General Terms and Conditions

Last updated: May 2026

Satoshi Connect SA

1. Purpose and scope of application

These General Terms and Conditions (the “GTC”) govern the business relationship between Satoshi Connect SA, a Swiss limited company (société anonyme) having its registered office in Neuchâtel, registered with the Commercial Register of the Canton of Neuchâtel under enterprise identification number CHE-213.053.544 (“Satoshi Connect”), and any natural or legal person (the “Client”) who accesses the services offered by Satoshi Connect.

Satoshi Connect is a financial intermediary within the meaning of Article 2, paragraph 3 of the Swiss Federal Act on Combating Money Laundering and Terrorist Financing (AMLA), affiliated with SO-FIT, a self-regulatory organisation recognised by the Swiss Financial Market Supervisory Authority (FINMA). Satoshi Connect carries out its activities within the regulatory framework applicable to financial intermediaries affiliated with a self-regulatory organisation under the AMLA.

These GTC apply to all services offered by Satoshi Connect (the “Services”), as defined below. They set out the respective rights and obligations of Satoshi Connect and the Client in connection with the use of the Services.

Access to the Services is reserved to Clients who have been admitted under the conditions set out in Article 4.

These GTC are made available to the Client on Satoshi Connect’s website and, where applicable, by any other appropriate means prior to the establishment of the business relationship or the use of the Services.

By requesting the establishment of a business relationship with Satoshi Connect, by using the Services or by transmitting instructions to Satoshi Connect, the Client acknowledges having taken note of these GTC and being bound by them.

Any special terms and conditions applicable to specific Services supplement these GTC. In the event of any conflict, the special terms shall prevail in respect of the Services they govern, unless otherwise expressly stipulated.

2. Definitions

For the purposes of these GTC, the following terms shall have the meanings set out below:

  • “Assets” means fiat currencies and crypto-assets that are the subject of an Order.
  • “Crypto-assets” means digital assets recorded on a distributed ledger (blockchain) and traded within the scope of the Services.
  • “Fees” means the principal remuneration of Satoshi Connect within the meaning of Article 10.
  • “Order” means any instruction from the Client to Satoshi Connect for the purpose of entering into a transaction relating to Assets within the scope of the Services.

3. General representations of the Client

By using the Services, the Client represents and warrants that they:

  • are at least 18 years of age or have reached the legal age of majority in their jurisdiction of residence;
  • have full legal capacity to contract with Satoshi Connect;
  • are acting on their own behalf or, where applicable, as a duly authorised representative of a legal entity;
  • have not been suspended or excluded from the Services by Satoshi Connect;
  • shall provide Satoshi Connect with accurate, complete and non-misleading information;
  • shall not use the Services for unlawful purposes, including, in particular, money laundering, terrorist financing, tax evasion or the circumvention of international sanctions;
  • are authorised to access the Services in accordance with the laws and regulations applicable to them, in particular with regard to their nationality, domicile, tax residence or registered office;
  • where they are not domiciled in Switzerland, are accessing the Services on their own initiative and not as a result of any active or targeted solicitation by Satoshi Connect in their jurisdiction of residence.

The Client undertakes to inform Satoshi Connect without delay of any change that may affect the accuracy of the foregoing representations.

4. Access to the Services and admission of Clients

Access to the Services is subject to a prior admission procedure. Satoshi Connect reserves the right, at its sole discretion and in compliance with applicable law, to accept or reject any application for access to the Services, without being required to state the reasons for its decision.

All or part of this admission process may be delegated by Satoshi Connect to third-party service providers, in particular in connection with applicable identification, compliance and risk assessment procedures.

The initial acceptance of a Client does not create any acquired right to access the Services or to the continuation of the business relationship. Satoshi Connect reserves the right, at its sole discretion and in compliance with applicable law, to terminate the business relationship at any time.

The Services are intended for Clients whose needs and intended use correspond to Satoshi Connect’s operational, regulatory and risk management model.

Satoshi Connect reserves the right, at any time, to restrict access to all or part of its Services, to refuse the execution of certain Orders or to make access to the Services subject to additional conditions, in particular in matters of compliance, risk management or internal organisation.

