BLOCKDEV AD / YUGO

RISK DISCLOSURE FOR CUSTODY AND ADMINISTRATION OF CRYPTO-ASSETS

Client Custody Risk Disclosure

28.05.2026

1. Purpose of the Document

This disclosure is intended to inform the clients of BlockDev AD, operating under the Yugo trademark, of the principal risks associated with the custody and administration of crypto-assets on behalf of clients. This document has been prepared as a client risk disclosure and supplements the General Terms and Conditions / Standard Custody and Wallet Terms, the Custody and Administration Policy, and the applicable internal procedures of the Company.

The Client should read this document carefully before using the custody service. The use of crypto-assets involves significant technological, market, legal, operational, and cyber risks.

2. Scope of the Service and Exclusions

Yugo may provide custody and administration only in respect of supported crypto-assets and networks included in BlockDev AD’s Crypto-Asset Acceptance Policy and/or in the Register of Supported Crypto-Assets and Blockchain Networks. Support for a particular asset or network may be temporarily suspended, restricted, or discontinued on technical, regulatory, AML/CFT, sanctions, liquidity, or operational grounds.

Express exclusion: Yugo will not provide custody, administration, transfer services, or ancillary custody services in relation to USDC or other electronic money tokens (EMTs). USDC/EMTs are outside the scope of this service, this disclosure, and the related custody procedures.

3. Role of Yugo and the External Custody Infrastructure Provider

BlockDev AD is the service provider to the Client. For the technical custody infrastructure, an external provider may be used, including BitGo Europe GmbH, which provides wallet infrastructure, key storage/control, and technical execution of validated instructions in accordance with the agreed terms and applicable law.

Yugo remains responsible for the client relationship, client onboarding, AML/CFT and sanctions checks, maintenance of internal records, control over instructions, reconciliation of positions, client notifications, complaints handling, and oversight of the external provider.

Yugo remains the service provider to the Client and is responsible for the organisation of the service, client relationships, records, control over instructions, AML/CFT and sanctions checks, client notifications, complaints, and oversight of the external provider.

3A. Segregation of Client Crypto-Assets

Yugo applies measures to segregate client crypto-assets from the Company’s own crypto-assets. Client crypto-assets are not used for Yugo’s own account, are not staked, are not provided as collateral, and are not used to finance the Company’s activities.

Where omnibus or pooled wallet structures are used, Yugo maintains an internal register of client positions that enables the crypto-assets associated with each respective client to be identified at any time.

4. Main Risks for the Client

Risk and Description

4.1 Market risk: The value of crypto-assets may change significantly and rapidly. The Client may incur losses due to a decrease in the price of the assets.

4.2 Technological risk: Distributed ledger technology (DLT) networks, wallets, smart contracts, node infrastructure, or providers may be affected by technical errors, delays, outages, or vulnerabilities.

4.3 Cyber risk: There is a risk of unauthorised access, phishing, compromised devices, malware, attacks against providers, or social engineering.

4.4 Operational risk: An incorrectly entered address, incorrect network, incomplete transaction identifier/tag, inconsistency in instructions, or human error may result in delay or loss.

4.5 Blockchain transaction finality risk: After broadcasting and confirmation, transactions on most blockchain networks are irreversible.

4.6 Liquidity/settlement risk: During high volatility, network congestion, or limited liquidity, there may be delays, price recalculation, temporary suspension, or restriction of a service.

4.7 Regulatory risk: Legislative or supervisory changes may lead to the restriction, suspension, or modification of supported assets, networks, or services.

4.8 Sanctions and AML/CFT risk: Yugo may delay, refuse, block, or report a transaction where there are sanctions, AML/CFT, fraud, or other compliance risk.

4.9 Third-party risk: External providers, including custody infrastructure providers, cloud services, transaction verification (KYT), client identification (KYC), or monitoring providers, may experience an incident, service interruption, or deterioration in service quality.

