Overview

This page provides detailed information about BlockRiver AG's regulatory status, supervisory framework, and compliance obligations.

Swiss Regulation

Company Registration

Legal Entity: BlockRiver AG (Aktiengesellschaft) Jurisdiction: Switzerland Commercial Register: Schwyz Commercial Register Registration Number: CHE-320.754.925 Registered Address: Asetstrasse 37, 6438, Ibach, Switzerland

VQF Membership

BlockRiver AG is a member of VQF (Verein zur Qualitätssicherung von Finanzdienstleistungen), a Self-Regulatory Organisation under Swiss law.

VQF Details: Verein zur Qualitätssicherung von Finanzdienstleistungen Talstrasse 70 8001 Zürich Switzerland Website: www.vqf.ch

VQF Recognition: VQF is officially recognised by the Swiss Financial Market Supervisory Authority (FINMA) under Article 24 of the Swiss Anti-Money Laundering Act (AMLA).

Supervision Scope: As a VQF member, BlockRiver AG is subject to supervision for compliance with Swiss anti-money laundering and counter-terrorist financing regulations. VQF conducts regular audits of its members' AML/KYC procedures, policies, and controls.

What VQF Membership Means

VQF membership authorises BlockRiver AG to:

• Act as a financial intermediary under Swiss AMLA
• Provide crypto-asset exchange and brokerage services
• Provide precious metals exchange and custody services
• Provide crypto-asset transfer services
• Offer custody of crypto-assets (subject to applicable requirements)
• Provide white-label software solutions for crypto-asset services

VQF membership does NOT mean:

• BlockRiver AG is a bank or banking institution
• BlockRiver AG is supervised by FINMA for prudential, conduct, or market regulation
• BlockRiver AG holds a securities dealer license
• BlockRiver AG is authorized to accept deposits from the public
• BlockRiver AG provides regulated financial services beyond crypto-asset services

FINMA Status

BlockRiver AG is NOT directly supervised by FINMA for banking, securities, insurance, or other regulated financial services.

BlockRiver AG does NOT hold:

• A banking license under the Swiss Banking Act
• A securities dealer license under FINMAG
• A DLT trading facility license
• A FinTech license
• Any other FINMA authorization

FINMA supervises VQF as a Self-Regulatory Organisation, but does not directly supervise individual VQF members unless they engage in activities requiring direct FINMA authorization.

FINMA Public Warnings:

BlockRiver AG has never been the subject of any warning, enforcement action, or public statement by FINMA. You can verify this by checking FINMA's public warning list at: https://www.finma.ch/en/warning-list/

We are not aware of any pending or threatened regulatory investigations or enforcement actions by any financial regulator.

Anti-Money Laundering Compliance

BlockRiver AG is subject to comprehensive AML/CTF obligations under:

• Swiss Federal Act on Combating Money Laundering and Terrorist Financing (AMLA)
• FINMA Anti-Money Laundering Ordinance (AMLO-FINMA)
• VQF Regulations and Guidelines
• FATF Recommendations

Our AML Framework includes:

• Customer due diligence (KYC) procedures
• Enhanced due diligence for higher-risk clients
• Ongoing monitoring of business relationships
• Transaction monitoring and reporting
• Sanctions screening
• Record keeping
• Internal controls and governance
• Regular independent audits
• Employee training programs

Suspicious Activity Reporting: BlockRiver AG is obligated to report suspicious transactions to the Swiss Money Laundering Reporting Office (MROS).

Travel Rule Compliance: BlockRiver AG complies with FINMA's Travel Rule requirements for transmission of originator and beneficiary information with crypto-asset transfers.

European Union (MiCA)

MiCA Does Not Apply Directly

The EU Markets in Crypto-Assets Regulation (MiCA) does NOT directly apply to BlockRiver AG because:

• BlockRiver AG is a Swiss entity
• Switzerland is not a member of the European Union or European Economic Area
• BlockRiver AG is not established in the EU/EEA

MiCA Status

BlockRiver AG does NOT hold:

• MiCA authorization as a Crypto-Asset Service Provider (CASP)
• Authorization to issue Asset-Referenced Tokens (ARTs)
• Authorization to issue E-Money Tokens (EMTs)
• Any other MiCA-related authorization or registration

Services to EU/EEA Clients

BlockRiver AG does not actively market, promote, or solicit clients in EU/EEA jurisdictions.

