Terms of Service for Januar ApS

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CVR-no.: 38891294
Effective as of April 13th 2025

GENERAL TERMS

These terms of service (hereinafter referred to as “Terms”) shall constitute a binding agreement between the Customer and JANUAR ApS, a company incorporated in Denmark, registered at Gothersgade 14, 4. sal, 1123 Copenhagen K, Denmark, with company registration number (CVR): 38 89 12 94 (hereinafter referred to as “JANUAR” ) and the Customer, being any legal person or entity either accessing an account via JANUAR.com including any subdomain of this website, via API or having signed an Order Form with JANUAR (hereinafter referred to as “Customer” ). 

The Customer and JANUAR shall collectively be referred to as “Parties” and individually as “Party”. 

1. DEFINITIONS 

• Accounts: Any account, wallet, custody arrangement, or other account-based relationship provided by JANUAR to the Customer under these Terms, the specific characteristics, functionality, and conditions of which are described in the applicable service-specific appendix or appendices. Accounts may include, depending on the Services selected by the Customer, a Payment Account for fiat funds, a Crypto Account for Crypto Assets, or other account-based arrangements as described in the relevant Appendices.
• Currency(/ies): fiat currencies as per JANUAR offer. 
• Customer: any entity that uses, accesses, or subscribes to the Service, whether directly or through authorized representatives. 
• Funds: fiat currencies held in a Payment Account within JANUAR. 
• Group Companies: any entity that directly or indirectly controls, is controlled by, or is under common control with JANUAR.
• IP: all intellectual property rights, including, without limitation, copyrights, trademarks, service marks, trade names, trade dress, logos, domain names, patents, know-how, database rights, and any other intellectual property rights, whether registered or unregistered, as well as all related applications, renewals, and extensions, that are owned by or licensed to JANUAR, the Customer, or any third party, and that may be used in connection with the Service. 
• KYC: Know Your Customer documentation includes but is not limited to the following: ID, proof of address, etc,.
• Nested Flow: when the Customer allows another business or third party to use its payment account to send or receive funds as if the account were their own. This practice is not permitted, as it conceals the true identity of the payment beneficiary and disrupts the transparency required for proper transaction monitoring and anti-money laundering (AML) controls. 
• Order Form: any document, form, or online submission process that outlines the specific terms of the Customer’s engagement with JANUAR’s Service, including, but not limited to, pricing, product or service details, subscription periods, payment terms, and any applicable volume or usage limitations, which, upon acceptance by both the Customer and JANUAR, becomes incorporated into and governed by the terms and conditions of these Terms. 
• Payment Account: an account provided by JANUAR that is exclusively designed for the temporary-storage and management of fiat Currencies as per JANUAR offer. This account enables the Customer to perform transactions and payments using traditional fiat money. 
• Payment Institution: means a legal entity that has been granted authorisation under the applicable regulatory framework (in accordance with Article 11 of PSD2) to provide and execute payment services throughout the European Union. Such an institution is permitted to engage in activities set out as payment services and is subject to supervision, registration, and compliance obligations, ensuring the safe and efficient provision of payment-related functionalities to its users. 
• Platform: the online interface, or Web App, through which the Customer can access and use JANUAR’s Services. This includes both the user-facing components and underlying infrastructure that support account management, transactions, data retrieval, and any other functionalities made available by JANUAR. 
• Price list: document outlining the charges, fees, and costs associated with the various services offered by JANUAR, specifying the pricing structure for different transactions. The Price list can be found on our website and is shared with the Customer as part of the onboarding process. 
• Service: meaning the total services provided by the company, as outlined in Section 3 of these Terms.
• Terms: refers to these terms of service, including all policies, documents, appendices, price lists, additional terms, and any modifications, amendments, or updates made from time to time, which collectively form a binding agreement between the Customer and JANUAR governing the Customer’s use of and access to the Service. 
• Transactions: refer to a wide range of financial activities and exchanges involving the transfer, exchange, or movement of Funds or Crypto Assets, such as payments, transfers, conversions, purchases, sales, or any other financial interactions that involve the exchange of value between parties. Transactions may occur within various financial systems, such as traditional fiat-based systems or blockchain-based networks, and can involve a diverse set of assets and instruments, each subject to its unique terms and conditions. 
• User or Users: person authorised by the Customer to access and use the Platform, including employees, directors, officers, or other representatives of the Customer. 

