Terms of Use

1. About These Terms

1.1These Terms of Use (the "Terms") govern your access to and use of the website at marblebank.app, its subdomains and any online banking platform or mobile application that the Bank makes available (together, the "Website"). They also describe the general framework within which the Bank offers its services.

1.2In these Terms, "the Bank", "we", "us" and "our" mean Marble Bank Ltd. "You" and "your" mean any person who accesses or uses the Website, whether as a visitor, an applicant for services or a Client. "Client" means a person with whom the Bank has entered into a Client Agreement.

1.3Please read these Terms carefully. They contain important information about eligibility, risks, fees, our liability to you and the law that applies.

2. Who We Are

2.1Marble Bank Ltd is a private company limited by shares incorporated on 31/07/2026 under the Companies Act No. 21 of 1994 of the Commonwealth of Dominica, with Company No. 2026/C0112. Its registered office is at 3 Kings Lane, St. George, Roseau, Commonwealth of Dominica.

2.2The Bank holds an Offshore Banking License granted by the Minister for Finance under Section 5 of the Offshore Banking Act, Chapter 73:02, issued on 07/09/2026. The licence is renewable annually.

2.3The Bank is supervised by the Financial Services Unit, Ministry of Finance, Commonwealth of Dominica (the "FSU"). The FSU's contact details are: Financial Services Unit, Ministry of Finance, 5th Floor, Financial Centre, Kennedy Avenue, Roseau, Commonwealth of Dominica; tel. +1 767 266 3514; fsu@dominica.gov.dm; www.fsu.gov.dm.

2.4The Bank is also registered as a virtual asset business under the Virtual Asset Business Act, 2022 and supervised by the FSU.

2.5The Bank's management, operations, compliance and technology functions are supported by a group service company (the "Group Service Company") under an intra-group services agreement. The Bank has no branches or subsidiaries. The Bank remains responsible for all services it provides to you.

3. Acceptance of These Terms

3.1By accessing or using the Website you confirm that you have read, understood and agree to these Terms. If you do not agree, you must not use the Website.

3.2These Terms apply together with our Privacy Policy, our Cookie Policy and our Legal Notice, each published on the Website. If you become a Client, the documents described in section "Account Relationships and Governing Documents" below also apply.

4. Eligibility and Availability of Services

The Bank provides services only to eligible persons on a non-resident basis. In particular:

a)the Bank does not offer its services to citizens or residents of the Commonwealth of Dominica, or to companies or other entities resident in the Commonwealth of Dominica;

b)US persons, including US citizens, US tax residents, holders of a US permanent resident card and entities incorporated or organised in the United States, may apply, subject to enhanced checks, including verification of their US tax status (for example an IRS Form W-9), and to certain services, including discretionary wealth management and any securities-related services, not being available to them;

c)the Bank does not offer its services in any country or territory where doing so would be unlawful, or to any person who is subject to sanctions or who is resident in, or connected with, a jurisdiction that the Bank does not accept under its internal country risk criteria; in particular, the Bank does not accept persons resident in Russia or Belarus;

d)the Bank does not provide services to individuals under the age of 18.

4.1The Bank does not actively market, promote or solicit its services in the European Union or the European Economic Area (the "EU/EEA"). The Bank accepts persons resident or established in the EU/EEA as Clients only where they approach the Bank on their own exclusive initiative. Nothing on the Website is intended as marketing or solicitation directed at persons in the EU/EEA.

The Bank is not authorised or regulated by the Financial Conduct Authority or the Prudential Regulation Authority, and does not actively market, promote or solicit its services in the United Kingdom (the “UK”). The Bank accepts persons resident or established in the UK as Clients only where they approach the Bank on their own exclusive initiative. Nothing on the Website is intended as a financial promotion, an invitation or an inducement to engage in investment activity, or as marketing or solicitation directed at persons in the UK, within the meaning of section 21 of the Financial Services and Markets Act 2000.

4.2The Website is accessible worldwide, but its availability does not mean that our services are available in your country. It is your responsibility to ensure that your access to the Website, and any application for services, is lawful where you are.

4.3The Bank introduces its products and services in phases. Any description of a product or service on the Website does not mean that it is currently available to you. Each product or service is subject to successful onboarding, your eligibility, the Bank's internal approval and any regulatory approvals that apply.

Virtual asset services. The Bank is registered as a virtual asset business under the Virtual Asset Business Act, 2022 and supervised by the FSU. Services relating to virtual assets, including conversion, transfer and custody of virtual assets, are provided by the Bank under that registration. Virtual asset custody uses specialist technology providers engaged by the Bank, and the Bank remains responsible to you for it. Each virtual asset service is introduced in phases, and any description of a service that is not yet available to you is for information only.