5. Risk of Irreversible and Erroneous Transactions

The Client is responsible for providing accurate and complete information regarding addresses, networks, transaction identifiers/tags/references, and any other data necessary for the execution of transactions. Sending an asset to an incorrect address, incorrect network, or unsupported smart contract may result in permanent loss.

  • Yugo does not guarantee the recovery of assets sent to an incorrect or unsupported address/network.
  • Yugo may attempt recovery only where this is technically, legally, and operationally possible, without any guarantee of success.
  • Recovery may take time and may be subject to additional costs where permitted under the applicable terms.

Yugo remains the service provider to the Client and is responsible for the organisation of the service, client relationships, records, control over instructions, AML/CFT and sanctions checks, client notifications, complaints, and oversight of the external provider.

6. Risk of Unsupported Assets and Networks

Yugo supports only the assets and networks included in the current Register of Supported Crypto-Assets and Blockchain Networks. The Client must not send unsupported assets or assets through an unsupported network.

In the event of an unsupported deposit, Yugo may be unable to credit, return, or recover the asset. If recovery is possible, it will be performed only after a technical, compliance, and risk assessment.

7. Risk Relating to Temporary Suspension, Blocking, or Refusal of Transactions

Yugo may refuse, delay, or temporarily suspend a deposit, withdrawal, transfer, or other operation where this is necessary to protect the Client, the Company, the market, or to comply with the law. Grounds may include:

  • sanctions risk or a match with sanctions lists;
  • exposure to a high-risk wallet, mixer, darknet, fraud, scam, or ransomware;
  • incomplete or inconsistent information concerning the Client, the recipient, or the transaction;
  • suspicion of money laundering, terrorist financing, or fraud;
  • a technical issue, blockchain network congestion, or incident at an external provider;
  • a requirement imposed by a competent authority or applicable law.

8. Risk Relating to Forks, Airdrops, and Network Events

Crypto-assets may be affected by protocol forks, token airdrops, token migrations, network upgrades, chain splits, or other events. Yugo does not guarantee that it will support all such events, credit new assets, or participate in governance/staking/asset-receipt processes.

Support for a given event will depend on technical feasibility, security, legal and regulatory analysis, AML/CFT risk, and a decision by the competent functions of Yugo.

9. Risk Relating to External Providers

Yugo may use external providers for custody infrastructure, blockchain monitoring, client identification/transaction verification (KYC/KYT), transaction monitoring, cloud hosting, information system development, and other functions. Although Yugo performs due diligence and ongoing oversight, third-party services may be affected by outages, cyber incidents, technical limitations, changes in terms, regulatory restrictions, or contract termination.

In the event of an incident or interruption at an external provider, Yugo will apply its procedures for business continuity, incident management, communication, and orderly wind-down where necessary.

9A. Risk Relating to Custody Infrastructure

The Client understands that the technical custody infrastructure may be provided through an external provider, including BitGo Europe GmbH. Although Yugo performs due diligence and ongoing oversight of the external provider, technical incidents, interruptions, cyber risks, operational outages, or regulatory restrictions at the external provider may temporarily affect access, transfers, or the processing of client crypto-assets.

10. Segregation, Records, and Reconciliation

Yugo applies measures to segregate client crypto-assets from the Company’s own assets. Where pooled wallets are used, Yugo maintains an internal register for allocating positions by client. Yugo performs reconciliation between the internal records, the data from the custody infrastructure, and/or the blockchain data.

Despite these measures, temporary discrepancies may arise and require verification, escalation, and corrective action. In the event of a material discrepancy, Yugo may temporarily restrict operations until the facts are clarified.

USDC, EURC, and other electronic money tokens (EMTs) are outside the scope of Yugo’s custody and administration service. Clients should not use the custody service for the storage or transfer of EMTs.

10A. Register of Client Positions and Client Statements

Yugo maintains an internal register of client positions, including at least:

  • type of crypto-asset;
  • quantity;
  • relevant network;
  • movements in the position;
  • pending or blocked operations;
  • transaction hash/identifiers;
  • fees charged;
  • reconciliation data.