2. RECITALS 

2.1. JANUAR is a Danish Payment Institution, authorised and supervised by the Danish Financial Supervisory Authority (Finanstilsynet). JANUAR is also authorised as a crypto-asset service provider (CASP) pursuant to Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), in respect of the crypto-asset services it provides, and is subject to supervision by the relevant competent authority in accordance with MiCA. The Customer may at any time contact JANUAR via email to support@januar.com. 

2.2. The Customer wishes to open an account provided by JANUAR (the “Payment Account”) . Customers can access their accounts through our secure web interface. Access requires multi-factor authentication, including passwords and time-based one-time passwords (2FA). 

2.3. The Customer wishes to send, transfer, convert and perform payments (the “Service”) through the Payment Account or Crypto Account and authorises JANUAR, as a regulated service provider, to execute or arrange the execution of such transactions on the Customer’s behalf, including through third-party financial institutions, liquidity providers, or infrastructure partners, in accordance with these Terms.

2.4. By signing up to use an account through JANUAR or signing an Order Form, the Customer agrees that they have read, understood, and accepted all the terms of service contained in the Terms. 

2.5. At any time during the contractual relationship, the Customer can download the Terms on request on the JANUAR website. 

2.6. These Terms are concluded in English. JANUAR reserves the right to answer requests in English. 

2.7. These Terms may be amended at some point in time. The Customer will be notified. If those amendments are unfavourable to the Customer, JANUAR will provide the Customer with a 2 (two) months notice, unless dictated otherwise by law or a Supervisory Authority. The amendments shall be deemed accepted by the Customer at the end of the notice period. Changes in the exchange rate may take effect immediately when the changes are based on the reference exchange rate. Should the Customer notify JANUAR of its inability to accept the amendments, these Terms may be terminated by the Customer according to 11.6. 

2.8. Relevant communications and changes will be communicated by JANUAR to the Customer as soon as possible via email. Minor communications, such as unplanned temporary unavailability of a service or feature, or launch of a new feature may be communicated via notification banner on the JANUAR Platform. 

2.9. These Terms remain in effect indefinitely until either Party initiates Termination as outlined in Section 11. 

2.10 JANUAR provides Services only to Customers established or operating within the European Economic Area (EEA). Use of the Services is prohibited for persons or entities connected to sanctioned or restricted jurisdictions, including the United States of America and countries listed on EU or UN sanctions lists. JANUAR may decline or terminate any relationship that would breach applicable sanctions or financial-crime laws.

2.11 JANUAR does not actively market or promote its Services outside the EEA. However, JANUAR may provide Services to Customers established outside the EEA who approach JANUAR on their own initiative. Such relationships are considered reverse solicitation and are subject to the same onboarding, compliance, and regulatory requirements as EEA customers.

3. SERVICES 

3.1. PAYMENT ACCOUNT

3.1.1 The Payment Account is the primary account offered by JANUAR. Each Payment Account is a named account, meaning it is opened in the name of the Customer. This naming structure is mandatory and not optional, ensuring transparency and compliance with applicable regulatory requirements.

3.1.2 The Payment Account enables the Customer to send and receive funds from clients and third parties in accordance with JANUAR’s Payment and Transfer Services described below. Each Customer may hold multiple virtual IBANs (VIBANs) linked to the same account structure, allowing for efficient management of incoming and outgoing Transactions.

3.1.3 The Payment Account includes an FX feature for supported currencies.

3.2 JANUAR FIAT SERVICES

3.2.1 Under the Fiat product line, JANUAR provides the following services associated with the Payment Account:

• The Payment Service allows Customers to send and receive funds from their clients. 
• The Transfer Service enables Customers to receive Transfers from third parties.
• The Multi Account Service provides the possibility for a Customer to obtain multiple VIBANs under one named Payment Account.
• The FX Feature, which is already included in the Payment Account, allows conversions between Euro (EUR) and Danish Krone (DKK).
• The Payment Approval Workflow (optional) is an optional “four-eye” approval process available to Customers who wish to implement internal payment control measures.