Services are provided to EU/EEA corporate entities only on a reverse solicitation basis, meaning:

• The client approaches BlockRiver AG entirely at their own exclusive initiative
• No marketing, advertising, or promotional activities by BlockRiver AG preceded the approach
• The client independently sought out BlockRiver AG's services
• BlockRiver AG did not engage in any inducement or solicitation

Client Responsibility: EU/EEA corporate entities considering BlockRiver AG's services must:

• Ensure compliance with MiCA and applicable national laws in their jurisdiction
• Determine whether use of a non-MiCA authorized service provider is permitted
• Obtain any necessary authorizations or approvals
• Understand that they are using a non-MiCA authorized provider

BlockRiver AG makes no representation regarding the availability or legality of its services in any EU/EEA jurisdiction.

United Kingdom

FCA Status

BlockRiver AG is NOT:

• Authorized by the UK Financial Conduct Authority (FCA)
• Registered with the FCA under the Money Laundering Regulations
• Approved to conduct regulated activities in the UK
• Permitted to market financial promotions to UK retail consumers

UK Financial Promotions Regime

BlockRiver AG does NOT:

• Market or promote services to UK retail consumers
• Conduct financial promotions directed at the UK
• Solicit UK clients through advertising, marketing, or promotional activities

UK Corporate Entities: BlockRiver AG may consider providing services to UK-incorporated corporate entities on a strictly reverse solicitation basis, subject to:

• The entity qualifying as a professional client or eligible counterparty
• Compliance with UK financial services regulations
• Satisfactory KYC/AML and risk assessment
• Acceptance by BlockRiver AG at our sole discretion

United States

BlockRiver AG is NOT:

• Registered with the US Securities and Exchange Commission (SEC)
• Registered with the US Commodity Futures Trading Commission (CFTC)
• Registered with FinCEN as a Money Services Business (MSB)
• Licensed in any US state for money transmission or virtual currency activities
• Registered as a broker-dealer, investment adviser, or other regulated entity

No US Clients: BlockRiver AG does NOT provide services to:

• US persons (as defined under US securities laws)
• Entities incorporated in the United States
• Entities primarily conducting business in the United States
• US citizens or residents, regardless of location

Other Jurisdictions

BlockRiver AG does not hold authorizations, licenses, or registrations in jurisdictions outside of Switzerland unless specifically disclosed.

Provision of services to clients in other jurisdictions is conducted:

• On a reverse solicitation basis only
• Subject to the client's responsibility to ensure local law compliance
• At BlockRiver AG's sole discretion based on risk assessment
• Without any representation regarding legality or regulatory compliance in the client's jurisdiction

Compliance Program

BlockRiver AG maintains a comprehensive compliance program overseen by our designated Compliance Officer and subject to VQF supervision.

Key Components:

• Written policies and procedures
• Risk-based approach to client acceptance
• Ongoing compliance monitoring
• Regular independent audits
• Management oversight and governance
• Employee training and awareness
• Incident reporting and remediation

Annual Audit: BlockRiver AG undergoes an annual compliance audit by an external audit firm approved by VQF.

Audit Scope:

• Compliance with Swiss AMLA requirements
• AML/KYC policies and procedures
• Transaction monitoring and reporting
• Internal controls and governance
• Staff training and competence
• Record keeping

Audit Reports: Audit reports are submitted to VQF for review. Summary findings may be made available to regulatory authorities upon request.

Audit Frequency: Audits are conducted annually

Updates and Changes

This regulatory information is accurate as of the "Last Updated" date shown above. Regulatory frameworks, authorizations, and memberships may change over time.

For current information or specific regulatory inquiries, please contact: Compliance Department: compliance@blockriver.com

Verification

Clients and counterparties may verify BlockRiver AG's regulatory status through:

• Swiss Commercial Register: www.zefix.ch (search by name or registration number)
• VQF Member List: Contact VQF directly to confirm membership status
• FINMA Public Register: www.finma.ch (confirms VQF is a recognised SRO; individual members are not listed)

This information is provided for transparency and informational purposes only. It does not constitute legal, regulatory, or compliance advice. Clients should obtain their own professional advice regarding regulatory matters.

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