5. No Offer and No Advice

5.1The content of the Website is provided for general information only. It does not constitute an offer, invitation or solicitation to buy or sell any product, to open an account or to enter into any transaction, and it must not be relied on as such.

5.2Nothing on the Website is investment, legal, tax, accounting or other professional advice, or a recommendation that any product or service is suitable for you. You should obtain independent professional advice before making any financial decision.

5.3Where the Bank provides discretionary wealth management or any other advisory-related service, it does so only under a separate written agreement after assessing the suitability of the service for the Client.

5.4Information on the Website may be changed at any time without notice. While we take reasonable care to keep it accurate, we do not guarantee that it is complete, accurate or up to date.

6. Account Relationships and Governing Documents

If the Bank accepts you as a Client, your relationship with the Bank is governed by:

• the Client Agreement in the form of Terms Addendum (the Bank's general terms and conditions for Clients);
• the specific terms for each product or service you use (the "Product Terms");
• your individual Pricing Schedule; and
• any other document that the Bank and you agree in writing.

6.1If there is any conflict between these Terms and the Client Agreement, Product Terms or Pricing Schedule, the Client Agreement, Product Terms or Pricing Schedule (as relevant) prevail in respect of the services concerned.

6.2Services are provided only after you have accepted the relevant Client Agreement and Product Terms and agreed your Pricing Schedule.

7. Fees, Charges and Pricing

7.1The Bank does not publish a general tariff or list of fees.

7.2All fees, charges, interest rates, foreign exchange margins and transaction or account limits are offered privately by Marble Bank Ltd to each Client. They are determined on an individual basis by reference to the Client's risk profile, the services requested, expected volumes and the commercial terms agreed.

7.3The applicable fees, charges, interest rates, foreign exchange margins and limits are set out in an individual Pricing Schedule, which is agreed with you before the relevant service is provided. The Bank does not charge any fee that is not set out in your Pricing Schedule, the Client Agreement or the Product Terms.

7.4The Bank may decline to provide pricing information to any person who is not a Client or an applicant at an appropriate stage of onboarding.

7.5The Bank may change your Pricing Schedule only in accordance with the Client Agreement, including any notice period it sets out. Third parties, such as correspondent banks, payment networks or blockchain networks, may charge their own fees, which are outside the Bank's control.

8. Onboarding and Due Diligence

8.1The Bank is subject to anti-money laundering, counter-terrorist financing, counter-proliferation financing and sanctions laws. Before accepting you as a Client, and throughout the relationship, the Bank must identify and verify you and, where relevant, your company, its directors, its beneficial owners and other connected persons.

During onboarding and afterwards, the Bank may ask you to provide, among other things:

• identity documents and a live facial image or video for identity verification and liveness checks;
• proof of address;
• corporate documents, ownership structure and beneficial ownership information;
• information on the source of funds and source of wealth;
• information on the nature and purpose of the relationship and expected activity; and
• information about virtual asset wallets you use.

8.2You must provide complete, accurate and up-to-date information and documents, and inform the Bank promptly of any change. The Bank may suspend or end services if you do not.

8.3The Bank uses outsourced service providers, including an identity verification and screening provider, to support these checks. The Bank remains responsible for all due diligence decisions.

8.4The Bank may refuse any application, decline any instruction or limit any service at its discretion and without giving reasons, including where the law prevents the Bank from explaining its decision. The Bank does not open anonymous accounts or accounts in fictitious names.

9. Security and Your Obligations

When using the Website, you must:

a)use it only for lawful purposes and in accordance with these Terms;

b)keep your login details, passwords, one-time codes, devices and any authentication tools secure and confidential, and not share them with anyone;

c)notify the Bank immediately at hello@marblebank.app, or through any secure channel set out in the Client Agreement, if you suspect any unauthorised access to your account or loss of your security credentials;

d)use up-to-date software, operating systems and security protections on any device you use to access the Website;

e)check the details of each instruction, including beneficiary details and virtual asset wallet addresses, before you confirm it.

You must not:

a)attempt to gain unauthorised access to the Website, its servers or any connected systems;

b)introduce viruses, malware or other harmful material;

c)use automated tools to scrape, copy or monitor the Website without the Bank's written consent;

d)interfere with the operation or security of the Website or other users' use of it;

e)use the Website to commit, facilitate or conceal fraud, money laundering, terrorist financing, sanctions evasion or any other financial crime.