4. RISKS, RESPONSIBILITIES, AND LIABILITIES 

4.1. If the Customer is obligated to collect and verify identification documentation on all its clients in accordance with national anti-money laundering (AML) regulation, the Customer’s compliance program needs to be approved by JANUAR prior to the Customer’s onboarding.

4.2. The Customer must use Januar’s Products and Services in accordance with these Terms and with all applicable laws and regulations. 

4.3. The Customer must take all necessary steps and apply all necessary measures to anticipate, stop, and prevent any misuse of the Accounts and any other services that the Customer has access to. The Customer must comply with all reasonable instructions JANUAR may issue regarding how the Customer can keep their Accounts safe. JANUAR cannot be liable for any damages or losses that occur as a result of the Customer’s failure to properly secure and safeguard credentials.

4.4. The Customer is responsible for checking JANUAR’s company website periodically to review the current version of the Terms. JANUAR will also distribute an email when there have been amendments to the Terms.

4.5. The Customer must ensure that only authorised users have access and must immediately notify JANUAR of any suspected unauthorised access, misuse, or security breach. 

4.6. The Customer shall ensure that the Platform and API Service are used solely for lawful purposes and in compliance with these Terms. 

4.7. The Customer is responsible for verifying the correctness of any payment or transfer instructions, including recipient account identifiers and wallet addresses. 

4.8. The Customer must implement and maintain appropriate technical and organisational measures to protect its own systems, hardware, and software against malware, viruses, or other security risks. 

4.9. The Customer accepts to truthfully answer all enquiries made by JANUAR, since JANUAR is a regulated entity and thus is subject to the Danish Anti-Money Laundering Act and the Danish Payment Act. Failure to deliver adequate replies or requested documentation (e.g. ID on owners,proof of address, source of funds, etc.), may at JANUAR’s sole discretion be considered breach of these Terms and allow JANUAR to terminate the Terms without further notice.

4.10. JANUAR does not provide any financial, investment, legal, or tax advice. It is the Customer’s responsibility to consult with appropriate professionals. The Customer is responsible for determining and handling any taxes related to their use of JANUAR's Products and Services . This includes assessing, paying, and withholding Taxes as required. The Customer is solely responsible for accurately reporting and remitting the correct Taxes to the relevant tax authority. JANUAR is not obligated to determine, calculate, collect, report, or remit any Taxes arising from transactions. 

4.11. By using the Services, the Customer agrees that it is their own responsibility for securing the required licences and registrations, ensuring compliance with relevant laws. JANUAR reserves the right to block payments in certain jurisdictions until the Customer presents valid compliance documents. The Customer is liable for any legal obligations and must indemnify JANUAR against claims, damages, or costs, including attorneys' fees, arising from non-compliance. This includes covering all legal expenses related to unauthorised activities connected with the use of JANUAR’s Products and Services. 

4.12. The Customer shall indemnify and hold JANUAR harmless from and against any and all losses, damages, claims, penalties, costs, and expenses (including reasonable legal fees) incurred by JANUAR arising out of or in connection with the Customer’s breach of these Terms, misuse of the Services, or failure to comply with any applicable legal, regulatory, or contractual obligation relating to its use of the Services.

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4.13. The Customer acknowledges that JANUAR’s total liability arising from or relating to the Services, whether in contract, tort, or otherwise, shall not exceed the limits stated in Sections 4.15 and 4.16. JANUAR is not liable for the acts or omissions of intermediary banks, liquidity providers, third-party networks and infrastructure providers, or other third parties involved in processing Transactions.

4.14. The Customer’s purchase of goods, services, digital content or otherwise from a third-party will at all times be subject to the third-party's terms and conditions and JANUAR shall in no way be liable for the actions or inactions of the third-party.

