Terms of Use
Last Updated: September 1, 2026
1. INTRODUCTION, NATURE OF SERVICES, AND ACCEPTANCE
These Terms of Use (“Terms”) are entered into by and between you (“User,” “you,” or “your”) and Everyrealm Inc., a Delaware corporation, doing business as Interstice Digital (“Interstice,” “Company,” “we,” “us,” or “our”).
These Terms govern your access to and use of Interstice Digital’s platform, including its website, interfaces, APIs, integrations, documentation, and any related infrastructure, tools, or services (collectively, the “Platform”).
These Terms include and incorporate by reference any annexes, schedules, product-specific terms, and supplemental terms and conditions (collectively, the “Annexes”), each of which governs specific services, products, or functionalities made available through the Platform, including, without limitation, the Cross-Chain Swap Engine and the Venezuela Protocol.
Each Annex forms an integral part of these Terms and applies exclusively to the applicable Service. In the event of any inconsistency between these Terms and an Annex, the Annex shall govern solely with respect to the relevant Service, and these Terms shall otherwise remain in full force and effect.
By accessing, browsing, or using the Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms, the Privacy Policy, the KYC/KYB Terms of Service, and all applicable Annexes and documents incorporated herein by reference. If you do not agree to these Terms, you must not access or use the Platform.
1.1 Nature of the Platform
Interstice Digital operates a non-custodial digital infrastructure platform designed to support institutional interaction with decentralized networks, digital assets, and cross-chain environments. The Platform provides technical infrastructure, compliance-support tooling, identity and verification integrations, structured data outputs, and related functionality in connection with user-directed activity.
Except where Interstice expressly acts as a direct counterparty to a transaction in accordance with Section 1.3 and any applicable Annex or transaction-specific terms, Interstice does not take custody of assets, hold or manage private keys, execute, process, or settle transactions, or act as an intermediary, agent, broker, dealer, exchange, financial institution, or other transactional service provider.
All activity conducted using or in connection with the Platform is initiated and determined solely by the relevant users and, where applicable, their selected counterparties. Transactions are executed through wallets, smart contracts, protocols, blockchain networks, or other systems that are not owned or controlled by Interstice.
Where Interstice expressly acts as a direct counterparty, it does so solely as principal, for its own account and using its own assets or balance sheet, and not as an agent, broker, fiduciary, representative, custodian, or intermediary for the User or any third party. Interstice’s limited role as a disclosed direct counterparty does not give it custody or control over the User’s wallet, private keys, accounts, or digital assets.
1.2 Informational and Infrastructure-Only Role
All information, data, outputs, and materials made available through the Platform are provided for informational, technical, and compliance-support purposes only. Nothing on the Platform constitutes legal, financial, investment, tax, or regulatory advice, and no content should be relied upon as a substitute for independent professional judgment.
Except where Interstice is expressly identified as a direct counterparty pursuant to Section 1.3, nothing on the Platform constitutes a solicitation, recommendation, endorsement, or offer to buy, sell, or otherwise transact in any digital asset, financial instrument, security, or investment product. Any quote provided by Interstice in its capacity as a disclosed direct counterparty constitutes proposed terms for a bilateral principal transaction only and does not constitute investment advice, a recommendation, endorsement, or solicitation based on the User’s individual objectives or circumstances.
Any decision to engage in transactions, interact with counterparties, or utilize blockchain infrastructure is made solely by the user, at their own risk and discretion.
1.3 No Transaction Control; Limited Direct-Counterparty Role
The Platform may present or display information relating to potential transaction parameters, including pricing data, estimated costs, potential counterparties, or possible execution pathways across third-party systems or blockchain networks. Such information is provided on a neutral and informational basis for User evaluation.
Interstice does not recommend, prioritize, rank, optimize, or endorse any transaction, route, asset, price, or counterparty. Except where Interstice is expressly identified as the direct counterparty, Interstice does not initiate, control, execute, or settle transactions and does not participate in any transaction as principal, intermediary, or agent.
Notwithstanding the foregoing, Interstice may, in limited circumstances and where expressly disclosed to the User before the User authorizes or enters into the applicable transaction, provide a quote and act as the direct counterparty to that transaction. In such circumstances, Interstice acts exclusively as principal, for its own account and using its own assets or balance sheet, and not on behalf of the User or any third party.
Any transaction in which Interstice acts as direct counterparty constitutes a bilateral transaction between the User and Interstice and may be subject to additional transaction-specific terms, disclosures, pricing, fees, or conditions presented to the User before authorization. The existence of this limited direct-counterparty capability does not mean that Interstice acts as counterparty to every transaction made available through the Platform.
Participation in any transaction is entirely voluntary. The User may decline, reject, or elect not to proceed with any proposed transaction or quote at any time before the User provides final authorization or executes the applicable transaction.
1.4 Regulatory Status Disclaimer
Interstice Digital is not registered with or regulated by the U.S. Securities and Exchange Commission or any other regulatory authority as an investment adviser, broker-dealer, exchange, alternative trading system, futures commission merchant, swap execution facility, clearing agency, bank, depository institution, or money services business, unless expressly stated otherwise in writing.
Nothing in the Platform, the Services, or these Terms shall be interpreted as a representation that Interstice is licensed, regulated, or approved by any governmental or regulatory authority, or that it operates within any particular regulatory classification.
1.5 Regulatory Uncertainty and User Responsibility
The regulatory landscape applicable to digital assets, blockchain infrastructure, and cross-chain systems is rapidly evolving and subject to uncertainty.
Interstice makes no representation that the Platform complies with the laws of any jurisdiction. Users are responsible for determining the legality of their activities and ensuring compliance with applicable law.
1.6 Sanctions and Compliance Framework
Interstice maintains internal policies and procedures designed to support compliance with applicable regulatory frameworks, including anti-money laundering (AML), know-your-customer (KYC/KYB), sanctions regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and counter-terrorism financing (CTF) laws.
Such measures are risk-based, informational, and supportive in nature and do not constitute legal determinations, regulatory assurances, or guarantees of permissibility. Interstice does not represent that any activity conducted through or in connection with the Platform is compliant with applicable sanctions or regulatory regimes.
1.7 Forward-Looking Statements
The Platform may contain statements regarding anticipated features, technical capabilities, product developments, or business plans that constitute forward-looking statements. These statements are based on current expectations and assumptions and are subject to risks and uncertainties that may cause actual results to differ materially.
Interstice undertakes no obligation to update or revise any forward-looking statements to reflect subsequent events or changes in circumstances, and users should not place undue reliance on such statements.
1.8 Technology, Market, and Digital Asset Risk
The use of digital assets, blockchain networks, smart contracts, wallets, and cross-chain infrastructure involves significant financial, market, technological, operational, cybersecurity, regulatory, and liquidity risks.
Such risks include, without limitation, fluctuations or loss in the value of digital assets; changes in market conditions, liquidity, demand, utility, or market acceptance; price volatility; unavailable or withdrawn liquidity; counterparty default or insolvency; software vulnerabilities; smart contract failures; network congestion; protocol malfunctions; cybersecurity incidents; key-management failures; inaccurate or delayed third-party data; interoperability failures; regulatory restrictions; and delayed, failed, incomplete, or irreversible transactions.
The value, performance, liquidity, utility, and market acceptance of any digital asset may change materially and without notice. Interstice does not guarantee the current or future value, performance, liquidity, utility, availability, or market acceptance of any digital asset or the outcome of any transaction.
Interstice does not own, operate, or control underlying blockchain networks, protocols, smart contracts, wallets, or other Third-Party Systems and does not guarantee their availability, performance, security, functionality, or continued operation.
The User voluntarily assumes all risks associated with digital assets and any transaction or activity undertaken through or in connection with the Platform and remains solely responsible for determining whether any such transaction or activity is appropriate.
1.9 Acceptance and Binding Effect
By clicking “accept,” checking an acceptance box, creating an account, submitting onboarding information, accessing the Platform, or using any Service, you acknowledge that you have read, understood, and agree to be legally bound by these Terms, the Privacy Policy, the KYC/KYB Terms of Service, and all applicable Annexes and other documents expressly incorporated by reference.
You further acknowledge that you understand the nature of Interstice’s role, including its general role as a non-custodial infrastructure provider and its ability, where expressly disclosed, to act as a direct counterparty solely as principal and for its own account.
You acknowledge that you have had the opportunity to seek independent legal, financial, investment, tax, regulatory, and other professional advice before accessing or using the Platform or entering into any transaction.
Your electronic acceptance of these Terms shall have the same legal force and effect as a handwritten signature. If you do not agree to the applicable contractual documents, you must not create an account, access the Platform, or use any Service.
2. ELIGIBILITY, INSTITUTIONAL USE, AND JURISDICTION
2.1 Eligibility Requirements
The Platform is intended solely for use by legally capable persons and entities that can form binding contracts under applicable law. By accessing or using the Platform, you represent and warrant that you meet these requirements and that your access to and use of the Platform does not violate any applicable law, regulation, or contractual obligation.
Interstice reserves the right, at its sole discretion, to determine eligibility criteria and to restrict, deny, suspend, or terminate access to any user that does not meet such criteria or that presents legal, regulatory, or reputational risk. Nothing in these Terms shall be construed as granting any right to access or use the Platform.
2.2 Institutional and Professional Use
The Platform is designed primarily for use by institutional participants, professional counterparties, and other sophisticated users with experience in digital assets, financial infrastructure, or compliance environments. The Platform is not intended for retail or unsophisticated users.
By accessing or using the Platform, you represent and warrant that you possess sufficient knowledge and experience to understand the technical, legal, and financial risks associated with digital assets, blockchain-based systems, and cross-chain infrastructure, and that you are capable of independently evaluating such risks and your compliance obligations.
You further acknowledge and agree that all decisions relating to transaction parameters, counterparties, and execution are made solely and independently by you, and that the Platform does not impose, determine, or enforce any default outcome, execution path, or transaction decision.
Interstice does not verify the level of sophistication, expertise, or qualifications of any user and makes no representation as to the suitability of the Platform for any particular user.
2.3 Jurisdictional Use and Restrictions
The Platform is not intended for use in any jurisdiction where its access, availability, or use would be unlawful or would require Interstice to obtain licensing, registration, or regulatory approval.
Users who access or use the Platform from any jurisdiction do so on their own initiative and are solely responsible for ensuring that such access and use comply with all applicable laws and regulations.
Interstice may, at any time and without notice, restrict, suspend, or disable access to the Platform in any jurisdiction where it determines, in its sole discretion, that continued operation may present legal or regulatory risk or require registration, licensing, or authorization.
