3. About Us and Our Regulatory Status

3.1  Bloomsbury Money Jersey Limited is a company incorporated in Jersey, Channel Islands, with registered office at 3rd Floor, IFC5, Castle Street, St Helier, Jersey, JE2 3BY, and company registration number 151029. Our Jersey office (compliance and operations) is at the same address, and our London headquarters is at The Bloomsbury Building, 10 Bloomsbury Way, London, WC1A 2SL, United Kingdom. You can contact us by telephone on +44 (0) 203 6 333 333, by email to support@bloomsburymoney.com, or using the details published on our website.

3.2  We are registered with the Jersey Financial Services Commission (JFSC) to carry on money service business under the Financial Services (Jersey) Law 1998, and we are registered and supervised by the JFSC in respect of our virtual asset service provider (VASP) activities under Jersey’s financial services and AML/CFT regulatory regime. Our registration details appear on the JFSC public register at www.jerseyfsc.org (registry reference 210054).

3.3  We are regulated and supervised only by the JFSC, within the scope of our MSB and VASP registrations. We are not authorised or regulated by the UK Financial Conduct Authority (FCA) or by any other regulator in any jurisdiction outside Jersey, and, save as described in Section 7.5 in respect of funds held in real accounts with UK banks, no protections available under the regulatory or compensation regime of any other jurisdiction apply to your relationship with us.

3.4  We are not a bank. We do not accept deposits and we do not pay interest on balances. Funds held in your Account are not deposits with us, and are not protected by the Bank Depositors Compensation Scheme established under the Banking Business (Depositors Compensation) (Jersey) Regulations 2009. Where funds are held in real accounts with a UK bank, protection under the UK Financial Services Compensation Scheme may be available as described in Section 7.5.

3.5  The JFSC’s registration of our business is not an endorsement of, and does not constitute any guarantee in respect of, our Services, and the JFSC does not accept liability for any loss you may suffer in connection with your use of the Services.

4. Client Classification and Global Onboarding

4.1  We provide the Services under these Terms only to Professional Clients. We will classify you as a Professional Client where, on the basis of the information you provide during onboarding, we are satisfied that you are a body corporate, partnership, trust, foundation, institutional client, or an individual who possesses the experience, knowledge and expertise to make your own financial decisions and to properly assess the risks of the Services.

4.2  As a Professional Client you acknowledge that certain protections that might apply to retail consumers do not apply to you, that you are responsible for assessing the suitability of the Services for your own needs, and that you have had the opportunity to take independent legal, tax and financial advice before entering into the Agreement.

4.3  Global onboarding. We onboard clients on a global basis. Your eligibility for the Services is determined by our individual onboarding, due diligence and risk assessment of you — not by your region. We do not classify clients by reference to any particular country grouping, and the Services, Payment Rails, currencies and products available to you are determined by your individual risk profile and our risk appetite, and may differ from those available to other clients.

4.4  We do not offer the Services in any jurisdiction where their provision would be contrary to Applicable Laws, and we may decline, restrict or exit clients from particular jurisdictions at our discretion, including for sanctions or risk-appetite reasons. You are responsible for ensuring that your access to and use of the Services is lawful in the jurisdiction(s) in which you are located, incorporated or operating.

4.5  You must notify us promptly of any change in your circumstances which could affect your classification or eligibility. We may re-classify you or terminate the Agreement if you cease to satisfy our Professional Client criteria.

5. Services, Eligibility, Onboarding and Risk Assessment

5.1  Subject to these Terms and to our onboarding and risk-assessment processes, we may provide you with some or all of the following Services: (a) multi-currency Accounts accessed through the Platform; (b) domestic (local) and cross-border payments in and out; (c) foreign exchange services, comprising spot FX Conversions only; (d) virtual asset services, including custody/storage of supported Virtual Assets and transfers of Virtual Assets in and out, provided on a principal basis as described in Section 11; and (e) issuance and servicing of Visa debit Cards for individuals and businesses.

5.2  Provision of any Service is at our discretion. We are not obliged to provide any particular Service, currency, Virtual Asset, Payment Rail or Card product to any client.

5.3  Due diligence information. Before opening an Account, and on an ongoing basis, we will carry out customer due diligence, identity verification, sanctions screening and risk assessment in accordance with the AML/CFT Legislation. You shall provide us with any information we request from time to time for these purposes (“DD Information”), including information required to verify your identity, beneficial ownership, control structure, source of funds and source of wealth, and the nature and purpose of your intended use of the Services.

5.4  You shall notify us of any changes to DD Information as soon as reasonably practicable. You agree that we may provide DD Information to Correspondent Banks, card schemes and other third parties for the purposes of complying with scheme rules or Applicable Laws. Failure to comply with this Section 5 is a material breach of these Terms entitling us to terminate the Agreement.

5.5  Payment Rails. The Payment Rails available to you are assigned by us upon successful completion of onboarding and our risk assessment. The Payment Rails assigned to you depend on factors including your risk profile, jurisdiction, business activity, currencies required and the requirements of our Correspondent Banks, and may vary from time to time at our discretion or as required by our Correspondent Banks or Applicable Laws. We may add, change, suspend or withdraw Payment Rails at any time without liability to you, and we will use reasonable efforts to notify you of material changes where lawful and practicable.