4.15. JANUAR will be liable for direct losses of Customer funds or loss of access to such funds resulting from incidents attributable to JANUAR, including system malfunctions or security breaches. Liability is capped at the market value of the affected assets and funds at the time of the loss, except where mandatory law provides otherwise.
Service unavailability, including during planned maintenance or emergency interruptions handled in accordance with the Service Level Agreement, does not in itself give rise to additional monetary liability. Where a recurring monthly fee is charged and account access is unavailable for more than fifteen (15) consecutive days due to technical issues attributable to JANUAR, the monthly fee will be waived in full, which constitutes the sole monetary remedy for such unavailability.
JANUAR is not liable for losses arising from events beyond its reasonable control, including blockchain-related issues outside of JANUAR’s direct influence, force majeure events, internet or third-party service failures, deliberate misuse of the system, or for any indirect or consequential losses such as missed opportunities or loss of potential income.

4.16. Subject to Section 4.15, JANUAR’s liability for direct damages shall always be limited to the refund of eventual effective losses incurred by the Customer plus the sum of the monthly account fees to be received by JANUAR under this engagement during the period of six (6) months preceding the breach of these Terms. 

4.17. JANUAR does not permit any nested flow within JANUAR Accounts. If the Customer wishes to allow their clients to accept third party payments into their JANUAR Accounts, they must direct this flow using JANUAR’s Embedded Accounts. This is because the JANUAR Embedded Accounts product includes JANUAR performing the KYC process for both the Partner Account holder and each Client-Account. By issuing individual IBANs for each verified Client-Account, JANUAR maintains a direct relationship with every underlying party, thereby eliminating the nested flow.

4.18. In the event of insolvency, all customer funds are safeguarded in accordance with regulation. JANUAR will not use customer funds in the event of a wind down of the company. JANUAR will use reasonable efforts to ensure critical systems will remain online until all customer funds and assets are returned. JANUAR will also ensure that the company can continue critical activities during the wind-down.

5. SAFEGUARDING AND ACTIVE BALANCE 

5.1. JANUAR will provide the Customer with access to a Payment Account through JANUAR’s financial partner(s).

5.2. The Payment Account allows the Customer to hold and transfer funds using their Payment Account as described above. JANUAR will combine the balance of the Customer’s Account(s) with other Customers’ balances and hold those funds in a safeguarding account at a bank or invest those funds in accordance with Danish regulation on safeguarding of Customer funds. JANUAR owns the interest or other earnings on these investments. 

5.3 The Payment Account is provided solely for the execution of payment transactions and does not constitute a deposit account. Funds may only be held for as long as necessary to execute payment transactions and in accordance with applicable law. JANUAR reserves the right to require the withdrawal or transfer of funds where an Account remains inactive or is used primarily for storage purposes.

5.4. Pooled Customer funds are held apart from JANUAR’s own funds and held in a safeguarded account in the name of JANUAR. Customers’ beneficial ownership remains unaffected by pooling. Customers’ beneficial ownership remains unaffected by pooling. JANUAR will not use Customers’ funds for its operating expenses nor for any other corporate purposes. Safeguarded funds are excluded from JANUAR’s winding-down plan.

5.5. For certain account configurations offered by JANUAR, fiat funds received in the Payment Account may, in accordance with the applicable product terms, be converted into a stablecoin on an end-of-day basis and credited to the Customer’s Crypto Account. Such conversion forms part of the agreed operational model for that specific Service.

5.6. The Customer’s Accounts contain the balance of funds available for payments. When the Customer uses the Service to pay a third party, the Customer instructs JANUAR to transfer the funds from the Customer’s Accounts to the recipient’s account, i.e. the account for the third party. The Customer needs to have enough balance to cover the amount of any payment initiated and the Transaction Fees owed to JANUAR at the time of the payment. 

6. PAYMENT ACCOUNT 

6.1. JANUAR reserves the right to restrict or suspend the execution of transactions and to block or freeze the Customer’s Accounts where required for legal, regulatory, or risk management purposes. Any notice to the Customer, where applicable, shall be handled in accordance with Section 11.3. 