2.4 Restricted Countries
Access to and use of the Platform and any Service is prohibited for any individual or entity that is located in, organized or incorporated under the laws of, ordinarily resident in, or accessing the Platform from any of the following countries or territories (collectively, the “Restricted Countries”):
Afghanistan; Algeria; Bangladesh; Belarus; Burundi; Cambodia; Cameroon; Central African Republic; Congo (Brazzaville); Cote D’Ivoire; Cuba; Democratic People’s Republic of Korea (North Korea); Democratic Republic of the Congo; Eritrea; Ethiopia; Guinea Bissau; Haiti; Iran; Iraq; Kazakhstan; Kenya; Kosovo; Lao People’s Democratic Republic (Laos); Lebanon; Libya; Mali; Morocco; Mozambique; Myanmar (Burma); Nicaragua; Nigeria; Pakistan; Palestine; Panama; Philippines; Russian Federation; Somalia; South Sudan; Sri Lanka; Sudan; Syrian Arab Republic (Syria); Tanzania; United States of America; Uganda; Ukraine; Uzbekistan; Venezuela; and Yemen.
In addition to the Restricted Countries identified above, Interstice may impose additional geographic or jurisdictional restrictions with respect to any particular Service, product, feature, or functionality made available through the Platform. Any such restriction applies solely to the applicable Service, product, feature, or functionality and does not, by itself, restrict access to other Services made available through the Platform.
Without limiting the foregoing, the United States of America, including its states, territories, and possessions (the “United States”), is a Restricted Country solely with respect to the Canton Swap functionality. Accordingly, the Canton Swap functionality may not be accessed or used by any individual or entity that is located in, organized or incorporated under the laws of, ordinarily resident in, or accessing such functionality from the United States.
For the avoidance of doubt, the designation of the United States as a Restricted Country solely with respect to the Canton Swap functionality does not, by itself, prohibit a User from accessing or using other Services made available through the Platform, subject in all cases to these Terms, any applicable Annex, and any other eligibility, jurisdictional, or compliance restrictions applicable to such Service.
You represent and warrant that you are not located in, organized or incorporated under the laws of, ordinarily resident in, or accessing or using the Platform from any Restricted Country.
You shall not access or use the Platform, directly or indirectly, on behalf of, for the benefit of, or through any person or entity located in, organized or incorporated under the laws of, or ordinarily resident in a Restricted Country. You shall not use any virtual private network (VPN), proxy, anonymization service, intermediary, or other mechanism for the purpose of circumventing or attempting to circumvent any geographic or jurisdictional restriction imposed by Interstice.
The designation of a country or territory as a Restricted Country reflects Interstice’s internal legal, regulatory, compliance, risk-management, operational, or business considerations and does not constitute a representation that such country or territory is subject to comprehensive sanctions or otherwise prohibited under applicable law.
Interstice may add, remove, or otherwise modify any Restricted Country at any time, in its sole discretion, including in response to changes in applicable law, sanctions regimes, regulatory requirements, risk assessments, or business considerations. Interstice may restrict, suspend, or terminate access to the Platform where it determines that a User is located in, organized or incorporated under the laws of, ordinarily resident in, or accessing the Platform from a Restricted Country in violation of this Section.
2.5 Sanctions and Restricted Persons
The Platform may not be accessed or used by any individual or entity that is subject to applicable sanctions or restrictions, including any person that is located in, organized under the laws of, or ordinarily resident in a comprehensively sanctioned jurisdiction, identified on any sanctions list maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) or any equivalent authority, or owned or controlled, directly or indirectly, by any such person or entity.
By accessing or using the Platform, you represent and warrant that you are not subject to any such restrictions and that you will not use the Platform in connection with any activity involving sanctioned persons, entities, or jurisdictions.
Interstice reserves the right to restrict, suspend, or terminate access to the Platform where it reasonably determines that a user may be in violation of applicable sanctions laws or related restrictions.
2.6 No Reliance on Platform Availability
Interstice does not guarantee that the Platform, or any portion of it, will be available in any specific jurisdiction or to any particular user at any given time.
Access to the Platform may be modified, restricted, suspended, or discontinued at any time due to legal, regulatory, operational, or business considerations, without liability to Interstice.
3. ACCOUNT ACCESS, VERIFICATION, AND COMPLIANCE CONTROLS
3.1 Access to the Platform
Access to certain features or functionalities of the Platform may require registration, onboarding, or the submission of additional information by the user. Interstice reserves the right, at its sole discretion, to determine eligibility criteria and to grant, restrict, suspend, or revoke access to the Platform at any time based on legal, regulatory, operational, or risk considerations. Access may be conditioned on the nature of the user, jurisdiction, intended use of the Platform, or other factors deemed relevant by Interstice. Nothing in these Terms shall be construed as creating any right of access to the Platform or any of its features.
Access to and continued use of the Cross-Chain Swap Engine and any other transaction-related functionality may be conditioned upon the User’s successful completion and continued satisfaction of identity verification, KYC/KYB, sanctions screening, wallet screening, and any other onboarding, compliance, eligibility, or risk-management procedures required by Interstice.
Interstice may require additional or updated information at any time and may suspend, restrict, or terminate access if the User fails to complete or satisfy any applicable requirement. Completion of any verification or screening process does not constitute a representation, certification, or guarantee by Interstice that the User or any proposed transaction complies with applicable law.
3.2 Separate KYC/KYB Terms and Data Processing
Where a user undergoes identity verification, onboarding, or screening, such activities shall be governed by Interstice’s KYC/KYB Terms of Service, which are incorporated by reference into these Terms.
Any collection and processing of personal or business information in connection with such activities is governed by the Privacy Policy, as further described in Section 13.
3.3 Nature of Verification and Compliance Activities
Any identity verification, screening, or compliance-related activity conducted by or on behalf of Interstice is performed solely for access control, internal risk management, and compliance-support purposes.
Such activities are informational, risk-based, and inherently limited in scope. They do not constitute a representation, certification, or guarantee that any user is compliant with applicable laws or regulations, and they do not create any obligation on the part of Interstice to monitor, supervise, validate, or enforce user activity on an ongoing basis.\
Interstice does not act as a financial institution, intermediary, or regulated entity in connection with such activities and does not assume responsibility for the legality, permissibility, or regulatory treatment of any user’s conduct.
3.4 Screening and Risk-Based Controls
Interstice may, at its discretion, conduct screening of users, associated persons, or related identifiers against internal systems, publicly available sources, or third-party datasets, including sanctions lists and risk indicators.
Such screening is inherently probabilistic, subject to limitations in underlying data sources, and performed on a discretionary and risk-based basis. Interstice makes no representation or warranty as to the accuracy, completeness, or timeliness of any screening activity or result and does not guarantee that any such screening will identify all relevant risks.
Interstice may apply internal criteria, methodologies, and thresholds, which may be modified at any time without notice, in determining access to the Platform.
3.5 Access Restrictions and Suspension
Interstice reserves the right to restrict, suspend, or terminate access to the Platform, in whole or in part, at any time and without prior notice, where it reasonably determines that a user has failed to satisfy onboarding or verification requirements, has provided inaccurate, incomplete, or misleading information, may be subject to sanctions or regulatory restrictions, or where continued access may expose Interstice to legal, regulatory, or reputational risk.
Any such restriction or suspension relates solely to access to the Platform and shall not, by itself, cancel, reverse, or modify any external system, asset, transaction, or relationship. Except for any obligation expressly undertaken by Interstice as a disclosed direct counterparty, all such systems, assets, transactions, and relationships remain independent of and outside Interstice’s control.
The submission of false, misleading, inaccurate, incomplete, or outdated information, including by omission, constitutes a material breach of these Terms. Interstice may, without prior notice or liability, reject onboarding, decline or delay any request, require additional information, or restrict, suspend, or terminate the User’s access to the Platform.
3.6 No Monitoring or Transaction Oversight
Interstice does not undertake any obligation to monitor user activity, transactions, or interactions with third parties on an ongoing basis.
The Platform does not provide transaction monitoring, surveillance, enforcement, or compliance supervision services. Any compliance-related tools, outputs, or data made available through the Platform are informational in nature only and do not constitute oversight, control, or regulatory enforcement.
3.7 User Responsibility for Compliance
You acknowledge and agree that you are solely responsible for complying with all applicable laws and regulations, conducting independent due diligence on counterparties, transactions, and activities, and determining whether your use of the Platform is lawful in your jurisdiction.
Interstice does not provide legal, regulatory, or compliance determinations and does not assume any responsibility for user compliance.
4. SCOPE AND NATURE OF SERVICES
4.1 Overview of the Platform
Interstice Digital operates a non-custodial infrastructure platform designed to support institutional interaction with decentralized networks, digital assets, and cross-chain environments.
Except where Interstice expressly acts as a direct counterparty pursuant to Section 1.3 and the applicable Annex or transaction-specific terms, the Platform does not provide execution, settlement, custody, routing, matching, or intermediary services. Where Interstice acts as a disclosed direct counterparty, its role is limited to entering into the applicable bilateral transaction as principal and for its own account and does not convert the Platform generally into an exchange, trading venue, broker, custodian, matching engine, or financial intermediary.
All services provided by Interstice are informational, technical, and supportive in nature and are intended solely to enable users to independently access, evaluate, and interact with external systems, counterparties, and blockchain networks.
4.2 Product Structure
The Platform may include multiple modules, products, or functionalities (each, a “Service”), including cross-chain infrastructure functionality and compliance-oriented infrastructure functionality.
Each Service may have distinct characteristics, technical implementations, and applicable conditions of use. Additional terms applicable to specific Services may be set forth in separate annexes, product documentation, or supplemental agreements, which are incorporated by reference into these Terms.
4.3 Cross-Chain Infrastructure Functionality
Certain components of the Platform may enable users to view, configure, or interact with information relating to cross-chain activity, including potential transaction parameters, pricing data, estimated costs, or possible execution pathways across independent blockchain networks or third-party systems.
Such information is presented on a neutral and informational basis, derived from predefined and objective parameters, and made available solely for user evaluation. Interstice does not recommend, prioritize, rank, or endorse any specific transaction, route, asset, or counterparty.
Users retain full control over all decisions relating to transaction parameters, counterparties, and execution. Except where Interstice is expressly identified as the relevant Liquidity Provider and direct counterparty, any interaction with blockchain networks, smart contracts, or liquidity sources is initiated and conducted independently by the User and occurs outside Interstice’s control. Where Interstice is the disclosed Liquidity Provider, the User remains solely responsible for accepting and authorizing the applicable transaction.
4.4 Compliance and Documentation Functionality
The Platform may also provide tools and infrastructure designed to support identity verification, compliance workflows, and the generation of structured records, audit trails, or documentation related to user activity.
Such functionality is limited to the collection, validation, analysis, and organization of information for compliance-support purposes and does not constitute a determination of legal or regulatory compliance. Any outputs, reports, or documentation generated through the Platform are informational in nature, may be incomplete or probabilistic, and may be subject to interpretation.
Interstice does not represent or warrant that any such outputs will be accepted, relied upon, or given legal effect by any regulatory authority or third party.
4.5 No Execution, Routing, or Discretion
Except where Interstice is expressly identified as a direct counterparty, the Platform does not execute transactions or exercise discretion over User decisions. Any information relating to potential transaction parameters, counterparties, quotes, or execution pathways is presented on a neutral basis and is subject entirely to User selection and control.
Where Interstice provides a quote or acts as a direct counterparty, it does so solely as principal, for its own account, and in accordance with Section 1.3 and the applicable Annex or transaction-specific terms. The User remains solely responsible for accepting or rejecting the quote and for reviewing and authorizing the transaction.