5. Geographic restrictions and absence of solicitation

The Services are primarily intended for Clients domiciled or having their registered office in Switzerland. Satoshi Connect may, at its sole discretion and subject to compliance with applicable legal, regulatory and operational requirements, accept Clients domiciled or having their registered office in other jurisdictions.

The Services are not intended for natural or legal persons who, by reason of their nationality, domicile, tax residence, registered office or any other applicable circumstance, are subject to legal or regulatory restrictions limiting or prohibiting access to the Services.

In particular, the Services are not offered where their provision by Satoshi Connect would require an authorisation, licence, registration or any other specific regulatory procedure in the jurisdiction concerned, in particular with regard to regulations applicable to financial services or crypto-assets.

Access to Satoshi Connect’s website and the use of the Services by persons located outside Switzerland take place exclusively at the Client’s own initiative. It is the Client’s sole responsibility to verify that the legislation applicable to them permits them to access the Services.

Satoshi Connect reserves the right to restrict or refuse access to the Services, in particular on the basis of:

  • applicable legal or regulatory requirements;
  • its internal compliance and risk management policies;
  • restrictions or constraints imposed by its banking partners or other operational partners.

6. Description of the Services

Satoshi Connect offers brokerage and execution services for transactions in crypto-assets and, where applicable, for their conversion into fiat currency (the “Orders”).

The Services may include, in particular, purchase, sale, conversion, settlement or payment transactions involving crypto-assets.

The Services are intended for professional, institutions and natural persons admitted under the conditions set out in Article 4.

Satoshi Connect may modify, restrict, suspend or evolve the scope of the Services at any time, without amendment to these GTC.

7. Nature of the Services and capacity of the parties

Satoshi Connect acts as direct counterparty (principal) to the Client in transactions entered into within the scope of the Services. No business relationship is created between the Client and any third party, including exchange platforms, market makers or professional counterparties that Satoshi Connect may engage in connection with the execution of Orders, its risk management or its treasury management.

Satoshi Connect shall in no case act as custodian, asset manager or portfolio manager on behalf of the Client.

The Services are provided on an execution-only basis. Satoshi Connect does not provide any investment advice, personalised recommendation, asset management service, financial advisory service, or any assessment of the suitability or appropriateness of the transactions carried out by the Client. The Client makes their decisions autonomously, on the basis of their own analysis and, where appropriate, with the assistance of independent advisors.

Satoshi Connect assumes no obligation to provide liquidity, to guarantee a given price, an execution timeframe or a level of liquidity. Satoshi Connect may refuse or suspend the execution of any Order, in whole or in part, at its sole discretion.

8. Order placement and execution process

The Client transmits their Order requests and the information necessary for their execution through the communication channels made available by Satoshi Connect.

Depending on the nature of the transaction concerned, the Client may be required to provide information including, in particular, in relation to the Assets concerned, the amounts, the banking details or the digital wallet addresses necessary for the execution of the Order.

Any Order request transmitted to Satoshi Connect remains subject to validation and acceptance by Satoshi Connect. Satoshi Connect reserves the right to accept, refuse, suspend or restrict any Order, in whole or in part, at its sole discretion and in compliance with applicable law.

The operational arrangements applicable to the execution of Orders may be determined or modified by Satoshi Connect at any time.

Orders are executed on a best-efforts basis and depend, in particular, on market conditions, the availability of counterparties, operational constraints and applicable regulatory requirements.

The Client acknowledges that market conditions may change between the transmission of an Order request and its actual execution.

9. Qualification of funds remitted by the Client

Assets remitted by the Client to Satoshi Connect in connection with the execution of an Order are received exclusively for the purposes of executing the Services in accordance with Satoshi Connect’s brokerage and order execution model.

Satoshi Connect acts as direct counterparty (principal) to the Client and does not provide any custody or safekeeping services for Assets on behalf of the Client.

Assets remitted to Satoshi Connect are not subject to any segregation or individualised safekeeping on behalf of the Client. The Client has solely a contractual claim against Satoshi Connect relating to the execution of the Order in accordance with these GTC.