6.2. The Customer authorises JANUAR to execute payment instructions submitted by authorised Users and to debit or credit the relevant Accounts accordingly, subject to these Terms and applicable law. 

6.3. Only sums credited to the Customer’s Accounts shall be treated as available for payments initiated by the Customer. JANUAR will not act on an instruction from the Customer if there are not sufficient funds on the relevant Accounts to carry out the requested Transactions. Any incoming payment shall be credited to the Customer’s relevant Accounts. 

6.4. JANUAR has the right to and will monitor the Customer’s transactions, account balance, and general use of its Accounts to ensure Customers comply with JANUAR’s Terms to detect and prevent financial crime including money laundering, terror financing and market abuse. This is done for JANUAR to be in compliance with the regulatory requirements as a Payment Institution. 

7. SUSPENSION OF THE SERVICE 

7.1. JANUAR may have to suspend the Service to deal with technical changes, to conduct Platform maintenance on a regular basis, upon order from supervisory authorities or law enforcement, or to update the Service to reflect and comply with changes in relevant laws and regulatory requirements to which JANUAR is subjected to, or has decided to comply with on its own accord. 

8. INTELLECTUAL PROPERTY 

8.1. The services and all content included in or made available through the Services, including but not limited to all copyright, trademarks, patents, service marks, domain names, trade names, rights in designs, software code, icons, logos, characters, layouts, rights in know-how, trade secrets, buttons, colour scheme, graphics and other intellectual property rights ("IP") is the property of JANUAR, its affiliates or its licensors and is protected by local and international intellectual property laws and treaties. 

8.2. Subject to these Terms, JANUAR hereby grants the Customer a limited licence to use the JANUAR Platform, solely for the purpose as stated in these Terms. 

8.3. The use of the Services does not grant the Customer any rights other than those granted to the Customer under these Terms. Nothing contained on JANUAR’s websites or any communications to the Customer shall be construed as granting, by implication or otherwise, any licence or right to use any IP without our prior written consent. 

9. PRICING AND TERMS OF PAYMENT 

9.1. The Customer shall pay the fees for the Services in accordance with JANUAR’s price list published at https://www.januar.com/pricing (the “Price List”), as updated from time to time. The Price List forms an integral part of these Terms.
This Price List excludes any intermediary bank and blockchain fees that may be incurred during payment processing. The Customer assumes responsibility for these fees and acknowledges that JANUAR is not liable for any charges imposed by other banks or blockchains as part of transactions. 

9.2. If a payment is received by the Customer but later discovered that the funds must be returned, the fees will not be reversed.

9.3. The Customer agrees to authorise JANUAR to withdraw onboarding fees and monthly fees as per the direct debit authorisation signed with the Contract. 

9.4. In case of insufficient balance to cover the fees due to JANUAR, late payments are subject to interest in accordance with the applicable Danish Interest Act (in Danish: Renteloven). The default interest rate is calculated as the official lending rate of Danmarks Nationalbank, as determined on 1 January and 1 July of each year, plus eight (8) percentage points. Any applicable interest shall accrue only from the due date of the outstanding amount and in accordance with mandatory law.

9.5. JANUAR reserves the right to amend the Price List from time to time. Any changes to the Fees or the introduction of new fees that are unfavorable to the Customer shall be governed by section 2.7 of these Terms.

10. DATA PROTECTION 

10.1. The policy applied to data protection is set out in the Privacy Policy available on the JANUAR website. 

10.2. JANUAR may be obliged to disclose Customer data to third parties such as but not limited to law enforcement, the Danish financial supervisory authority, and different auditors or Group Companies. This includes all information provided in the compliance and onboarding process, including but not limited to, name, address, and account number or IBAN to the banks involved, the operators of payment and communications systems. By using the Account and the Service, the Customer authorises JANUAR to disclose the necessary data as well as associated data of any kind to third parties and Group Companies as legally required. 