4.6 Interaction with Third-Party Systems
The Platform may enable users to access, connect to, or interact with third-party systems, including blockchain networks, smart contracts, or external service providers.
All such systems operate independently of Interstice. Interstice does not control their availability, performance, security, or outcomes and is not responsible for any act, omission, or failure of any third party. Any interaction with such systems is undertaken solely by the user and subject to the applicable terms of such third parties.
4.7 Product-Specific Terms and Annexes
Certain Services or functionalities offered through the Platform may be subject to additional terms, conditions, or disclosures, including product-specific annexes (the “Annexes”).
Such Annexes are incorporated by reference into these Terms and form an integral part of the agreement between you and Interstice. In the event of any conflict between these Terms and an applicable Annex, the Annex shall govern solely with respect to the relevant Service.
4.8 No Guarantee of Availability or Continuity
Interstice reserves the right to modify, suspend, or discontinue any Service, feature, or functionality of the Platform at any time, with or without notice.
The availability, scope, and characteristics of any Service may change due to technical, regulatory, operational, or business considerations. Interstice shall have no liability arising from any modification, limitation, or discontinuation of any part of the Platform.
5. USER OBLIGATIONS AND COMPLIANCE RESPONSIBILITIES
5.1 General Compliance Obligation
You shall use the Platform strictly in accordance with these Terms and all applicable laws, rules, and regulations. Access to and use of the Platform is conditioned on your ongoing compliance with this Section, and any failure to comply may result in immediate restriction, suspension, or termination of access.
You acknowledge that the Platform operates solely as an infrastructure and compliance-support layer and that your use of the Platform does not alter, reduce, or transfer any legal or regulatory obligation applicable to you.
5.2 Independent Legal and Regulatory Responsibility
You are solely responsible for determining the legality, regulatory treatment, and permissibility of your activities in connection with the Platform, including any interaction with digital assets, blockchain networks, counterparties, or cross-border arrangements.
Interstice does not provide legal, financial, regulatory, or compliance advice and does not make any determination as to whether your activities are lawful or compliant with applicable law. You agree to obtain independent legal, regulatory, and professional advice as necessary to assess your obligations and risks.
5.3 Sanctions, AML, and Financial Crime Compliance
You represent, warrant, and covenant that your use of the Platform will at all times comply with all applicable laws and regulations relating to sanctions, anti-money laundering (AML), counter-terrorism financing (CTF), and financial crime.
You shall not use the Platform in connection with any person, entity, or jurisdiction subject to applicable sanctions, any activity designed to evade, circumvent, or violate sanctions or financial crime laws, or any transaction or arrangement involving proceeds of unlawful activity. You further agree that your activities will not cause Interstice to be in violation of any applicable law or regulation.
5.4 No Circumvention or Misrepresentation
You shall not use, and shall not permit any third party to use, the Platform to circumvent, evade, or attempt to circumvent any applicable law, regulation, or compliance requirement, to misrepresent identity, ownership, control, source of funds, or business purpose, or to obscure or conceal the nature of any activity, relationship, or transaction.
All information provided by you must be accurate, complete, and not misleading, whether by omission or otherwise.
5.5 Responsibility for Transactions and Counterparties
You acknowledge and agree that all decisions relating to counterparties, transaction parameters, and execution are made solely and independently by you. You are solely responsible for selecting counterparties, conducting due diligence on any counterparty, asset, or transaction, and evaluating all risks associated with any activity conducted in connection with the Platform.
Interstice does not vet, verify, recommend, or endorse any counterparty, asset, or transaction and does not assume responsibility for any outcome.
The User represents and warrants that any transaction conducted through or in connection with the Platform is undertaken for the User’s own account or for the account of a legal entity that the User is duly authorized to represent and has fully disclosed to Interstice.
The User shall not access or use the Platform as an undisclosed agent, nominee, intermediary, broker, representative, or conduit for any other person or entity. The User shall promptly disclose any person or entity for whose account or benefit the User accesses the Platform or undertakes any transaction and shall provide evidence of its authority to act upon request.
Where Interstice is expressly identified as the direct counterparty, the User remains solely responsible for determining whether to transact with Interstice, evaluating the applicable pricing and terms, and conducting any legal, financial, tax, regulatory, or other review the User considers appropriate.
5.6 No Reliance on the Platform
You shall not rely exclusively on the Platform, or on any data, output, or functionality provided through it, for purposes of determining compliance, legality, or risk.
Any information provided through the Platform is inherently limited, may be incomplete or inaccurate, and is provided solely for informational and support purposes. All decisions made by you are undertaken at your sole risk and responsibility.
5.7 No Substitution for Compliance Programs
You acknowledge that the Platform does not replace, and is not intended to replace, your internal compliance program, policies, procedures, or controls.
You remain solely responsible for implementing and maintaining appropriate compliance frameworks, including those relating to sanctions, AML, and financial regulation.
5.8 Cooperation and Information Requests
You agree to respond promptly to reasonable requests for information, documentation, or clarification and to cooperate with any compliance-related inquiry, review, or assessment conducted by Interstice.
Failure to provide requested information or to cooperate may result in restriction or termination of access to the Platform.
5.9 Responsibility for Access and Use
You are solely responsible for maintaining appropriate controls over access to the Platform, including the management of credentials, permissions, and internal authorization structures.
You shall be responsible for all activities conducted through your account or access credentials, whether authorized or unauthorized.
5.10 No Representation of Interstice
You shall not represent, imply, or suggest that Interstice has approved, endorsed, or validated any activity, transaction, or counterparty, that Interstice has determined that any activity is compliant with applicable law, or that Interstice is acting as an intermediary or advisor in any transaction.
Any such representation shall constitute a material breach of these Terms.
5.11 Ongoing Nature of Obligations
The obligations set forth in this Section are continuous in nature and shall apply at all times during your access to and use of the Platform.
Any breach of this Section shall constitute a material breach of these Terms and may result in immediate enforcement action, including suspension or termination of access, without liability to Interstice.
6. PROHIBITED USES
6.1 General Prohibition
You shall not access or use the Platform, directly or indirectly, in any manner that is unlawful, improper, or inconsistent with the intended purpose of the Platform as described in these Terms.
Without limiting the foregoing, any use of the Platform that attempts to exploit, misuse, or circumvent its intended function as a non-custodial infrastructure and compliance-support system is strictly prohibited.
6.2 Violations of Law and Regulatory Evasion
You shall not use the Platform in connection with any activity that violates, or is intended to violate, any applicable law, rule, or regulation, including those relating to sanctions, anti-money laundering, counter-terrorism financing, securities, commodities, or financial conduct.
You shall not use the Platform to evade, circumvent, or attempt to evade any regulatory requirement, legal restriction, or compliance obligation, including through structuring, misrepresentation, concealment, the use of intermediaries, or any arrangement designed to obscure the true nature of an activity, transaction, or relationship.
6.3 Sanctioned and Restricted Activity
You shall not use the Platform in connection with any individual or entity that is subject to sanctions, any jurisdiction subject to comprehensive sanctions or restrictions, or any activity that may result in a violation of applicable sanctions regimes.
You shall not structure, facilitate, or attempt to structure any activity in a manner designed to obscure the involvement of any sanctioned person, entity, or jurisdiction or to otherwise avoid detection under applicable sanctions frameworks.
6.4 Fraud, Misrepresentation, and Deceptive Conduct
You shall not provide false, inaccurate, incomplete, or misleading information to Interstice or to any third party in connection with your use of the Platform.
You shall not engage in any activity that involves fraud, deception, manipulation, or the concealment of material facts, including with respect to identity, ownership, source of funds, business purpose, or the nature of any transaction or relationship.
6.5 Misuse of the Platform
You shall not use the Platform in any manner that is inconsistent with its intended function as a non-custodial infrastructure and compliance-support system.
You shall not use the Platform as a substitute for your own compliance program or legal obligations, rely on the Platform as a sole or determinative source of compliance, risk, or legal assessment, or use the Platform to create, suggest, or imply the existence of compliance, regulatory approval, or legal validation where none exists.
6.6 Unauthorized Access and Interference
You shall not access or attempt to access any portion of the Platform for which you are not authorized, interfere with, disrupt, or attempt to disrupt the integrity, security, or performance of the Platform, introduce any malicious code, exploit, or harmful component, or circumvent, disable, or otherwise interfere with any security feature or access control mechanism.
6.7 Data Extraction and Use
You shall not, except as expressly permitted, extract, scrape, harvest, or systematically collect data from the Platform, use any automated system, including bots, crawlers, or similar technologies, to access the Platform, or use any data, outputs, or information obtained from the Platform for unauthorized commercial, competitive, or unlawful purposes.
6.8 Misuse of Outputs and Documentation
You shall not use any data, reports, compliance outputs, or documentation generated through the Platform in a misleading or deceptive manner, to misrepresent compliance status or regulatory approval, or in any way that suggests endorsement, validation, certification, or participation by Interstice.
6.9 Third-Party Violations
You shall not use the Platform in a manner that violates the terms, conditions, or policies of any third-party system, protocol, or service with which you interact.
You acknowledge that your use of such third-party systems is governed by their respective terms and that Interstice shall have no responsibility or liability for any violation thereof.
6.10 Enforcement and Remedies
Interstice reserves the right, at its sole discretion and without prior notice, to investigate any actual, suspected, or potential violation of this Section.
Where Interstice determines that a violation has occurred or may occur, it may take any action it deems appropriate, including restricting, suspending, or terminating access to the Platform, without liability and without prejudice to any other rights or remedies available under these Terms or applicable law.
6.11 No Limitation
The prohibitions set forth in this Section are in addition to, and not in limitation of, any other restrictions or obligations set forth in these Terms or under applicable law.
7. THIRD-PARTY SYSTEMS AND BLOCKCHAIN INTERACTIONS
7.1 Independent Third-Party Systems
The Platform may enable users to access, view, or interact with third-party systems, including blockchain networks, smart contracts, protocols, liquidity sources, data providers, or other external services (collectively, “Third-Party Systems”).
All Third-Party Systems operate independently of Interstice. Interstice does not own, operate, control, maintain, or administer any Third-Party System and has no authority over their design, functionality, governance, or performance.
7.2 No Control or Responsibility
Interstice does not control and is not responsible for the availability, uptime, or continued operation of any Third-Party System, the accuracy, completeness, or reliability of any data obtained from such systems, the execution, settlement, or outcome of any interaction conducted through such systems, or any act, omission, error, delay, or failure of any Third-Party System.
Any reliance on or interaction with Third-Party Systems is undertaken solely at your own risk.
7.3 Independent User Interaction
Any interaction with Third-Party Systems, including any interaction with blockchain networks, smart contracts, or counterparties, is initiated, determined, and conducted solely by you.
Except where Interstice expressly acts as a direct counterparty in accordance with Section 1.3, Interstice does not initiate, submit, transmit, or execute transactions on the User’s behalf and does not control or influence transaction outcomes.
