11. Virtual Asset Services - Storage and Transfers

11.1  Where we have approved you for virtual asset services, we may provide (a) custody/storage of supported Virtual Assets in wallets administered by us or by our approved custodians, and (b) transfers of supported Virtual Assets into and out of your Account. The Virtual Assets and blockchain networks we support may change at any time. All virtual asset Services are provided by us acting as principal, as further described in clauses 11.2 and 11.3.

11.2  Principal dealing and transfer of title. All Virtual Assets (but, for the avoidance of doubt, not fiat currency) received by us from you or on your behalf are received by us acting as principal, and not as agent, nominee, trustee, custodian or fiduciary. Full legal and beneficial title to, and ownership of, any Virtual Assets transferred to us passes to Bloomsbury Money at the point of receipt, being the time at which the relevant transfer is recorded in a wallet or address controlled by us with the number of network confirmations we require. Upon receipt, and subject to completion of our compliance checks under clause 11.6, we will credit your Account and you will acquire a contractual entitlement against us for the delivery of Virtual Assets equivalent in type and quantity to those received (or their redemption in accordance with these Terms). Virtual Assets credited to your Account are not held on trust or under a custodial or client-asset arrangement, are not segregated from our own assets, and in the event of our insolvency you would rank as an unsecured creditor in respect of your contractual entitlement. References in these Terms to the "custody" or "storage" of Virtual Assets shall be construed accordingly as the safekeeping by us of Virtual Assets in which we hold title, against our contractual obligation to deliver equivalent Virtual Assets to you. This clause does not apply to fiat currency, which continues to be held in accordance with Section 7.

11.3  Virtual asset transfer information ("Travel Rule"). The Money Laundering (Jersey) Order 2008 and Financial Action Task Force Recommendation 16 impose requirements (the "Travel Rule") on virtual asset service providers to obtain, hold and transmit required originator and beneficiary information when executing virtual asset transfers on behalf of a customer. Because we deal in Virtual Assets exclusively as principal in accordance with clause 11.2, a transfer of Virtual Assets between you and us constitutes the bilateral settlement of a principal transaction to which we are ourselves a party — as beneficiary of inbound transfers and as originator of outbound transfers — and is not a virtual asset transfer executed by us on behalf of an originator for the benefit of a distinct third-party beneficiary. The parties accordingly acknowledge that the Travel Rule’s originator-and-beneficiary transmission requirements are not applicable to such first-party settlement flows between you and us. This clause does not limit our obligations or your obligations under the AML/CFT Legislation: we will in all cases collect, verify and retain customer due diligence information in respect of you and the wallets and addresses you use, including in respect of transfers to or from unhosted wallets, and we may decline any transfer where such information is not provided. Where any transfer does constitute a virtual asset transfer executed on behalf of a customer — including any transfer you instruct us to make to, or to receive from, a third party or an account or wallet held with another virtual asset service provider — the Travel Rule applies to that transfer and we will collect and transmit the required information before executing it.

11.4  Risk warning. Virtual Assets are high-risk. Their value can be extremely volatile and may fall to zero. Virtual Assets are not legal tender, are not backed by any government or central bank, and holdings of Virtual Assets are not protected by any depositor compensation, investor compensation or insurance scheme. You should not use the virtual asset Services unless you understand and can bear these risks. You are solely responsible for your decisions to buy, hold, transfer or dispose of Virtual Assets.

11.5  Irreversibility. Blockchain transactions are generally irreversible. If you provide an incorrect wallet address, an address on the wrong network, or transfer an unsupported asset, the Virtual Assets are likely to be permanently lost and we will have no obligation or ability to recover them.

11.6  Transfers in. We will credit inbound Virtual Asset transfers only after the required number of network confirmations and completion of our compliance checks, including blockchain analytics screening. We may quarantine, return (where technically possible) or refuse Virtual Assets that we assess as linked to illicit activity, sanctioned wallets, mixers or other high-risk sources.

11.7  Transfers out. Outbound transfers are subject to our compliance checks, the information collection and, where applicable, transmission requirements described in clause 11.3, network conditions and network fees. We may delay or decline any transfer to unhosted wallets or to counterparties or jurisdictions that fall outside our risk appetite.

11.8  Forks, airdrops and staking. We are not obliged to support any fork, airdrop, token migration or other network event, and we have no liability for any value attributable to unsupported events. We do not offer staking, lending or yield products under these Terms.

11.9  Network risk. We are not responsible for the operation, security or availability of any blockchain network, nor for losses arising from network failures, consensus attacks, smart-contract defects, protocol changes or third-party wallet software.

12. Visa Debit Cards - Issuance and Use

12.1  We may, at our discretion and subject to the rules of Visa and of our card issuing partners, issue Visa debit Cards linked to your Account to eligible individuals and businesses. Business clients may nominate Authorised Cardholders; you are responsible for the use of every Card issued on your Account and for ensuring Authorised Cardholders comply with these Terms.

12.2  Use of the Card. Cards may be used, up to available Account balance and applicable limits, for purchases in person, online and via contactless payment, and for ATM withdrawals, wherever Visa is accepted, unless a merchant category or country is blocked by us, by our issuing partner or by Visa. The Card is a debit card: transactions are funded from your Account balance and no credit is provided.

12.3  Card transactions in a currency different from the Account currency are converted at the applicable Visa scheme rate plus any margin set out in the Fee Schedule, applied on the date the transaction is processed.

12.4  Card security. You and each Authorised Cardholder must keep the Card, PIN and card credentials secure, not disclose the PIN to anyone, and take reasonable steps to prevent unauthorised use. You must notify us without undue delay, through the channels we specify, if a Card is lost or stolen or you suspect unauthorised use, in which case we will block the Card.

12.5  Authorisations, holds and refunds. Merchants may seek pre-authorisations that place a hold on your available balance. Refunds are credited when received from the merchant/acquirer through the Visa network. Disputes and chargebacks are handled in accordance with Visa scheme rules and applicable timeframes; we will assist with eligible disputes but do not guarantee the outcome of any chargeback.

12.6  As a Professional Client, and to the extent permitted by Applicable Laws, you bear the losses arising from unauthorised Card transactions occurring before you notify us of loss, theft or compromise, and all losses where you or an Authorised Cardholder acted fraudulently or with gross negligence, including failing to keep credentials secure.

12.7  We may decline authorisations, suspend or cancel any Card, or vary Card limits and functionality at any time, including where required by Visa, our issuing partner, our Correspondent Banks or Applicable Laws. Cards remain our property (or that of our issuing partner) and must be returned or destroyed on request.