9.1The Bank will never ask you to disclose your full password or one-time codes by email, telephone or messaging service. Treat any such request as fraudulent and report it to the Bank.

9.2The Bank may suspend or restrict access to the Website, or to any account, where it reasonably considers this necessary for security reasons, to prevent fraud or financial crime, or to comply with the law.

10. Virtual Asset Risk Warnings

Virtual assets involve significant risk and are not suitable for everyone. When the Bank provides virtual asset services to you, you should be aware of the following risks:

• Volatility: the value of virtual assets can rise or fall sharply and rapidly, including within very short periods.
• Loss: you may lose some or all of the value of your virtual assets. Past performance is not a guide to future results.
• Irreversible transfers: transfers on a blockchain generally cannot be reversed or cancelled once confirmed. A transfer sent to a wrong or incompatible address may be lost permanently.
• Regulatory change: laws and regulations on virtual assets are developing and may change in any jurisdiction. Such changes may affect the availability, value, tax treatment or transferability of virtual assets and may require the Bank to restrict or stop services.
• Stablecoin issuer risk: a stablecoin depends on its issuer and the reserves backing it. A stablecoin may lose its peg or become illiquid or worthless if the issuer fails, its reserves are insufficient or it is subject to regulatory action.
• Technology and network risk: blockchain networks may suffer delays, congestion, forks, protocol changes, cyber-attacks or failures that affect your virtual assets.
• Liquidity risk: it may not always be possible to sell or convert a virtual asset quickly or at the expected price.
• Third-party risk: the Bank uses specialist custody and wallet technology providers and liquidity counterparties, whose failure or disruption could affect the availability of your virtual assets or services.

10.1Virtual assets are not legal tender in the Commonwealth of Dominica and are not backed by any government or central bank. Further risk information is given in the relevant Product Terms.

11. How Your Money and Assets Are Held

11.1Balances on current accounts and call and term deposits are deposits. A deposit is a claim against the Bank. If the Bank became insolvent, deposits might not be repaid in full or at all.

11.2Where the Bank holds assets for you in custody, including virtual assets, they are kept separate from the Bank's own assets in its records and are recorded as belonging to you. This is intended to allow them to be identified and returned to you. However, the outcome in an insolvency depends on the applicable law, the terms of your Client Agreement, the accuracy of records and the position of any technology provider, sub-custodian or payment provider used by the Bank, and the Bank cannot guarantee that assets will be returned in full or without delay.

11.3The Bank never uses assets it holds for you in custody, including collateral, by default. It does not lend, pledge, stake or otherwise use them for its own account or for another client unless you have given your express prior written consent for a specific product that provides for this use.

11.4The Bank does not describe any funds or assets held with it as insured, guaranteed or risk-free. Further details are given in the Client Agreement and the Product Terms.

12. No Deposit Insurance or Compensation Scheme

No deposit insurance. There is no deposit insurance, banking ombudsman or compensation scheme for financial services in the Commonwealth of Dominica.

12.1Accordingly, funds and assets held with the Bank are not protected by any deposit guarantee or investor compensation scheme in the Commonwealth of Dominica, in the EU/EEA or in any other jurisdiction. Virtual assets are not deposits and are not covered by any such scheme anywhere.

13. Intellectual Property

13.1The Website and all its content, including text, graphics, logos, the "Marble Bank" name, software, design and layout, are owned by or licensed to the Bank and are protected by intellectual property laws.

13.2You may view and print content from the Website for your own personal, non-commercial use. You must not copy, reproduce, modify, distribute, publish or otherwise use any content for any other purpose without the Bank's prior written consent.

14. Links to Other Websites

14.1The Website may contain links to websites operated by third parties, including regulators and service providers. These links are provided for convenience only. The Bank does not control and is not responsible for the content, security or privacy practices of those websites, and a link does not mean that the Bank endorses them.

14.2You must not create a link to the Website, or frame any part of it, without the Bank's prior written consent.

15. Availability of the Website

15.1The Bank aims to keep the Website available, but does not guarantee that it will be available at all times or free from errors, interruptions or delays. The Bank may suspend, withdraw or change all or part of the Website, including for maintenance, upgrades or security reasons, without notice.

15.2The Bank does not guarantee that the Website is free from viruses or other harmful components. You are responsible for protecting your own devices and data.

15.3Where the Website is unavailable, Clients may contact the Bank through the channels set out in the Client Agreement.

16. Limitation of Liability

16.1To the extent permitted by law, the Bank is not liable for any loss or damage arising from your use of, or inability to use, the Website, or from reliance on any content on the Website.

16.2To the extent permitted by law, the Bank is not liable for any indirect, consequential or special loss, or for any loss of profit, revenue, business, opportunity, goodwill or data, however caused.