Where Interstice acts as a direct counterparty, it may provide a quote and enter into the applicable bilateral transaction solely as principal and for its own account. Any execution or settlement remains subject to the User’s independent authorization and the operation of the applicable wallet, smart contract, blockchain network, or other independent system.
7.4 No Endorsement or Recommendation
The inclusion, display, or availability of any Third-Party System through the Platform does not constitute an endorsement, recommendation, or approval by Interstice.
Any information relating to Third-Party Systems, including pricing, routing, or technical data, is provided on a neutral and informational basis. Interstice does not prioritize, rank, recommend, or otherwise influence the selection of any system, route, or counterparty.
7.5 Third-Party Terms and Conditions
Your use of any Third-Party System is subject to the terms, conditions, and policies of such third party.
You are solely responsible for reviewing and complying with all applicable third-party terms, and Interstice shall have no liability for any failure to do so or for any breach of such terms.
7.6 No Guarantee of Compatibility or Performance
Interstice does not guarantee that the Platform will be compatible with any Third-Party System or that any integration, connection, or interaction will function as expected.
Third-Party Systems may change, become unavailable, or behave unpredictably without notice. Interstice shall not be responsible for any disruption, failure, or loss arising from such changes.
7.7 Blockchain and Smart Contract Risk
Interactions with blockchain networks and smart contracts involve inherent technological and operational risks, including irreversible transactions, software vulnerabilities, protocol errors, network congestion, and unintended outcomes.
Interstice does not audit, verify, or guarantee the security, functionality, or reliability of any blockchain network or smart contract, except where expressly stated in separate written documentation. Any interaction with such systems is undertaken entirely at your own risk.
7.8 No Custody, Customer Accounts, or Control of Assets
Interstice does not provide custodial wallet services and does not maintain customer deposit accounts, custodial accounts, or customer asset balances. Interstice does not receive, hold, safeguard, transmit, or transfer funds or digital assets on behalf of the User and does not possess or control the User’s wallet, private keys, signing authority, or digital assets.
Where Interstice acts as a direct counterparty, any digital asset received, delivered, or transferred by Interstice is received, delivered, or transferred solely in its capacity as principal to the applicable bilateral transaction and not as custodian, agent, money transmitter, broker, fiduciary, or intermediary for the User.
Each transaction must be independently initiated and authorized by the User through the User’s own wallet or signing infrastructure. The User is solely responsible for reviewing all transaction parameters, wallet addresses, assets, amounts, networks, counterparties, quotes, fees, and smart contract interactions before providing authorization.
Blockchain transactions are generally final and irreversible once confirmed. Interstice cannot access, freeze, block, recover, cancel, reverse, redirect, or modify a transaction after it has been authorized and executed through the applicable blockchain network or Third-Party System.
7.9 Changes to Third-Party Integrations
Interstice may, at any time and in its sole discretion, add, remove, or modify integrations with Third-Party Systems.
Such changes may affect the availability, functionality, or scope of the Platform without giving rise to any liability or obligation.
8. INTELLECTUAL PROPERTY
8.1 Ownership of the Platform
The Platform, including all software, systems, interfaces, designs, content, documentation, underlying technology, and all intellectual property rights therein, are and shall remain the exclusive property of Interstice or its licensors.
Nothing in these Terms grants you any ownership interest in the Platform or any portion thereof. All rights not expressly granted are reserved by Interstice.
8.2 Limited License
Subject to your compliance with these Terms, Interstice grants you a limited, non-exclusive, non-transferable, non-sublicensable, and revocable license to access and use the Platform solely for its intended purpose.
This license does not include any right to reproduce, modify, distribute, create derivative works of, publicly display, or otherwise exploit the Platform, except as expressly permitted in writing by Interstice.
8.3 Restrictions on Use
You shall not, and shall not permit any third party to copy, reproduce, modify, or create derivative works of the Platform, reverse engineer, decompile, disassemble, or otherwise attempt to derive source code or underlying logic, remove, alter, or obscure any proprietary notices, or use the Platform in a manner that competes with, replicates, or substitutes for Interstice’s services.
8.4 Ownership of Outputs and Data
Except as otherwise expressly provided in a separate written agreement, all outputs, reports, compliance records, documentation, analytics, and data generated through the Platform, including any derived data, metadata, and analytical outputs, are and shall remain the exclusive property of Interstice.
Such outputs may incorporate proprietary methodologies, models, scoring systems, data sources, and internal processes, and shall not be considered works made for hire or owned by the user, to the maximum extent permitted by law.
Interstice retains the right to use, retain, analyze, and exploit such outputs and derived data for internal purposes, including compliance, analytics, system improvement, product development, and operational optimization, subject to applicable law and the Privacy Policy.
8.5 Feedback
If you provide any feedback, suggestions, ideas, or recommendations regarding the Platform (“Feedback”), you hereby grant Interstice a perpetual, irrevocable, worldwide, royalty-free, and fully transferable right to use, modify, incorporate, and otherwise exploit such Feedback for any purpose, without restriction or compensation.
8.6 Third-Party Intellectual Property
The Platform may include or reference content, data, or systems owned by third parties. All rights in such third-party materials remain with their respective owners.
Nothing in these Terms grants you any right to use any third-party intellectual property except as expressly permitted by the applicable third party.
8.7 Reservation of Rights
All rights not expressly granted to you under these Terms are reserved by Interstice.
9. DISCLAIMERS
9.1 No Advice, Recommendation, or Reliance
Interstice does not provide investment, financial, legal, tax, regulatory, compliance, brokerage, asset-management, fiduciary, or advisory services of any kind.
Interstice does not recommend any particular transaction, digital asset, counterparty, quote, pricing term, trading strategy, investment decision, or course of action. No transaction is required or recommended by Interstice, including where Interstice is expressly identified as a potential direct counterparty.
All decisions concerning the Platform, digital assets, counterparties, and transactions are made independently by the User based on the User’s own evaluation, due diligence, judgment, and professional advice.
The User acknowledges and agrees that it is not relying on any statement, communication, advertisement, marketing material, projection, forecast, estimate, expectation, opinion, roadmap, or other information provided by or on behalf of Interstice as a representation, promise, or guarantee concerning the present or future value, performance, liquidity, utility, demand, availability, or market acceptance of any digital asset, Service, transaction, or technology.
Nothing provided through the Platform or in any communication by Interstice constitutes a guarantee of results or a substitute for independent professional advice.
9.2 No Offer or Solicitation
Except for a quote or transaction terms expressly provided by Interstice in its disclosed capacity as a direct counterparty pursuant to Section 1.3, nothing on the Platform constitutes a solicitation, recommendation, endorsement, or offer to transact in any digital asset, financial instrument, or investment product.
Interstice does not promote or recommend any transaction, asset, or counterparty.
Where Interstice is expressly identified as a direct counterparty, any quote or transaction terms provided by Interstice constitute proposed terms for a bilateral principal transaction only and do not constitute investment advice, a recommendation, or a solicitation directed to the User’s individual investment objectives or circumstances. The User remains free to reject or decline any such quote before authorizing the transaction.
9.3 No Regulatory Representation
Interstice makes no representation or warranty that the Platform, or any activity conducted in connection with it, complies with the laws or regulations of any jurisdiction.
Nothing in the Platform or these Terms shall be interpreted as a representation that Interstice is licensed, registered, or approved by any regulatory authority, or that any activity conducted through or in connection with the Platform is lawful, permissible, or compliant under applicable law.
9.4 Informational and Probabilistic Nature of Outputs
Any data, reports, compliance outputs, documentation, or analytical results generated through the Platform are informational in nature only and may be incomplete, inaccurate, outdated, or subject to interpretation.
Such outputs may be based on third-party data, internal methodologies, or probabilistic models and are not guaranteed to be correct, complete, or reliable. Interstice does not warrant that any output will be accepted, relied upon, or given legal effect by any regulator, authority, or third party.
9.5 No Monitoring or Enforcement
Interstice does not monitor, supervise, or enforce user activity, transactions, or interactions with third parties and does not provide regulatory oversight or compliance enforcement services.
The availability of compliance-related tools, screening outputs, or documentation does not create any obligation for Interstice to take action, intervene, or prevent any activity conducted by users.
9.6 Third-Party Systems Disclaimer
The Platform may include or reference Third-Party Systems, including blockchain networks, smart contracts, data providers, and external services.
Interstice does not control and makes no representation or warranty with respect to any Third-Party System, including its availability, accuracy, performance, security, or outcomes. All interactions with Third-Party Systems are undertaken solely at your own risk.
9.7 Technology and Digital Asset Risk
The use of digital assets, blockchain networks, smart contracts, and cross-chain infrastructure involves inherent technological and operational risks, including the possibility of loss, failure, delay, or unintended outcomes.
Interstice does not guarantee the functionality, security, reliability, or performance of any underlying system and shall not be responsible for any loss arising from such risks.
9.8 No Warranty
THE PLATFORM AND ALL RELATED SERVICES, INFORMATION, AND OUTPUTS ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS.
TO THE MAXIMUM EXTENT PERMITTED BY LAW, INTERSTICE DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, COMPLETENESS, OR RELIABILITY.
INTERSTICE DOES NOT WARRANT THAT THE PLATFORM WILL BE UNINTERRUPTED, ERROR-FREE, SECURE, OR FREE FROM DEFECTS.
9.9 No Guarantee of Availability or Continuity
Interstice does not guarantee that the Platform, or any part of it, will be available at any particular time, in any particular jurisdiction, or to any particular user.
The Platform may be modified, limited, suspended, or discontinued at any time without notice and without liability.
9.10 Forward-Looking Statements
The Platform may include statements regarding anticipated features, capabilities, or developments that constitute forward-looking statements.
Such statements are based on current expectations and assumptions and are subject to risks and uncertainties that may cause actual results to differ materially. Interstice undertakes no obligation to update or revise any such statements.
9.11 Digital Asset Market Risk and Absence of Insurance Protection
Digital assets may experience substantial and unpredictable changes in price, value, liquidity, demand, utility, and market acceptance. Market conditions, counterparty availability, trading activity, regulatory developments, technological changes, network events, and other external factors may materially affect transaction outcomes and asset valuations.
The User acknowledges that it may lose some or all of the value associated with a digital asset or transaction and voluntarily assumes all financial, market, liquidity, counterparty, technological, and operational risks arising from or relating to its use of the Platform.
Digital assets, wallets, and transactions accessed or conducted through or in connection with the Platform are not deposits or accounts maintained by Interstice and are not insured by the Federal Deposit Insurance Corporation (“FDIC”), protected by the Securities Investor Protection Corporation (“SIPC”), or covered by any comparable governmental, regulatory, deposit-insurance, investor-protection, or private consumer-protection scheme.
10. LIMITATION OF LIABILITY
10.1 Exclusion of Damages
To the maximum extent permitted by applicable law, Interstice and its affiliates, officers, directors, employees, agents, contractors, and service providers shall not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages of any kind. This includes, without limitation, any loss of profits, revenue, business opportunities, goodwill, data, or anticipated savings, as well as any loss arising from business interruption, system failure, or loss of use, whether or not Interstice has been advised of the possibility of such damages.