Assets received by Satoshi Connect are held only for the period necessary for the execution of the Orders, subject to operational constraints, applicable compliance checks and legal and regulatory obligations.

If an Order cannot be executed for any reason whatsoever, in particular due to compliance checks, operational constraints, market unavailability or incomplete instructions from the Client, Satoshi Connect shall return the Assets concerned to the Client as soon as reasonably practicable, subject to applicable legal and regulatory obligations and applicable Fees and costs.

In any event, save where mandatory legal or regulatory provisions provide otherwise, Assets relating to an Order that remains unexecuted shall not be retained beyond a maximum period of sixty (60) days calculated from the day following their receipt by Satoshi Connect.

In particular, in the event of the application of freezing measures within the meaning of Article 10 AMLA or any other legal or regulatory obligation preventing the return of the Assets concerned, Satoshi Connect shall retain the Assets until the relevant measure is lifted, without this being qualified as a custody or safekeeping service. The Client shall not be entitled to any interest, indemnity or other compensation by reason of such unavailability.

10. Fees and costs

Satoshi Connect charges a commission in respect of the Services provided (the “Fees”).

In addition to the Fees, the Client shall bear the costs and expenses actually incurred in connection with the execution of Orders, including blockchain network fees, banking fees and fees charged by exchange platforms, counterparties or liquidity providers.

Such fees and costs may be deducted from the amounts received, deducted from the amounts transferred, or may affect the net amount ultimately received by the Client or the relevant beneficiary, depending on the nature of the Order and the applicable execution arrangements.

The applicable Fees and, where relevant, the principal costs associated with the execution of an Order are communicated to the Client prior to its execution. By confirming the Order, the Client acknowledges and accepts the applicable Fees and costs.

11. Client cooperation obligations

The Client is required to use the Services in accordance with these GTC, applicable laws and the instructions communicated by Satoshi Connect.

The Client is required to provide accurate, complete and up-to-date information, and to inform Satoshi Connect without delay of any material change to the information provided in connection with the business relationship, in particular with regard to their identity, address or registered office, tax residence, nationality, beneficial owner or the origin of the Assets used within the scope of the Services.

The Client is solely responsible for the lawfulness of the Assets used within the scope of the Services, for the accuracy of the instructions transmitted and for the security and confidentiality of their means of communication.

The Client is required to cooperate fully with Satoshi Connect in connection with its compliance obligations, in particular by providing, upon request, any information or document required.

12. Compliance, anti-money laundering and Travel Rule

Satoshi Connect applies the Swiss laws and regulations applicable in matters of anti-money laundering, international sanctions, combating the financing of terrorism and risk management.

The Client authorises Satoshi Connect to collect, process and transmit, where necessary, the information relating to the originator and the beneficiary of crypto-asset transfers in accordance with applicable legal and regulatory obligations, in particular in connection with the so-called “Travel Rule” requirements.

Subject to any mandatory legal provisions to the contrary, Satoshi Connect may, without prior notice and without any obligation to state reasons, refuse an Order, suspend the Services, freeze transactions or terminate the business relationship in the event of regulatory, legal, operational or reputational risk, or non-cooperation of the Client.

Such measures may be implemented without compensation, subject to the mandatory provisions of applicable law.

13. Limitation of liability

Within the limits of mandatory law, Satoshi Connect disclaims any liability for losses resulting, in particular, from:

  • market volatility;
  • the non-execution or late execution of Orders;
  • technical malfunctions or security incidents affecting systems outside Satoshi Connect’s sphere of control;
  • or decisions taken by the Client.

Within the limits of mandatory law, Satoshi Connect excludes any liability for indirect or consequential damages or for loss of profit suffered by the Client.

Subject to applicable mandatory law, the liability of Satoshi Connect is limited to cases of wilful misconduct or gross negligence.

Without prejudice to the other limitations provided for in these GTC and within the limits of mandatory law, Satoshi Connect’s total liability in connection with an Order, whether contractual, tortious or based on any other cause of action, shall be limited to the amount of the Fees received by Satoshi Connect in respect of the relevant Order.