11. TERMINATION 

11.1. JANUAR may: (a) suspend, restrict, or terminate the Customer’s access to any or all of the Services, and/or (b) deactivate or cancel their Account if: (i) JANUAR is required by a facially valid subpoena, court order, or binding order of a government authority; (ii) JANUAR reasonably suspects the Customer to use its Accounts in connection with a prohibited use of business; (iii) Use of its Accounts is subject to any pending litigation, investigation, or government proceeding and/or JANUAR perceives a heightened risk of legal or regulatory non-compliance associated with the Customer’s Accounts activity; (iv) JANUAR’s service partners are unable to support the Customer’s use; (v) The Customer takes any action that JANUAR deems as circumventing JANUAR's controls, including, but not limited to, opening multiple Accounts; (vi) JANUAR reasonably believes that the Customer is in material breach of the Terms, including any material misrepresentation to JANUAR. 

11.2. JANUAR will terminate the Customer’s access to any or all of the Services, cancel the Customer’s Account(s) and offboard the Customer from the JANUAR Platform as a consequence of warnings from the side of JANUAR in case of any such activities incongruent with the Terms of Service, including but not limited to the use of the account for deposit purposes. 

11.3. Further, JANUAR reserves the discretionary right to unilaterally block, suspend and/or terminate the Customer’s use of the Services, either temporarily or permanently in the following circumstances: 

• The Customer has failed to comply with these Terms. 
• The Customer poses an unacceptable fraud and compliance risk to JANUAR, or if the Customer provides any false, incomplete, inaccurate, insufficient or misleading information in the line of business, whether this information is provided deliberately or not. The Customer also poses an unacceptable fraud and compliance risk to JANUAR, if the Customer’s transaction pattern indicates any illegal activity such as but not limited to money laundering. 
• The Customer acknowledges that JANUAR’s decision to take certain actions, including limiting access to, suspending, or closing the Customer’s account at JANUAR’s discretion, may be based on confidential criteria that are essential to JANUAR’s risk management and security protocols. Where legally possible, JANUAR will provide the Customer with a notice prior to action and an explanation, but is under no obligation to do so and may be prohibited by court order, law enforcement, or any other legal requirement. 

11.4. JANUAR will not be liable to the Customer for any losses incurred in connection with closure of Services or suspension of Accounts. 

11.5. When the Customer believes the reasons for a suspension no longer exist, and JANUAR has not yet reestablished access to any Service suspended, the Customer may notify JANUAR via email to support@januar.com. 

11.6. The Customer may request termination and Accounts closure at any time. JANUAR will proceed to the closure of the Accounts at the end of the month, taking into account operational requirements, without causing unnecessary delays. 

12. WARRANTIES 

12.1. The Customer warrants that: 

• The information provided to JANUAR in order to obtain User access to the Platform, and API Service if applicable, is accurate and complete. 
• The Customer’s use of the Platform, and API Service if applicable, does not expose JANUAR to malicious software or security risks such as malware, trojans, viruses, denial of service attacks or any other material which is malicious or technologically harmful either to or via the Platform, and API Service if applicable. 
• The Customer will not attempt to gain unauthorized access to any part of the Platform, Production, the server on which Production resides, or any other server, computer, or database connected to JANUAR. 
• The Customer will not (i) reverse engineer, reverse compile, decrypt, unmask, or reverse assemble the Platform, Production or Data accessible via the API Service; or (ii) distribute, disclose, publish, market, sell, rent, lease, sublicense or assign to any third party any information to which you have access via the Platform, and API Service if applicable, without prior express consent of JANUAR. 

12.2. JANUAR warrants that: 

• JANUAR will perform its services and activities in compliance with all applicable laws, rules, and regulations governing financial services; and with reasonable skill, care, and diligence in accordance with industry standards. 
• JANUAR will provide accurate, complete, and up-to-date information to the best of its knowledge at the time of provision, including but not limited to financial statements, reports and analyses. 
• JANUAR will maintain strict confidentiality regarding all non-public information obtained from the Customer and implement reasonable measures to safeguard data and protect against unauthorized access. 
• In cases where JANUAR engages third-party services or products to facilitate its services, JANUAR will use reasonable efforts to ensure the reliability and suitability of such third-party services. 