10.2 No Liability for Digital Asset Risks, Third-Party Systems, or External Activity
To the maximum extent permitted by applicable law, Interstice shall not be liable for any loss, damage, or claim arising out of or relating to market movements; fluctuations or changes in digital asset value, price, liquidity, demand, utility, or market acceptance; counterparty default, insolvency, or unavailability; blockchain network events; smart contract behavior; failed, delayed, incomplete, or irreversible transactions; wallet or key-management issues; inaccurate or unavailable pricing; regulatory developments; any Third-Party System; any decision made by the User; or any act, omission, error, delay, failure, or misconduct of a third party.
Except for any obligations expressly undertaken by Interstice in transaction-specific terms where Interstice acts as a disclosed direct counterparty, all external activity and interaction with Third-Party Systems is undertaken independently by the User and at the User’s sole risk.
Where Interstice acts as a direct counterparty, Interstice shall remain entitled to all disclaimers, limitations, and exclusions contained in these Terms with respect to market risk, changes in asset value, liquidity conditions, blockchain networks, smart contracts, external infrastructure, User decisions, and matters outside Interstice’s reasonable control.
10.3 No Liability for Compliance or Regulatory Outcomes
Interstice shall not be liable for any regulatory, legal, or compliance-related outcome, including any determination by a regulator, authority, or third party, any enforcement action, investigation, or penalty, or any failure by you to comply with applicable laws or regulations. You acknowledge that Interstice does not provide compliance determinations or regulatory assurances and does not assume responsibility for your compliance obligations.
10.4 No Liability for Data, Outputs, or Decisions
Interstice shall not be liable for any loss or damage arising from your reliance on any data, report, output, or documentation generated through the Platform, any error, omission, inaccuracy, or delay in such information, or any decision made by you or any third party based on such information. All use of Platform outputs is undertaken at your sole risk.
10.5 Aggregate Liability Cap
To the maximum extent permitted by applicable law, the total aggregate liability of Interstice, whether in contract, tort, strict liability, or otherwise, arising out of or relating to these Terms or the use of the Platform, shall not exceed the greater of (i) the total amount of fees, if any, paid by you to Interstice in the twelve (12) months preceding the event giving rise to the claim, or (ii) one hundred U.S. dollars (USD $100).
10.6 Basis of the Bargain
You acknowledge and agree that the limitations and exclusions of liability set forth in these Terms are a fundamental basis of the agreement between you and Interstice, and that Interstice would not provide access to the Platform without such limitations.
10.7 Applicability
The limitations set forth in this Section shall apply to the fullest extent permitted by applicable law, regardless of the form of action, whether based in contract, tort, negligence, strict liability, or otherwise. To the extent that any limitation or exclusion is not enforceable under applicable law, such limitation or exclusion shall be enforced to the maximum extent permitted.
11. INDEMNIFICATION
11.1 Indemnification Obligation
You agree to defend, indemnify, and hold harmless Interstice and its affiliates, officers, directors, employees, agents, contractors, and service providers (collectively, the “Indemnified Parties”) from and against any and all claims, demands, actions, proceedings, damages, losses, liabilities, costs, and expenses, including reasonable attorneys’ fees and legal costs, arising out of or relating to your access to or use of the Platform, your violation of these Terms, or your violation of any applicable law, regulation, or third-party right.
11.2 Compliance and Regulatory Exposure
Without limiting the foregoing, your indemnification obligations extend to any claim, investigation, enforcement action, or proceeding arising out of or relating to your failure to comply with applicable sanctions, anti-money laundering, counter-terrorism financing, or other financial crime laws, including any interaction with a sanctioned person, entity, or jurisdiction, or any activity conducted by you in connection with the Platform that results in regulatory scrutiny, liability, or enforcement.
11.3 Third-Party Interactions and External Systems
You acknowledge that all interactions with counterparties, blockchain networks, smart contracts, digital assets, or Third-Party Systems are undertaken solely by you and outside of Interstice’s control. You agree to indemnify and hold harmless the Indemnified Parties from and against any claim arising out of or relating to such interactions, including any dispute, loss, liability, or claim asserted by any third party.
11.4 Data and Information Provided
You further agree to indemnify and hold harmless the Indemnified Parties from any claim arising out of or relating to any information or data provided by you that is false, inaccurate, incomplete, or misleading, or any failure to obtain the necessary rights, consents, or legal authority to provide such information. This includes any claim brought by a third party in connection with personal or business information submitted to Interstice.
11.5 Misuse of the Platform
Your indemnification obligations also apply to any claim arising out of or relating to your misuse of the Platform, including any attempt to circumvent applicable laws or regulatory requirements, any use of the Platform inconsistent with its intended purpose, or any improper use of data, outputs, or documentation generated through the Platform.
11.6 Defense and Control
Interstice reserves the right, at its sole discretion, to assume the exclusive defense and control of any matter subject to indemnification, at your expense. You agree to cooperate fully in the defense of any such claim and shall not settle any matter without Interstice’s prior written consent, which shall not be unreasonably withheld.
11.7 Survival
The obligations set forth in this Section shall survive the termination or expiration of these Terms and your use of the Platform.
12. TERMINATION AND SUSPENSION
12.1 Right to Restrict or Terminate Access
Interstice reserves the right, at its sole discretion and at any time, to restrict, suspend, or terminate your access to the Platform, in whole or in part, with or without notice, for any reason or no reason, including where Interstice determines that such action is necessary or appropriate for legal, regulatory, operational, or risk management purposes.
Nothing in these Terms shall be construed as creating any obligation for Interstice to provide continued access to the Platform or to maintain the availability of any feature, functionality, or Service.
12.2 Termination for Cause
Without limiting the foregoing, Interstice may restrict, suspend, or terminate your access to the Platform where it reasonably determines that you have breached these Terms, provided inaccurate or misleading information, failed to satisfy onboarding or verification requirements, or engaged in conduct that may expose Interstice to legal, regulatory, or reputational risk.
Any such determination shall be made by Interstice in its sole discretion and shall not require prior notice, explanation, or opportunity to cure.
12.3 Effect of Termination
Upon termination or suspension of access, your right to use the Platform shall immediately cease, and you shall discontinue all use of the Platform and any associated services or materials.
Termination or suspension shall affect only the User’s access to the Platform and shall not cancel, reverse, or modify any transaction previously authorized or executed. Except for any surviving obligation expressly undertaken by Interstice as a direct counterparty under applicable transaction-specific terms, all external systems, transactions, digital assets, and third-party relationships remain independent of and outside Interstice’s control. Interstice does not have the ability to reverse, cancel, or otherwise affect any completed blockchain transaction or asset position.
12.4 No Liability for Termination or Suspension
To the maximum extent permitted by applicable law, Interstice shall not be liable for any loss, damage, or claim arising out of or relating to the restriction, suspension, or termination of access to the Platform, including any loss of data, business opportunities, or anticipated activity.
12.5 Survival of Terms
Any provisions of these Terms that by their nature should survive termination or expiration shall remain in full force and effect, including, without limitation, those relating to disclaimers, limitation of liability, indemnification, intellectual property, and dispute resolution.
12.6 Discontinuation of the Platform
Interstice reserves the right to modify, suspend, or discontinue the Platform, or any portion thereof, at any time, with or without notice.
Interstice shall have no liability arising from any modification, limitation, suspension, or discontinuation of the Platform.
13. PRIVACY AND DATA HANDLING
13.1 Incorporation of Privacy Policy
Interstice’s collection, use, processing, and disclosure of personal and business information are governed by the Interstice Privacy Policy (the “Privacy Policy”), which is hereby incorporated by reference into these Terms.
By accessing or using the Platform, or by submitting any information to Interstice, you acknowledge that you have read, understood, and agree to the practices described in the Privacy Policy.
13.2 Relationship with KYC/KYB Terms
Where personal or business information is collected in connection with identity verification, onboarding, screening, or compliance-related processes, such activities shall be governed by both the Privacy Policy and the KYC/KYB Terms of Service.
Each of these documents applies independently and cumulatively and together form part of the contractual framework governing your interaction with Interstice. In the event of any conflict between these Terms and the Privacy Policy, the Privacy Policy shall govern solely with respect to data protection and privacy matters.
13.3 Nature of Data Processing
Interstice processes data for compliance, verification, documentation, and risk management purposes, as described in the Privacy Policy.
Such processing is independent of any transaction or interaction between users and third parties and does not involve participation in such activity.
13.4 Independent Role
Interstice acts as an independent data controller with respect to the information it collects and processes in connection with the Platform, as described in the Privacy Policy.
Nothing in these Terms shall be interpreted as creating any agency, fiduciary, advisory, intermediary, or other regulated relationship between Interstice and any user in connection with data processing activities. Interstice does not act on behalf of users in processing data and does not assume any obligation to act in the user’s interest.
13.5 User Responsibility for Data
You represent and warrant that all information provided to Interstice is accurate, complete, and not misleading, and that you have obtained all necessary rights, consents, and legal bases to provide any personal or third-party data.
You acknowledge that Interstice may rely on such information without independent verification to the maximum extent permitted by applicable law, and that you remain solely responsible for the legality and appropriateness of such data.
13.6 Cross-Border Data Processing
You acknowledge and agree that your information may be transferred, processed, and stored across multiple jurisdictions, including the United States and other jurisdictions in which Interstice or its service providers operate, as further described in the Privacy Policy.
Such cross-border processing is an inherent component of the Platform and may occur on an ongoing or event-driven basis. Interstice does not guarantee that data processing in any particular jurisdiction will satisfy the legal requirements of any other jurisdiction, and you remain responsible for assessing the legal implications of such processing.
14. DISPUTE RESOLUTION AND GOVERNING LAW
14.1 Governing Law
These Terms, and any dispute, claim, or controversy arising out of or relating to these Terms or the use of the Platform, including any non-contractual claims, shall be governed by and construed in accordance with the laws of the State of New York, without regard to its conflict of law principles.
The Federal Arbitration Act (9 U.S.C. §§ 1–16) shall govern the interpretation and enforcement of the arbitration provisions set forth in this Section.
14.2 Informal Resolution
Before initiating any formal proceeding, you agree to attempt in good faith to resolve any dispute with Interstice by providing written notice describing the nature of the dispute and the relief sought.
If the parties are unable to resolve the dispute within thirty (30) days after such notice, either party may initiate arbitration as set forth in this Section.
14.3 Binding Arbitration
Except as otherwise expressly provided herein, any dispute, claim, or controversy arising out of or relating to these Terms or the use of the Platform shall be resolved exclusively by final and binding arbitration administered by JAMS in accordance with its applicable rules.
The arbitration shall be conducted by a single arbitrator, in English, and seated in New York, New York, unless otherwise agreed by the parties. The arbitrator shall have exclusive authority to resolve any dispute relating to the interpretation, applicability, enforceability, or formation of these Terms, including any claim that all or any part of these Terms is void or voidable.
Judgment on the arbitration award may be entered in any court of competent jurisdiction.