The limitations and exclusions of liability provided for in these GTC also apply to the officers, directors, employees, auxiliary persons and other persons engaged by Satoshi Connect in connection with the provision of the Services.

14. Risk factors and absence of warranty

Crypto-assets and distributed ledger technologies entail significant technological, operational, regulatory and market risks. Their operation relies, in particular, on systems, protocols, networks, infrastructures and third-party providers that may be subject to failures, interruptions, errors, attacks, modifications or restrictions outside Satoshi Connect’s sphere of control.

The Client acknowledges that the use of the Services may result in significant losses, including the total loss of the Assets concerned.

The Client acknowledges in particular:

  • the high volatility of crypto-assets;
  • the risks associated with blockchain infrastructures, computer networks and third-party providers;
  • the risks of fraud, cyber-attack, unauthorised access or technical failure;
  • as well as the generally irreversible nature of blockchain transactions.

It is the Client’s responsibility to verify, with the utmost care, the information, details, digital wallet addresses and instructions transmitted in connection with the Services. Satoshi Connect cannot guarantee the recovery of Assets transferred to an incorrect, invalid or inaccessible address.

Satoshi Connect provides no warranty as to the continuous availability of the Services, the absence of interruption or error, or the operation, security or integrity of the crypto-assets, blockchains, protocols or infrastructures used within the scope of the Services.

Within the limits of applicable law, the Services are provided “as is” and “as available”. The Client acknowledges that they alone bear the risks associated with the use of the Services and with crypto-assets.

15. Indemnification

The Client undertakes to indemnify and hold Satoshi Connect harmless from any reasonable claim, loss, damage, cost or expense, including legal fees, resulting directly from:

  • a breach by the Client of these GTC or of any other terms applicable to the business relationship;
  • any use of the Services that does not comply with applicable laws or with the instructions communicated by Satoshi Connect;
  • the provision of inaccurate, incomplete or misleading information by the Client;
  • or any claim or action brought by a third party or an authority in connection with the acts or omissions of the Client.

16. Confidentiality and security

16.1 Confidentiality

Each party shall treat as confidential all non-public information exchanged in connection with the business relationship and shall refrain from disclosing such information to third parties, save to the extent necessary for the performance of the Services or where disclosure is required by law, regulation or a competent authority.

Confidentiality obligations do not apply to information which is or becomes publicly available without breach of these GTC, which has been lawfully obtained from a third party authorised to disclose it, or whose disclosure is imposed by a legal or regulatory obligation.

16.2 Electronic communications and security

The Client acknowledges that exchanges carried out by electronic means, including via the Internet, electronic mail, online platforms or other electronic means of communication, involve inherent risks, in particular risks of interception, alteration, delay, loss of data, identity theft or unauthorised access.

The Client is responsible for the security and confidentiality of their means of communication, identifiers, passwords, authentication codes and other means of access to the Services.

The Client undertakes to take all reasonable measures to prevent any unauthorised access to the Services or any misuse thereof.

Satoshi Connect shall never ask the Client to disclose their passwords or authentication codes. Any such request must be ignored and reported to Satoshi Connect without delay.

16.3 Acceptable use

The Client shall use the Services, the website and any platforms or interfaces made available by Satoshi Connect lawfully and in accordance with these GTC.

The Client shall refrain, in particular, from any attempt at unauthorised access, any breach of security measures or any use likely to compromise the security, integrity or availability of the Services or of Satoshi Connect’s systems.

17. Data protection

Satoshi Connect processes the Client’s personal data in accordance with its Privacy Policy in force, accessible on Satoshi Connect’s website, which forms an integral part of the business relationship.

Satoshi Connect may process and retain certain data, documents and information relating to the use of the Services for purposes of security, fraud prevention, risk management, compliance and compliance with its legal and regulatory obligations.

The Client acknowledges that certain data may be transmitted to service providers, counterparties, authorities or competent bodies where this is necessary for the provision of the Services or for compliance with applicable legal and regulatory obligations.

Documents and data relating to the business relationship are retained in accordance with applicable legal requirements, in particular in matters of anti-money laundering.