Clients receive information or a statement of their positions at least once per quarter and, upon request, to the extent applicable and technically possible.

11. Client Statements and Information

Yugo provides the Client with information on the Client’s positions in supported crypto-assets, including the asset, balance, value/valuation, where available, and movements for the relevant period.

Valuations may be indicative and may be based on external sources of market data; they do not constitute investment advice or a guaranteed price.

11A. Indicative Nature of Valuations

Valuations of crypto-assets are indicative, may be based on external sources of market data, and do not constitute a guaranteed price, investment advice, or an offer to buy/sell.

12. Liability and Limitations

Yugo is liable in accordance with applicable law, the agreement with the Client, and its internal policies. In certain cases, losses may be caused by circumstances beyond Yugo’s control, including failures of the blockchain network, actions of third parties, actions or errors of the Client, force majeure, sanctions or regulatory measures, or technical limitations of the network.

The Client should understand that crypto-assets are not bank deposits and are generally not covered by a deposit guarantee scheme or an investor compensation scheme, unless applicable law expressly provides otherwise.

Crypto-assets do not constitute a bank deposit, payment account, or electronic money and are generally not protected by a deposit guarantee scheme or an investor compensation scheme, unless applicable law expressly provides otherwise.

12A. Limitations of Liability

Yugo is not liable for:

  • market volatility;
  • loss of value of a crypto-asset;
  • unsupported networks or assets;
  • forks, airdrops, or network events not supported by Yugo;
  • acts or omissions of the Client;
  • incorrect address, incorrect network, or incorrect client instruction;
  • events beyond Yugo’s reasonable control, including issues in DLT networks, cyberattacks against third parties, interruptions of external providers, sanctions measures, or actions of competent authorities.

Where applicable law permits a limitation of liability, any liability of Yugo in connection with the loss of crypto-assets or means of access caused by an incident for which Yugo is responsible may be limited to the market value of the affected asset at the time of the relevant incident.

13. Client Obligations

To reduce risk, the Client should:

  • maintain up-to-date and accurate information in the Client’s profile;
  • not provide access to the Client’s account to third parties;
  • use strong passwords, two-factor authentication (MFA), and secure devices;
  • carefully verify the address, network, identifier/tag, and asset before a transaction;
  • not send unsupported assets or assets through unsupported networks;
  • immediately report suspicious activity, compromised credentials, or unauthorised access;
  • provide information and documents during AML/CFT, sanctions or fraud checks.

13A. Return of Client Crypto-Assets and Termination

Upon termination of the relationship, Yugo will take reasonable steps to return or transfer eligible client crypto-assets to an address specified by the Client, provided that the applicable AML/CFT, sanctions, technical, and contractual requirements have been satisfied.

In certain cases, Yugo may require additional identification, address confirmation, additional documentation, or completion of compliance checks before the return is performed.

14. Complaints and Contact

The Client may submit a complaint or enquiry through the channels specified in the General Terms and Conditions, on the website, or in the client interface. Complaints are handled in accordance with Yugo’s Complaints Handling Policy. Filing a complaint is free of charge.

15. Client Acknowledgement

By using the custody service, the Client confirms that the Client has received, read, and understood this disclosure, as well as the applicable General Terms and Conditions / Standard Custody and Wallet Terms.

Topic and Acknowledgement

15.1 Acknowledgement: The Client understands that crypto-assets are high-risk and may lose value.

15.2 EMT exclusion: The Client understands that USDC and other EMTs are outside the scope of Yugo’s custody/transfer service.

15.3 Irreversibility: The Client understands that transactions on blockchain networks may be irreversible.

15.4 Unsupported assets: The Client understands that unsupported assets/networks may result in unrecoverable loss.

16. Review and Update of the Disclosure

This disclosure is reviewed at least annually and upon any material change in the service, supported assets/networks, providers, risk profile or applicable regulatory framework. The current version is provided to clients through an appropriate channel.

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