The existence of any arbitration, all submissions, evidence, materials, testimony, orders, and awards relating to the arbitration, and all information disclosed in connection with the proceeding shall be kept confidential by the parties, except to the extent disclosure is reasonably necessary to enforce an award, seek permitted judicial relief, comply with applicable law or legal process, or protect a party’s legal rights.
14.4 Class Action Waiver
You agree that any dispute shall be brought solely in your individual capacity and not as a plaintiff or class member in any purported class, collective, consolidated, or representative proceeding.
To the maximum extent permitted by applicable law, you waive any right to participate in, or to have any dispute heard as part of, any class, collective, or representative action. The arbitrator shall have no authority to consolidate claims or to preside over any form of class or representative proceeding.
14.5 Injunctive and Equitable Relief
Notwithstanding the foregoing, Interstice may seek injunctive or equitable relief in any court of competent jurisdiction to prevent unauthorized access to or misuse of the Platform, protect its intellectual property or confidential information, or otherwise enforce compliance with these Terms.
14.6 Arbitration Costs and Fees
Each party shall bear its own legal fees and costs, except as may be awarded by the arbitrator in accordance with applicable law or the rules of JAMS.
If the arbitrator determines that any claim is frivolous or brought in bad faith, the prevailing party shall be entitled to recover its reasonable attorneys’ fees and costs.
14.7 Time Limitation
Any claim or cause of action arising out of or relating to these Terms or the use of the Platform must be brought within one (1) year after the event giving rise to such claim, or such claim shall be permanently barred, to the maximum extent permitted by applicable law.
14.8 Severability of Dispute Resolution Provisions
If any portion of this Section is found to be invalid or unenforceable, such portion shall be severed, and the remaining provisions shall remain in full force and effect, except that if the class action waiver in Section 14.4 is found to be unenforceable, then the arbitration provisions set forth in this Section shall not apply.
15. MISCELLANEOUS
15.1 Entire Agreement
These Terms, together with any documents incorporated by reference, including the Privacy Policy, the KYC/KYB Terms of Service, and any applicable Annexes, constitute the entire agreement between you and Interstice with respect to the subject matter hereof and supersede all prior or contemporaneous understandings, agreements, representations, or communications, whether written or oral.
15.2 Assignment
Interstice may assign, transfer, or delegate its rights and obligations under these Terms, in whole or in part, without notice or consent.
You may not assign, transfer, or delegate any of your rights or obligations under these Terms without the prior written consent of Interstice, and any attempted assignment in violation of this provision shall be null and void.
15.3 No Waiver
No failure or delay by Interstice in exercising any right, power, or remedy under these Terms shall operate as a waiver thereof. Any waiver shall be effective only if made in writing and shall not be deemed a waiver of any subsequent breach or default.
15.4 Severability
If any provision of these Terms is held to be invalid, illegal, or unenforceable, such provision shall be enforced to the maximum extent permitted by law, and the remaining provisions shall remain in full force and effect.
15.5 Force Majeure
Interstice shall not be liable for any delay or failure in performance resulting from causes beyond its reasonable control, including, without limitation, acts of God, natural disasters, war, terrorism, civil unrest, labor disputes, governmental actions, failures of utilities or telecommunications networks, or failures of third-party systems or infrastructure.
15.6 No Agency or Partnership
Nothing in these Terms shall be deemed to create any partnership, joint venture, agency, fiduciary, or employment relationship between you and Interstice.
You shall have no authority to bind Interstice or to act on its behalf in any manner.
15.7 Third-Party Beneficiaries
These Terms are intended solely for the benefit of you and Interstice and do not create any rights in favor of any third party, except that the Indemnified Parties may rely upon and enforce the provisions of Section 11.
15.8 Headings
Section headings are for convenience only and shall not affect the interpretation of these Terms.
15.9 Interpretation
These Terms shall be interpreted according to their fair meaning and not strictly for or against either party. Any rule of construction that ambiguities are to be resolved against the drafting party shall not apply.
15.10 Notices
Interstice may provide notices under these Terms through the Platform, by email, or by other reasonable means. Such notices shall be deemed effective upon transmission or posting, as applicable.
You are responsible for maintaining accurate and current contact information and for reviewing such communications.
15.11 Modifications to Terms
Interstice may modify or update these Terms and its Annexes at any time, in its sole discretion. Any such changes shall become effective upon publication, unless otherwise specified.
Your continued access to or use of the Platform following the publication of any such changes constitutes your acceptance of the revised Terms.
ANNEX I - CROSS-CHAIN SWAP ENGINE
1. Scope and Application
This Annex I (“Annex”) governs your access to and use of the Cross-Chain Swap Engine (the “CCSE”), a Service made available through the Platform.
This Annex forms an integral part of the Terms of Use (the “Terms”) and applies exclusively to any interaction with the CCSE. In the event of any inconsistency between this Annex and the Terms, this Annex shall govern solely with respect to the CCSE, and the Terms shall otherwise remain in full force and effect.
This Annex is subject to, and shall be read in conjunction with, the Terms of Use, the Privacy Policy, and, where applicable, the KYC/KYB Terms of Service, each of which is incorporated by reference.
2. Definitions
For purposes of this Annex:
“Liquidity Provider” or “LP” means any person or entity, including Interstice where expressly identified and disclosed as such, that acts solely in its own capacity and as principal, responds to a Request-for-Quote by offering pricing and transaction terms from its own assets or balance sheet, and may enter into a bilateral transaction directly with a User. Any third-party LP acts independently of Interstice.
“Request-for-Quote” or “RFQ” means a communication initiated by a user through the Platform for the purpose of soliciting pricing or transaction terms from one or more LPs with respect to a potential transaction.
“Audit Records” has the meaning set forth in Section 16 of this Annex.
3. Nature and Characterization of the Service
The CCSE constitutes a non-custodial, bilateral Request-for-Quote coordination and messaging layer designed to enable communication between Users and LPs in connection with potential cross-chain transactions.
The CCSE does not constitute, and shall not be construed as, a trading venue, exchange, alternative trading system, broker-dealer, money-transmission service, clearing agency, settlement system, matching engine, or financial intermediary of any kind. It does not operate an order book, liquidity pool, automated market maker, capital-aggregation mechanism, or multilateral trading environment.
Interstice’s role in operating the CCSE is generally limited to enabling communication and coordination of potential transaction parameters. Except where Interstice is expressly identified as an LP and direct counterparty, all contractual relationships and asset transfers occur directly between Users and independent third-party LPs.
Interstice may, in limited circumstances and where expressly disclosed to the User before transaction authorization, participate in an RFQ and enter into a bilateral transaction as an LP and direct counterparty. In that capacity, Interstice acts solely as principal, for its own account and using its own assets or balance sheet, and not as an agent, broker, fiduciary, custodian, representative, or intermediary for the User.
Interstice’s operation of the CCSE and its limited ability to act as a disclosed LP do not cause the CCSE to constitute a trading venue, exchange, brokerage service, matching engine, custodial service, or financial intermediary.
4. Bilateral RFQ Framework
All interactions made available through the CCSE are conducted on a strictly bilateral Request-for-Quote basis.
A User may submit an RFQ to one or more LPs. Each LP receives and evaluates the RFQ independently and may respond with a quote based on its own pricing methodology, risk assessment, asset availability, balance sheet, and internal considerations.
An LP may include Interstice where Interstice is expressly identified as the quoting party and potential direct counterparty. Any quote provided by Interstice is provided solely in its separate capacity as principal and not in its capacity as operator of the Platform or as an agent, advisor, broker, or fiduciary for the User.
The Platform does not aggregate, rank, prioritize, optimize, or algorithmically process quotes. Each quote constitutes a separate bilateral proposal from the identified LP. Interstice does not act as a matching engine and does not facilitate multilateral interaction among participants.
The selection, acceptance, or rejection of any quote is determined exclusively by the User in its sole discretion. No quote is required or recommended by Interstice.
5. User-Controlled Transaction Initiation and Execution
All transactions are initiated and executed directly by users through their own wallet infrastructure and external blockchain systems.
Digital assets remain under the exclusive control of the user at all times prior to transaction initiation. Interstice does not have access to, and does not control, user wallets, private keys, accounts, or signing authority, and cannot initiate, authorize, prevent, or modify any transaction.
Acceptance of a quote constitutes a bilateral arrangement between the User and the identified LP. Where the identified LP is an independent third party, such acceptance does not create any contractual obligation or transaction liability for Interstice. Where Interstice is expressly identified as the LP and direct counterparty, acceptance may create a bilateral obligation between the User and Interstice solely in accordance with the applicable quote and any transaction-specific terms.
6. Atomic Settlement and Smart Contract Mechanism
Transactions coordinated through the CCSE are implemented through dual-chain Hash Time-Locked Contract (“HTLC”) mechanisms deployed independently on the Canton Network and Ethereum.
Such transactions are conditional and atomic in nature, such that both legs of the transaction either complete in accordance with the logic of the underlying blockchain systems, without any ability for Interstice to intervene, alter, or influence such outcome.
The cryptographic preimage required to unlock settlement is generated and controlled by the user or its designated infrastructure. Interstice does not generate, possess, store, access, or control any such cryptographic material.
Upon satisfaction of the relevant smart contract conditions, settlement occurs automatically and irreversibly in accordance with the logic of the underlying blockchain systems.
The atomic settlement mechanism is designed to ensure that transactions either complete in accordance with predefined conditions or fail in their entirety, without any ability for Interstice to intervene, alter, or influence such outcome.Interstice makes no representation or warranty regarding the outcome of any transaction, and users acknowledge that technical, network, or external factors may result in delay, failure, or loss.
Interstice does not design, audit, or assume responsibility for the underlying smart contract architecture beyond any expressly disclosed third-party review.
7. Absence of Custody, Control, or Intermediation
At no time does Interstice operate or maintain custodial wallet infrastructure for Users, hold or control User private keys or signing authority, maintain customer deposit accounts or customer asset balances, or receive, hold, safeguard, transmit, or transfer funds or digital assets on behalf of a User.
Except where Interstice is expressly identified as the direct counterparty, Interstice does not participate as principal in the execution or settlement of any transaction. Interstice does not act as an agent, broker, intermediary, fiduciary, custodian, or representative of any party.
Where Interstice acts as a direct counterparty, it acts solely as principal and for its own account. Any assets delivered or received by Interstice in that capacity are transferred as consideration in a bilateral transaction and are not held, safeguarded, transmitted, or controlled on behalf of the User.
Interstice has no ability to access, freeze, redirect, recover, cancel, reverse, or modify any User asset or completed blockchain transaction. Interstice does not generate or approve transaction instructions on behalf of Users and does not transform User inputs into executable instructions without the User’s independent authorization.
8. Role and Independence of Liquidity Providers
Each LP acts solely as principal, from its own assets or balance sheet, and in its own capacity. Third-party LPs are independent of Interstice and are not agents, representatives, employees, or affiliates of Interstice unless expressly disclosed otherwise.
Interstice may act as an LP only where it is expressly identified to the User as the quoting party and potential direct counterparty before the User accepts the applicable quote. When acting as an LP, Interstice acts in a capacity separate from its operation of the Platform and does not act as an agent, broker, fiduciary, advisor, custodian, or intermediary for the User.