5.6  We may decline to open an Account, or decline to provide any Service, without giving reasons, where permitted by law.

5.7  Our obligations. We shall provide the Services in accordance with these Terms, any applicable service schedule, Applicable Laws and applicable scheme rules. Your obligations. You shall at all times comply with these Terms, Applicable Laws and applicable scheme rules, and shall pay the fees and charges when due; failure to do so is a material breach of these Terms.

6. Role of Correspondent Banks

6.1  As an MSB, we do not operate our own clearing or settlement infrastructure. All payments made through your Account are executed by the underlying Correspondent Banks and payment infrastructure providers with whom we maintain arrangements. Funds credited to your Account are held by us with Correspondent Banks.

6.2  You acknowledge that: (a) the execution, timing, routing and completion of any payment depends on the relevant Correspondent Banks and Payment Rails; (b) Correspondent Banks may apply their own compliance checks, cut-off times, holds, fees and deductions to payments; (c) a Correspondent Bank may delay, block, return or reject a payment, or freeze funds, in accordance with its own policies or legal obligations, and we are not liable for any resulting loss; and (d) intermediary and beneficiary bank charges may be deducted from payment amounts in accordance with international banking practice.

6.3  We will exercise reasonable skill and care in selecting and maintaining our Correspondent Bank relationships, but we are not liable for the acts, omissions, insolvency or default of any Correspondent Bank, except to the extent such liability cannot be excluded under Jersey law.

7. Your Account and the Platform

7.1  Your Account is a record of the funds and Virtual Assets we hold for you in connection with the Services. Balances do not constitute deposits and do not earn interest.

7.2  Client funds are held with Correspondent Banks in accounts designated for client money, segregated from our own operating funds, in accordance with applicable Jersey regulatory requirements and JFSC codes of practice applicable to our registrations.

7.3  The Platform. We provide access to the Services through the Platform. We may update, modify or maintain the Platform from time to time, and access may be interrupted for scheduled or emergency maintenance, security reasons or events outside our control. We do not guarantee uninterrupted availability of the Platform.

7.4  Account details. We may issue you with named account details (which may include IBANs, account numbers and routing details provided through our Correspondent Banks) for receiving payments in Supported Currencies. Depending on your onboarding outcome and assigned Payment Rails, these may be virtual account details or details of a real account as described in clause 7.5. Virtual account details are provided to facilitate the Services, may be changed by us or our Correspondent Banks, and do not represent a bank account held by you with any Correspondent Bank.

7.5  Real accounts and FSCS protection. Some Accounts or currency balances may be held in real (physical) bank accounts, rather than virtual accounts, maintained in the United Kingdom with ClearBank Limited or another UK-authorised bank. Where funds are held in this way, they may qualify for protection under the UK Financial Services Compensation Scheme (FSCS) in the event of the failure of the relevant UK bank, subject to the FSCS’s eligibility criteria, look-through requirements and limits (currently GBP 85,000 per eligible depositor, per bank, across all accounts held with that bank). We will inform you where your Account structure involves a real account. FSCS protection, where available, applies only to the failure of the relevant UK bank and does not apply to the failure of Bloomsbury Money, to virtual accounts, to Virtual Assets, or to funds held outside the UK. We make no representation or guarantee that FSCS protection will apply to you or to any particular balance, and you should verify your eligibility at www.fscs.org.uk.

7.6  Adding money. You may fund your Account by transfer from an account or wallet in your own name via the Payment Rails assigned to you. We may refuse, return or hold funds received from third parties or from sources inconsistent with your DD Information. Funds are credited to your Account only once we have actually received cleared funds and completed any required checks.

7.7  You must keep your Account credentials, passwords and API keys (“Security Credentials”) secure and ensure that only Authorised Users give instructions on your Account. You are responsible for all instructions given using your Security Credentials or by your Authorised Users, unless and until you have notified us that your Security Credentials have been compromised.

7.8  We may set and vary limits on your Account, including transaction, balance, velocity, ATM and Card limits, and minimum or maximum holding amounts, at our discretion.

7.9  We may refuse to act on any instruction which is unclear, incomplete, appears fraudulent or unauthorised, would breach these Terms or any law, exceeds applicable limits, or which a Correspondent Bank refuses to process.

7.10  Records of your transactions will be available in the Platform. You should check your records regularly in accordance with Section 22.2.

8. Authorised Users

8.1  You may nominate individuals to access and operate your Account as Authorised Users, subject to our approval and completion of any due diligence we require on such individuals. You may set permission levels for Authorised Users where the Platform allows.

8.2  You are responsible for the acts and omissions of your Authorised Users as if they were your own, and you must ensure that each Authorised User complies with these Terms. You must keep your list of Authorised Users up to date and promptly revoke access for any person who ceases to be authorised.

8.3  We may refuse, suspend or remove any Authorised User at our discretion, including for security or compliance reasons.