13. EXCLUSION FROM THE DANISH PAYMENT ACT 

13.1. In accordance with Article 6 paragraph 3 of the Danish Payment Act (in Danish: “Betalingsloven”), it is agreed by the Parties that the following provisions aiming at ensuring consumer protection (B2C) shall not apply to the Services provided by JANUAR to the Customer: Chapter 5 and Articles 80, 82(3), 97, 98, 100-102, 104, 111, 112, 117-119 and 125 in the Danish Payment Act. 

13.2. The excluded provisions pertain primarily to consumer protection measures intended for private individuals (B2C relationships), including requirements on pre-contractual and ongoing information disclosures, as well as certain rights related to payment transactions and consumer-friendly procedures for handling unauthorised or disputed transactions. By agreeing to exclude these specific provisions, the Customer acknowledges that these consumer-oriented safeguards do not apply to their contractual relationship with JANUAR, as the Customer is considered a business entity rather than a consumer. 

14. EVENT OF DEFAULT 

14.1. If an Event of Default as listed below occurs, unless otherwise prescribed by applicable law, JANUAR may close the Customer’s Accounts, in JANUAR’s absolute discretion, with a normal notice of one month. The notice may be waived in case of serious breach of applicable regulations or order by a supervisory authority, regulator, or any such extreme circumstances. 

14.2. Each of the following will be an “Event of Default”:

• the Customer fails to pay JANUAR any fees or charges, 
• the Customer enters into liquidation or bankruptcy, whether compulsorily or voluntarily, or a procedure is commenced against the Customer seeking or proposing liquidation or bankruptcy, or the Customer is generally unable to pay its debts as they become due (or the Customer confirms so in writing) 
• the Customer becomes subject to an administration order or has a receiver or similar appointment or order are made or proceedings commenced in respect of any of the Customer’s assets; 
• JANUAR considers it necessary to prevent what JANUAR reasonably considers to be or might be a violation of any applicable law (including but not limited to, market abuse, gaming the system, or scalping). 

14.3. Under such conditions, JANUAR will freeze the Customer’s account and take actions as required by applicable law. 

14.4. JANUAR shall in no case be liable for any economic loss, delay, discontinued service or failure in performance to the extent such loss, delay, discontinuity or failure is caused by fire, flood, explosion, war, strike, embargo, governmental requirements, civil and military authority, data trespass, denial-of-service (DoS) attack, pandemics, unlawful action of the Customer or any other cause beyond JANUAR’s reasonable control. 

15. REFERENCES 

15.1. JANUAR does not endorse in any way the Customer’s product or services and Customers may not use JANUAR’s name, logo, trademarks, copyrights or any other intellectual property or business secret without prior written approval from JANUAR. 

16. MISCELLANEOUS 

16.1. If any provision in these Terms is held to be invalid or unenforceable, these Terms including the remaining provisions will remain in full force and effect as if such invalid or unenforceable provisions had never been included. 

16.2. JANUAR may modify, suspend or discontinue, temporarily or permanently, all or any part of our Services with or without notice. JANUAR reserves the discretionary right, at any time and for any reason, to discontinue, redesign, modify, enhance, change, augment, expand, reduce, patch the software, the entire JANUAR Platform, and/or the Services, including without limitation, the structure, specifications, 'look and feel', navigation, features, UX, UI, embedded functionalities, and other elements of the software and/or the Services or any part thereof. In case of major change, such as the suspension or discontinuity of a major feature, JANUAR will give, to the best of its ability and unless this is the result of supervisory request or if the changes are aimed at ensuring compliance with applicable laws, at least one week notice. The Customer agrees that JANUAR will not be liable to the Customer’s customers or to any third party (on behalf of whom the Customer may be acting) for any lack of opportunity resulting from modification, suspension or discontinuity of all or any part of our Services. 

16.3. The failure of a Party to exercise any right, power or remedy provided under these Terms shall not constitute a waiver by such Party of its right to exercise any such or other right, power, or remedy. 