Satoshi Connect’s website and Services may contain links to third-party websites, applications, platforms or resources. Such links are provided for information purposes only. Satoshi Connect exercises no control over these items and disclaims any liability as to their content, availability or security, or as to the products and services offered therein.

The Client shall inform Satoshi Connect as soon as reasonably practicable of any anomaly, error, security vulnerability or suspicious use of which they become aware in connection with the Services. Satoshi Connect shall handle such reports with reasonable diligence, without any guarantee of outcome or specific processing time.

19. Duration, suspension and termination

The business relationship is entered into for an indefinite duration.

Satoshi Connect may suspend, restrict or interrupt at any time the Client’s access to all or part of the Services, at its sole discretion, in particular in the event of breach by the Client, compliance risk, legal, regulatory, operational or reputational risk, prolonged inactivity, or technical, organisational or security necessity, subject to applicable law.

The Client may terminate the business relationship at any time by written notice or through the means made available by Satoshi Connect, subject to the finalisation of pending transactions and applicable legal obligations.

Satoshi Connect may terminate the business relationship at any time, with immediate effect or upon reasonable prior notice, without being required to state the reasons for its decision, in particular where the relationship is deemed incompatible with its operational, regulatory or risk management model.

Upon termination of the business relationship, the Client loses access to the Services, pending Orders may be cancelled or suspended, and Satoshi Connect may, where appropriate, return the Assets in accordance with these GTC and applicable legal requirements.

The provisions of these GTC which, by their nature, are intended to survive the termination of the business relationship shall remain applicable thereafter.

20. Notices and communications

The Client accepts that communications and notices from Satoshi Connect may be made by electronic means, in particular by e-mail, via an online interface, a platform, a secure messaging system or any other communication channel made available by Satoshi Connect.

Save where mandatory provisions provide otherwise, any communication transmitted by Satoshi Connect to the contact details or identifiers provided by the Client shall be deemed validly delivered.

It is the Client’s responsibility to keep their contact details and information up to date and to consult regularly the communication channels used in connection with the Services.

21. General provisions

21.1 No waiver

The failure or delay by Satoshi Connect to exercise any right shall not constitute a waiver of such right.

21.2 Severability

If any provision of these GTC is held to be invalid, void or unenforceable, the remaining provisions shall remain in full force and effect. The parties shall endeavour to replace the provision concerned with a valid provision that best reflects the original intent.

21.3 Assignment

The Client may not assign all or part of their rights or obligations arising from these GTC without the prior written consent of Satoshi Connect.

Satoshi Connect may assign all or part of the business relationship to an affiliated company or to a successor entity, subject to applicable law.

21.4 Amendments to the GTC

Satoshi Connect reserves the right to amend these GTC at any time. The latest version of the GTC is published on Satoshi Connect’s website. It is the Client’s responsibility to review the latest version of the GTC before using the Services or transmitting any Order.

Continued use of the Services after the entry into force of the amended GTC shall constitute acceptance of the amendments. A Client who does not accept the amendments may terminate the business relationship in accordance with Article 19.

The version of the GTC in force at the time an Order is transmitted by the Client shall apply to the relevant Order.

21.5 Intellectual property

All content, visual elements, trademarks, software, documentation and other items relating to Satoshi Connect’s website or Services are protected by applicable intellectual property rights and remain the property of Satoshi Connect or of the relevant third parties.

Save with the prior written authorisation of Satoshi Connect, any reproduction, modification, redistribution or unauthorised use of such items is prohibited.

22. Governing law and jurisdiction

These GTC, as well as any legal relationship between the Client and Satoshi Connect, are governed by Swiss law, to the exclusion of conflict-of-law rules.

The exclusive place of jurisdiction for any dispute arising out of or in connection with these GTC is Neuchâtel, Switzerland, subject to the mandatory provisions of applicable law, in particular as regards consumer jurisdiction.

23. Contact

For any questions regarding these Terms or the Website, please contact:

Satoshi Connect SA
Rue Saint-Honoré 2
2000 Neuchâtel, Switzerland

Email: contact@satoshi-connect.ch