The Bank is not liable for any loss caused by:

a)your failure to keep your security credentials or devices secure;

b)incorrect or incomplete instructions you give, including incorrect wallet addresses or beneficiary details;

c)the acts or omissions of third parties outside the Bank's reasonable control, including blockchain networks, correspondent banks and payment systems;

d)events beyond the Bank's reasonable control, including natural disasters, power or telecommunications failures, cyber-attacks, war, civil unrest or actions of governments or regulators;

e)any action the Bank takes to comply with the law, including anti-money laundering and sanctions requirements.

16.3Nothing in these Terms excludes or limits liability for fraud, for death or personal injury caused by negligence, or for any other liability that cannot be excluded or limited by law. The Bank's liability for services provided to Clients is governed by the Client Agreement and the Product Terms.

17. Privacy and Cookies

17.1The Bank processes personal data in accordance with its Privacy Policy, which explains what personal data we collect, why we use it, who we share it with and your rights.

17.2The Website uses strictly necessary cookies and, only with your consent, Google Analytics cookies, as described in our Cookie Policy. You can accept or reject analytics cookies and change your choice at any time through "Cookie settings" in the footer.

18. Communications and Language

18.1The Bank communicates in English. These Terms, the Client Agreement, the Product Terms and other contractual documents are provided in English.

18.2If the Bank provides a translation of any document, it is for convenience only. If there is any conflict or inconsistency between the English version and a translation, the English version prevails.

18.3The Bank may communicate with you by email, through the Website or by any other method agreed in the Client Agreement. Be aware that email is not a secure form of communication. Do not send passwords or other security credentials by email.

19. Governing Law and Jurisdiction

19.1These Terms, and any non-contractual obligations arising out of or in connection with them, are governed by the laws of the Commonwealth of Dominica.

19.2The courts of the Commonwealth of Dominica have jurisdiction to settle any dispute arising out of or in connection with these Terms. This does not prevent the Bank from bringing proceedings to enforce its rights in any other court of competent jurisdiction, and the jurisdiction of the courts of the Commonwealth of Dominica is non-exclusive for that purpose.

19.3Nothing in this section deprives you of the protection of any mandatory provision of law that applies to you and cannot be excluded by agreement.

20. Complaints

20.1If you are not satisfied with any aspect of the Website or the Bank's services, please contact us by email at complaints@marblebank.app, through the messaging function in the Bank's application or by post to our registered office. Complaints are handled free of charge, fairly and independently of the team you are complaining about.

We aim to handle your complaint within the following timeframes, counted in business days (Monday to Friday, excluding public holidays in the Commonwealth of Dominica):

• we will acknowledge your complaint in writing within 2 business days of receiving it;
• we will send you our final response in writing within 15 business days of receiving your complaint;
• if your complaint is complex and we need more time, we will write to you within those 15 business days to explain why and when you can expect our final response, which we will send within 35 business days of receiving your complaint.

20.2If you are not satisfied with our final response, you may ask for it to be reviewed by the Bank's Sole Director or, where the Sole Director was involved in the matter, by another senior person who was not involved. You may also pursue the remedies available under the law governing your agreement with the Bank, including before the courts, and you may inform the FSU, as the Bank's supervisor, of your concerns. You may do so without waiting for our final response if we have not sent it within these timeframes.

20.3This section is the summary of our complaints handling process, and further information is available on request. We accept complaints in English and, where practicable, in other languages; where a complaint or our response is in another language, the English version prevails. There is no banking ombudsman in the Commonwealth of Dominica to which complaints can be referred.

21. Changes to These Terms

21.1The Bank may change these Terms at any time, for example to reflect changes in law, regulation, our services or the Website. The updated Terms will be published on the Website with the date of the latest update.

21.2Your continued use of the Website after changes are published means that you accept the updated Terms. Changes to the Client Agreement, Product Terms or your Pricing Schedule are made only in accordance with the Client Agreement.

22. General

22.1If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions continue in full force.

22.2If the Bank does not enforce any right under these Terms, or delays doing so, this does not mean that the Bank has waived that right.

22.3You may not transfer your rights or obligations under these Terms. The Bank may transfer its rights and obligations to another entity where permitted by law.

23. Contact Us

For general enquiries, please contact:

• Email: hello@marblebank.app
• Complaints: complaints@marblebank.app
• Data protection: privacy@marblebank.app
• Post: Marble Bank Ltd, 3 Kings Lane, St. George, Roseau, Commonwealth of Dominica

23.1Last updated: 07/09/2026