fundamental aspects like business profile, technical security, regulatory compliance, and operational feasibility.

DISCLOSURES ABOUT SUPPORTED NON-STRAITSX TOKENS

1. StraitsX is not a digital asset exchange. We only support a limited range of StraitsX Tokens and Non-StraitsX Tokens, all of which are stablecoins. These digital assets are designed to be pegged to specific fiat currencies (e.g. USD, SGD) and are backed by assets, with the intention of maintaining minimal price fluctuations. To ensure that only high-quality and appropriate digital assets are supported on our platform, StraitsX applies a rigorous evaluation process before we support any third-party digital assets (i.e. a Non-StraitsX Token), which we have outlined below.

Evaluation of supported digital assets

1. Prior to supporting any third-party digital assets (i.e. Non-StraitsX Tokens), the StraitsX Digital Asset Review team (“DAR”) uses the Supported Digital Token Framework to evaluate Non-StraitsX Tokens to support. The framework includes the following:
   
   1. Business profile assessment: The DAR team analyses the Non-StraitsX Token’s issuer or foundational team, evaluating their reputation, regulatory standing, governance structure, financial stability, and track record, alongside assessing the Non-StraitsX Token’s purpose, utility, market capitalisation, liquidity, and community adoption.
   2. Technical and security standards: The DAR team evaluates the technical aspects of the digital token, the underlying security infrastructure of the digital token’s blockchain protocol, to understand the overall technological risk of the digital token and its network.
   3. Regulatory analysis: The DAR team ascertains the digital token’s nature, categorisation under Singapore law, and compliance with MAS regulatory requirements, including the relevant acts (e.g. Payment Services Act 2019) and relevant notices.

Periodic review and suspended support for Non-StraitsX Tokens

1. StraitsX continuously monitors the supported Non-StraitsX Tokens to ensure they meet our standards on an ongoing basis. Where a Non-StraitsX Tokens temporarily fails to meet one or more of the criteria mentioned above, StraitsX may suspend support for a Non-StraitsX Token. Where a Non-StraitsX Tokens consistently fails to meet one or more of the aforementioned criteria, StraitsX may permanently cease support for that Non-StraitsX Token.
2. StraitsX also conducts ad-hoc reviews when trigger events such as changes in industry standards, new regulations, adverse media, or sanctions occur. These trigger events, if material, can also affect StraitsX’s decision on whether to continue supporting a Non-StraitsX Token.

Rights and options of customers in the event of suspended support for a Non-StraitsX Token

1. In the event StraitsX decides to cease support for a particular Non-StraitsX Token, the following process will be initiated:
   
   1. You will be notified via a Communication as soon as reasonably practical. While StraitsX aims to provide advance notice for discontinued support of any Non-StraitsX Token, urgent security or regulatory directives may lead to shorter notification periods.
   2. Some Services (e.g. transfer in, swap or redemption of that Non-StraitsX Token, functionalities, features) may be halted or ceased.
   3. You will have the ability to withdraw your Non-StraitsX Tokens from your StraitsX Digital Assets account to a self-custodied wallet during the designated withdrawal period, and can reach out to StraitsX Support for assistance. Where you fail to withdraw the relevant Non-StraitsX Tokens within the designated withdrawal period, please note that, in accordance with clause 16.1 of the General T&Cs, StraitsX may, at its sole and absolute discretion, convert them into (i) other forms of StraitsX Tokens; (ii) other supported Non-StraitsX Tokens; and/or (iii) supported fiat currency.

OTHER RISK WARNINGS & DISCLOSURES

Reversal of payments/transfers 

1. Payments/Transfers received in your StraitsX Accounts may be reversed at a later time, for example, if a payment/transfer is subject to a Chargeback, Reversal, Claim or is otherwise invalidated. This means that a payment/transfer may be reversed from your StraitsX Accounts after you have provided the sender the products/goods/assets/property or services that were purchased.

Unauthorised transactions

2. You should be aware of the possibility of unauthorised transactions from your StraitsX Accounts or receiving payments from unauthorised transactions from a third party’s account. You must be familiar, and adhere, with the user obligations (as reflected in in the Additional T&Cs pertaining to StraitsX Accounts) that can help protect you from the risks of unauthorised transactions by safeguarding your StraitsX Accounts’ IDs, passwords, API secret keys, and any other codes you use to access and use our StraitsX Services or to send any instruction to us.
   

Closure, suspension or limiting access to StraitsX Accounts or Services 

3. We may close, suspend, or limit your access to your StraitsX Accounts or the StraitsX Services, and/or limit access to your funds if you violate these StraitsX T&Cs, or any other agreement you enter into with StraitsX.
   

Technical risk

4. The StraitsX Services, StraitsX Dashboard or any StraitsX platform may experience unforeseen outages or technical errors beyond StraitsX’s reasonable control. Should such unforeseen outages or technical errors occur, StraitsX will take reasonable steps to restore functionality as promptly as possible.
   

Smart contract risk and/or protocol risk 

5. There is always a risk of hacks, cyber-attacks, distributed denials of service or errors, failures, vulnerabilities, flaws in the programming or source code or defects into the StraitsX Accounts and Services, StraitsX Dashboard, any StraitsX platform or any third-party platform that StraitsX relies on in powering its Services. While StraitsX implements an internal monitoring mechanism, the occurrence of such adverse events may affect the ability of StraitsX to repay or fulfil any withdrawal requests from StraitsX users.
   

Regulatory risk

6. You are solely responsible for understanding and complying with any and all laws, rules and regulations of your specific jurisdiction that may be applicable to you in connection with your use of our StraitsX Services and your StraitsX Accounts. There is also a real risk that regulatory bodies may implement changes to Applicable Laws and regulations affecting StraitsX Tokens and Non-StraitsX Tokens and any of the StraitsX Services. While StraitsX has taken every reasonable effort to ensure that our StraitsX Services are compliant with Applicable Laws, any changes in Applicable Laws or other regulatory actions could negatively impact StraitsX, including but not limited to the availability of any of our StraitsX Services to users in certain jurisdictions.
   

Not an offer or solicitation 

7. The content of the StraitsX Website and the StraitsX Earn services do not constitute an offer to buy or sell or a solicitation of an offer to buy or sell investments, securities, partnership interests, commodities or any other financial instruments. The content of the StraitsX Website and the StraitsX Earn services also do not constitute, and may not be used for or inconnection with, an offer or solicitation by anyone in any jurisdiction in which such an offer or solicitation is not authorised or permitted, or to any person to whom it is unlawful to make such offer or solicitation.
   

Taxes

1. StraitsX does not provide any legal, tax or financial advice, nor make any offers, recommendations or invitations to deal in digital assets. It is your responsibility to determine what, if any, taxes apply to your intended use of the StraitsX services, and it is your responsibility to collect, report and remit the correct tax to the appropriate tax authority. StraitsX is not responsible for determining whether taxes apply to your intended use of the StraitsX Services.