No assets are pooled, commingled, or contributed to a shared liquidity structure. The CCSE does not operate any liquidity pool, automated market maker, or capital-aggregation mechanism.
Interstice does not guarantee the availability, pricing, performance, conduct, or solvency of any third-party LP and does not assume any responsibility for transactions entered into between Users and third-party LPs. Where Interstice is the disclosed LP, its obligations are limited to those expressly set forth in the accepted quote and any applicable transaction-specific terms.
9. Pricing, Quotes, and Cost Disclosure
Except for Platform fees separately established by Interstice under Section 10 of this Annex, all quote pricing and transaction terms are determined independently by the LP providing the applicable quote. Each LP acts as principal and may determine its quote based on its own pricing methodology, market conditions, risk assessment, asset availability, balance sheet, and other considerations.
Where Interstice is not the LP, Interstice does not set, influence, validate, or guarantee the pricing provided by a third-party LP and does not provide best execution, price discovery, price comparison, or price-optimization services.
Where Interstice is expressly identified as the LP and direct counterparty, Interstice may determine the pricing and economic terms of its own quote in its capacity as principal. Such pricing does not constitute investment advice, a recommendation, best-execution analysis, or a representation that the quote reflects the best or most favorable price available in any market.
Any pricing, spread, or other economic return earned by Interstice when acting as the direct counterparty is separate from the Platform fee charged for use of the CCSE. Any such pricing or spread will be incorporated into or disclosed as part of the applicable quote or transaction terms to the extent required by applicable law. Platform fees are separately governed by Section 10 of this Annex.
Before the User authorizes a transaction, the Platform will display the material economic terms of the applicable quote and the applicable Platform fee. The Platform may also present a breakdown of other estimated transaction-related costs, including any spread incorporated into an LP quote and estimated blockchain network, gas, validator, protocol, or other third-party fees.
Estimated costs are provided solely for transparency and informational purposes and may be based on third-party information, prevailing network conditions, or other real-time inputs outside Interstice’s control. Such estimated third-party costs may differ from the amounts ultimately incurred. The applicable Platform fee rate and any maximum Platform fee amount presented to and authorized by the User through the transaction workflow will be governed by Section 10 and the applicable transaction-specific terms.
Neither the presentation of pricing or cost information nor the availability of a quote constitutes investment, financial, legal, or tax advice; a recommendation to enter into a transaction; a guarantee of execution, settlement, liquidity, or outcome; an assurance concerning the value or future performance of any digital asset; or a representation that the User is receiving the most favorable terms available.
10. Fee Levels and Platform Fee Rates
Interstice charges a Platform fee for eligible swaps completed through the CCSE. Under the current fee schedule, the applicable Platform fee rate is determined by the User’s fee level, which is based on the User’s trailing thirty-day Eligible Settled Volume.
For purposes of this Section, “Eligible Settled Volume” means the USD-denominated or USD-equivalent notional value of eligible swaps successfully completed and settled through the CCSE during the immediately preceding thirty-day period, as determined by Interstice’s system records. Eligible Settled Volume is measured on a rolling basis. Transaction volume ceases to count toward the User’s fee level when it falls outside the trailing thirty-day measurement period.
The current fee levels, Eligible Settled Volume thresholds, and corresponding Platform fee rates are:
- Core: less than USD 100,000 in trailing thirty-day Eligible Settled Volume - 15 basis points.
- Select: at least USD 100,000 but less than USD 1,000,000 in trailing thirty-day Eligible Settled Volume - 10 basis points.
- Premier: at least USD 1,000,000 but less than USD 5,000,000 in trailing thirty-day Eligible Settled Volume - 8 basis points.
- Elite: at least USD 5,000,000 but less than USD 20,000,000 in trailing thirty-day Eligible Settled Volume - 6 basis points.
- Signature: at least USD 20,000,000 in trailing thirty-day Eligible Settled Volume - 4 basis points.
One basis point equals 0.01%. A User will be assigned the highest fee level for which the User satisfies the applicable minimum Eligible Settled Volume threshold.
Only bona fide swap transactions successfully completed and settled through the CCSE constitute Eligible Settled Volume. Self-trades, related-party transactions, wash activity, wallet sends, internal transfers, failed or reversed settlements, test activity, artificial or manipulative activity, and any other transaction or activity determined by Interstice to be ineligible will not count toward a fee level.
Interstice may exclude, reclassify, correct, or adjust transaction volume where reasonably necessary to reflect a failed, refunded, reversed, duplicated, erroneous, artificial, manipulative, or otherwise ineligible transaction; prevent fraud or abuse; correct a technical or calculation error; or enforce these Terms. Interstice’s records and determinations will govern the calculation of Eligible Settled Volume and the assignment of fee levels, except to the extent otherwise required by applicable law.
A User’s digital asset balance, Points balance, Operator Network Points, potential or actual allocation from a Canton App Rewards pool, or participation in any promotional or rewards program does not increase or otherwise affect the User’s fee level. Fee levels apply solely to the Platform fee charged for eligible swaps and do not determine eligibility for Points, Canton App Rewards, or any other reward or benefit.
The Platform will display the User’s then-current fee level, the applicable Platform fee rate, and any applicable maximum Platform fee amount before the User authorizes the relevant swap. The Platform fee applicable to a transaction will be determined using the fee level and rate presented through the transaction workflow and accepted by the User. A subsequent change to the User’s Eligible Settled Volume, fee level, or the fee schedule will not retroactively alter the Platform fee applicable to a transaction already authorized by the User.
Interstice may prospectively establish, modify, replace, suspend, or discontinue any fee level, tier name, measurement period, volume threshold, fee rate, eligibility rule, calculation methodology, or other component of the fee schedule. Any change will apply prospectively after it is made available through the Platform or otherwise communicated in accordance with these Terms and will not alter the Platform fee applicable to a transaction previously authorized by the User
11. Third-Party Systems and Dependencies
The CCSE relies on independent third-party systems, including blockchain networks, smart contracts, oracle providers, and wallet infrastructure.
Interstice does not own, operate, or control any such systems and makes no representation or warranty regarding their availability, performance, security, or outcomes.
Any interaction with such systems is undertaken at the user’s sole risk. Interstice shall not be responsible for any failure, delay, or malfunction of such systems.
12. Smart Contract and Technical Risks
Transactions coordinated through the CCSE are implemented through smart contracts deployed on independent blockchain networks, which may contain vulnerabilities, defects, or unintended behaviors.
Although such smart contracts or related systems may be subject to independent review or audit, no audit, review, or testing process can eliminate all risks or guarantee the absence of errors, vulnerabilities, or adverse outcomes.
Users acknowledge and accept all risks associated with smart contract execution and underlying blockchain infrastructure, including, without limitation, risks of loss of digital assets, delayed or failed execution, incomplete or unsuccessful settlement, unintended outcomes resulting from code behavior, and failures or inconsistencies arising from oracle inputs, network congestion, validator behavior, consensus mechanisms, or time-lock conditions.
Users further acknowledge that interactions with smart contracts and blockchain systems are inherently probabilistic and may be affected by factors beyond the control of any party, including network conditions, third-party infrastructure, and external data dependencies.
Interstice does not design, deploy, operate, or control the underlying blockchain networks or smart contracts used in connection with transactions, and makes no representation or warranty as to their functionality, security, reliability, or performance.
To the maximum extent permitted by applicable law, Interstice shall have no liability for any loss, damage, or adverse outcome arising from or related to smart contract execution, blockchain operation, or any associated technical or systemic risk.
13. Irreversibility and Transaction Finality
Once a transaction has been initiated and the applicable conditions have been satisfied, settlement becomes final and irreversible.
Interstice has no ability to intervene in, halt, or reverse any transaction under any circumstances.
Users are solely responsible for verifying all transaction parameters prior to initiation.
14. Compliance and User Responsibility
All transactions conducted through the CCSE are bilateral transactions between the User and the identified LP, which may be an independent third-party LP or, where expressly disclosed, Interstice acting solely as principal.
Users are solely responsible for ensuring compliance with all applicable laws and regulations, including sanctions, anti-money laundering, financial crime, tax, securities, commodities, and other financial regulatory requirements, and for conducting appropriate due diligence regarding counterparties, assets, transactions, and applicable legal obligations.
Interstice’s identity verification, screening, documentation, or other compliance-support activities do not constitute a determination, certification, or guarantee that any User or transaction is lawful, permissible, or compliant.
The User represents that it acts for its own account or for a fully disclosed legal entity that it is duly authorized to represent and shall not use the CCSE as an undisclosed agent, nominee, intermediary, broker, representative, or conduit for any third party.
15. No Reliance on the Platform
The CCSE provides infrastructure and informational functionality only.
Nothing in the CCSE shall be relied upon as a substitute for independent legal, regulatory, or compliance analysis, and all decisions are made solely by the user.
16. Records and Documentation
The Platform may generate transaction-related records, confirmations, or audit logs for informational and compliance-support purposes.
Such records do not constitute regulated trade confirmations, broker confirmations, or legally binding reporting instruments.
Users remain solely responsible for maintaining their own records and satisfying any applicable reporting obligations.
17. Audit Trail and Transaction Records
The Platform may generate structured, time-stamped records relating to user activity, including interactions with the CCSE, quote selection, and transaction-related events (the “Audit Records”).
Audit Records are made available for informational, operational, and compliance-support purposes and may be accessible to the user and its designated personnel.
Audit Records reflect data captured at the Platform layer and do not constitute verification, certification, or validation of any transaction, nor do they represent a complete or authoritative record of activity occurring on blockchain networks or third-party systems.
The generation or availability of Audit Records does not constitute monitoring, supervision, surveillance, or regulatory oversight. Interstice does not review, validate, or control transactions through the creation of such records and does not assume any obligation to detect, prevent, or report any activity.
Users remain solely responsible for maintaining their own records and for satisfying all applicable legal and regulatory requirements.
18. Modification or Discontinuation
Interstice may, at any time and in its sole discretion, modify, suspend, or discontinue the CCSE, in whole or in part, without liability.
The CCSE is provided on an “as is” and “as available” basis, and Interstice makes no representation or warranty regarding its availability, continuity, or performance.
Interstice does not guarantee that the CCSE will be available on an uninterrupted, continuous, secure, or error-free basis, and the availability and functionality of the CCSE may change at any time due to technical, regulatory, operational, or other considerations.
19. Non-Binding Nature of RFQs and Quotes
Requests for Quotes and responses thereto are indicative and non-binding unless and until expressly accepted in accordance with the applicable quote, transaction workflow, and any transaction-specific terms.
The submission of an RFQ or receipt of a quote does not, by itself, create an obligation to transact. The User may reject, decline, or allow any quote to expire without entering into a transaction.
Any binding obligation arises, if at all, solely upon the User’s independent acceptance and authorization of a transaction with the identified LP. Where Interstice is expressly identified as the LP and direct counterparty, any resulting obligation is limited to the terms of the accepted quote and applicable transaction-specific terms.
Interstice does not guarantee the availability, continued validity, or execution of any quote and shall not be responsible for expired, withdrawn, rejected, or unavailable quotes. No quote constitutes investment advice, a recommendation, or a guarantee concerning transaction outcomes or the future value, performance, liquidity, utility, or market acceptance of any digital asset.
ANNEX II - VENEZUELA PROTOCOL
1. Scope and Nature of the Venezuela Protocol
This Annex II (“Annex”) governs your access to and use of the Venezuela Protocol (the “Venezuela Protocol”), a Service made available through the Platform.
This Annex forms an integral part of the Terms of Use (the “Terms”) and applies exclusively to any interaction with the Venezuela Protocol. In the event of any inconsistency between this Annex and the Terms, this Annex shall govern solely with respect to the Venezuela Protocol, and the Terms shall otherwise remain in full force and effect.
The Venezuela Protocol constitutes a compliance-oriented infrastructure designed to enable users to assess, document, and validate sanctions-screened interactions with Venezuelan private-sector counterparties in reference to applicable legal and regulatory frameworks, including those administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). It provides tools for identity verification, sanctions screening, transaction-related documentation, and audit record generation.
The Venezuela Protocol does not, and shall not be construed to, execute, settle, transmit, process, or intermediate any transaction or transfer of value. All transactions, payments, and transfers of value occur independently of Interstice and outside of its systems and control.
This Annex is subject to, and shall be read in conjunction with, the Terms of Use, the Privacy Policy, and, where applicable, the KYC/KYB Terms of Service, each of which is incorporated by reference.
Notwithstanding Section 2.4 of the Terms, the designation of Venezuela as a Restricted Country does not prohibit Interstice from making the Venezuela Protocol available, on a limited and case-by-case basis, to or in connection with persons or entities located in, organized under the laws of, or ordinarily resident in Venezuela, solely to the extent expressly authorized by Interstice and subject to applicable sanctions laws, eligibility requirements, identity verification, sanctions screening, and any other compliance or risk-management controls required by Interstice.
For the avoidance of doubt, this limited exception applies solely to the Venezuela Protocol and does not permit any such person or entity to access or use the Cross-Chain Swap Engine or any other Service unless expressly authorized by Interstice. Nothing in this exception constitutes a representation or determination by Interstice that any User, counterparty, activity, or transaction is lawful, permissible, exempt, or authorized under applicable sanctions laws or any OFAC General License or other authorization.
2. No Execution, No Custody, and No Intermediation
At no time does Interstice:
- hold, custody, or control any fiat currency, digital assets, or financial instruments;
- operate or maintain accounts, wallets, or payment infrastructure on behalf of any user;
- act as a payment processor, money transmitter, financial institution, or intermediary;
- initiate, authorize, route, or settle any transaction; or
- act as a counterparty, agent, broker, fiduciary, or representative in any transaction.
All payments are initiated, authorized, and completed solely by users through independent third-party systems, including financial institutions, payment processors, or blockchain networks.
Interstice does not generate, prepare, structure, or transmit payment instructions on behalf of any user, nor does it convert user inputs into executable payment instructions.
3. Compliance Infrastructure and Screening Framework
The Venezuela Protocol may include a multi-layered compliance framework designed to support risk assessment and documentation. Such framework may include, without limitation:
3.1 Sender Identity Verification and Screening
Users acting as senders (“Senders”) may be required to undergo business verification (KYB), including the collection and validation of entity information, tax identification details, beneficial ownership information, and authorized representatives.
Screening may include sanctions screening, politically exposed person (PEP) identification, and adverse media checks conducted through third-party providers.
3.2 Wallet-Level Screening
Where applicable, wallet addresses associated with users may be screened using third-party blockchain analytics providers for sanctions exposure, illicit finance indicators, transaction history risk, and clustering analysis.
Wallets that exceed defined risk thresholds may be restricted from use within the Platform.
3.3 Recipient Verification and Screening
Recipients (“Recipients”) may be required to undergo identity or business verification (KYC/KYB), including sanctions screening and risk assessment, prior to accessing the Platform.
Failure to satisfy such requirements may result in denial of access.
3.4 Transaction Monitoring
The Platform may integrate transaction monitoring tools, including real-time or post-event analysis of transactions or related activity.
All such monitoring is informational and risk-based in nature and does not constitute supervision, enforcement, or regulatory oversight.
4. Compliance Outputs and Audit Trail
The Venezuela Protocol may generate compliance-related outputs, including audit records, transaction documentation, and compliance packages.
Such outputs may include, without limitation:
- identity verification records;
- sanctions screening results;
- wallet risk assessments;
- transaction-related metadata (including external system references where applicable);
- user-provided information, including invoices or transaction details; and
- timestamped audit logs.
All such outputs are provided for informational, documentation, and compliance-support purposes only and may not reflect the complete or final state of any transaction or regulatory determination. Interstice does not guarantee that any such output will satisfy regulatory requirements or be accepted by any authority.
Such outputs shall not be relied upon as evidence of compliance, authorization, or regulatory approval.
5. Regulatory Positioning and User Responsibility
Users are solely responsible for determining whether any activity conducted in connection with the Venezuela Protocol complies with applicable laws and regulations, including U.S. sanctions laws, export controls, and any applicable foreign legal requirements.
Interstice does not:
- provide legal, regulatory, or compliance advice;
- determine the applicability, scope, or validity of any OFAC General License or other authorization;
- validate the legality of any transaction; or
- assume responsibility for user compliance.
Any reference to regulatory frameworks, including OFAC guidance or General Licenses, is provided for informational purposes only and does not constitute a legal determination.
The Platform does not perform any automated or systematic legal determination regarding the permissibility of any transaction.
Interstice does not determine, calculate, or guarantee the satisfaction of any tax, reporting, or local regulatory obligation in any jurisdiction.
6. Use of Third-Party Providers
The Venezuela Protocol relies on third-party service providers for identity verification, sanctions screening, transaction monitoring, and data analysis.
Interstice does not control and is not responsible for:
- the accuracy, completeness, or timeliness of third-party data;
- the methodologies or risk models used by such providers; or
- any errors, omissions, or failures in third-party systems.
All such services are provided independently and subject to their own terms and limitations.
7. Payment Flow and Independent Settlement
The Venezuela Protocol may facilitate the documentation and coordination of payment-related activity between Senders and Recipients.
Payments may be initiated by either party and may involve the use of external financial systems, including fiat payment rails, stablecoin infrastructure, or other third-party mechanisms.
At no point does Interstice:
- control the movement of funds;
- act as a settlement layer; or
- participate in transaction execution.
Settlement occurs independently between the relevant parties and external systems.
Settlement may involve independent third-party financial institutions, payment processors, or regulated service providers acting in their own capacity. Interstice does not control, operate, or participate in such systems.
Interstice does not have visibility into, control over, or involvement in the movement of funds within any financial system, including any debit, credit, or settlement process.
Interstice does not access, connect to, or operate any banking system, payment rail, or financial account used in connection with any transaction.
8. No Guarantee of Regulatory Acceptance
Interstice makes no representation or warranty that:
- any transaction complies with applicable law;
- any compliance output satisfies regulatory requirements; or
- any regulator will accept, recognize, or rely upon any documentation generated through the Platform.
Regulatory interpretations, enforcement priorities, and applicable legal frameworks may change at any time without notice.
9. Sanctions and Restricted Activity
Users may not use the Venezuela Protocol in connection with any activity that violates applicable sanctions laws or involves any person, entity, jurisdiction, government, sector, or activity to the extent prohibited or restricted under applicable sanctions laws.
The limited availability of the Venezuela Protocol to or in connection with persons or entities located in, organized under the laws of, or ordinarily resident in Venezuela, as described in Section 1 of this Annex, does not constitute an exemption from, waiver of, or determination regarding any applicable sanctions restriction.
Interstice reserves the right to restrict, suspend, or deny access where it reasonably determines that a User, counterparty, activity, or proposed transaction presents sanctions, legal, regulatory, or other compliance risk.
Any such determination is discretionary and based on Interstice’s internal risk criteria and does not constitute a legal conclusion, regulatory finding, sanctions designation, or determination regarding the applicability of any OFAC General License or other authorization.
10. Data and Documentation for Regulatory Use
Compliance outputs generated through the Platform may be made available to users for their internal use, including regulatory reporting, audit preparation, or documentation purposes.
Interstice does not provide regulatory filing, reporting, or submission services and does not submit information to any authority on behalf of users, except as required by applicable law.
11. No Reliance
The Venezuela Protocol is not a substitute for a user’s own compliance program, legal analysis, or regulatory obligations.
Users may not rely on the Platform as the sole basis for determining compliance with applicable law.
All decisions relating to transactions, counterparties, and regulatory obligations are made independently by users.
12. Fees and Cost Disclosure
Interstice may charge fees in connection with access to or use of the Venezuela Protocol. Such fees may consist of a fixed fee, a variable fee calculated as a percentage of a transaction amount, or a combination thereof.
All applicable fees shall be disclosed to the user prior to use of the relevant Service and shall be applied on a predetermined and transparent basis.
Such fees are charged for access to the Platform and its compliance infrastructure and are not contingent upon transaction outcomes, execution, exchange rates, or counterparty selection.
The Platform may present estimated transaction-related information, including fees, exchange rate references, and other cost components. Any such information is provided for transparency purposes only and may be based on third-party data, estimates, or real-time conditions.
Actual amounts transferred, converted, or received may vary based on external systems, financial institutions, or market conditions, all of which are outside Interstice’s control.
Interstice does not receive any direct or indirect economic benefit based on payment volume, transaction value, or user activity.
13. Exchange Rate Information
The Platform may display reference exchange rate information, including rates published by third parties such as the Banco Central de Venezuela (BCV) or other sources.
Such rates are provided for informational purposes only and do not constitute a guarantee, commitment, or representation as to the rate applied in any transaction.
Interstice does not control, determine, or guarantee any exchange rate, conversion outcome, or final amount received by any party.
All currency conversion outcomes are determined by external financial systems and counterparties. Interstice does not apply, enforce, or execute any currency conversion.
14. Modification or Discontinuation
Interstice may, at any time and in its sole discretion, modify, suspend, or discontinue the Venezuela Protocol, in whole or in part, without liability.
The Venezuela Protocol is provided on an “as is” and “as available” basis. Interstice does not guarantee that the Protocol will be available on a continuous, uninterrupted, secure, or error-free basis.
The availability and functionality of the Protocol may change at any time due to technical, regulatory, operational, or business considerations.
15. No Guarantee of Payment Outcome
Interstice makes no representation or warranty that any payment will be completed, delivered, received, or processed successfully.
Interstice shall not be responsible for any failure, delay, rejection, reversal, or inability to complete a payment, including any outcome resulting from third-party financial institutions, payment processors, counterparties, or regulatory constraints.
16. No Agency or Transaction Relationship
Nothing in the Venezuela Protocol shall be deemed to create any agency, intermediary, fiduciary, partnership, or joint venture relationship between Interstice and any user, sender, recipient, or third party.
Interstice does not act on behalf of any party, does not represent any party, and does not participate in any transaction or payment relationship between users.