17. GOVERNING LAW AND DISPUTES 

17.1. These Terms shall be governed by and construed in accordance with the laws of Denmark, excluding its conflict of law rules, and applicable European Union regulations, including the Markets in Crypto-Assets Regulation (MiCA). 

17.2. Any dispute arising out of or in connection with these Terms, including any disputes regarding the existence, validity, implementation, or termination thereof, shall be settled by the ordinary courts in Denmark with the district court of Copenhagen as chosen venue. 

17.3. Prior to any legal action, the Customer should seek resolution of the dispute by submitting a complaint to JANUAR according to its complaints policy. 

APPENDIX I - SPECIFICATIONS ABOUT THE USE OF PAYMENT SERVICES 

To initiate a fiat payment, the Customer must provide the amount and currency to be paid, message to recipient, recipient’s name and recipient’s account identifier in the form of International IBAN or Danish Domestic BBAN number. The Customer is solely responsible for ensuring that all payment details are complete and accurate. JANUAR may reject, delay, or request additional information in relation to a payment where required, to comply with applicable legal or regulatory obligations, including anti-money laundering and fraud prevention requirements.

To execute a payment transaction, the User gives consent, by providing the needed information through JANUAR’s API services or after pressing Confirm on JANUAR’s Platform. Transactions sent through the API are given consent by using the API Key to sign the transaction as part of payment initiation. 

The time at which a payment order is deemed to have been received is immediately through API or after 5 seconds through the Platform. The Customer can only cancel the payment order within the first 5 seconds after pressing Confirm on JANUAR’s Platform. Once a payment order has been received by JANUAR, it becomes irrevocable except as expressly stated herein or where otherwise required by applicable law.

The maximum completion time for the execution of a payment transaction is dependent on the path of the payment. JANUAR will send the transaction to a financial partner immediately after which the payment order will be executed at earliest convenience, typically within 1 banking day. JANUAR’s financial partner then sends it to the receiving bank. The receiving bank processes the payment within 1-2 banking days. The time for the payment to be completed by the involved institutions can take up to 3 banking days. If the transaction is flagged by transaction monitoring tools, this timeline will extend due to manual processing. 

Purpose and Use of the Payment Account

The Payment Account is provided exclusively for the execution of payment transactions in connection with the Customer’s business activities. The Payment Account does not constitute a deposit account and may not be used as a savings or investment vehicle. Funds held in the Payment Account do not accrue interest.

JANUAR reserves the right to impose limits, restrictions, or require the withdrawal or transfer of funds where the Payment Account is used primarily for storage purposes, remains inactive for an extended period, or where required to comply with applicable law, regulatory requirements, or JANUAR’s internal risk management policies.

APPENDIX II - CRYPTO SERVICES TERMS

When a customer purchases JANUAR’s Crypto Services, it is imperative to expand on the definitions to include relevant terms.

A. DEFINITIONS 

• Accounts: both Payment Account and Crypto Account 
• Conversion Fees: a charge applicable when the Customer uses JANUAR's Platform to convert between supported Currencies, between Currencies and Crypto Assets, or between supported Crypto Assets. This fee is integrated into the conversion rate provided during the transaction and is in accordance with the rates specified in JANUAR's Price List. 
• Crypto Account: an account provided by JANUAR that is exclusively designated for the storage and management of cryptocurrencies and digital assets. This account allows users to store, trade, and manage various types of cryptocurrencies as per JANUAR offer. This account is used to provide the “JANUAR Wallet” services. 
• Crypto Asset(s): digital assets and cryptocurrencies offered by JANUAR. This category may include cryptocurrencies, E-Money tokens, Asset Referenced Tokens (so-called stablecoins). Crypto Assets may be held in custody or administration by JANUAR, transferred on behalf of the Customer, or be subject to order execution or conversion services, in accordance with the applicable Crypto Services provided by JANUAR and these Terms.
• JANUAR Trade: the service provided by JANUAR that enables the Customer to convert between supported fiat Currencies and Crypto Assets. This includes facilitating the exchange of one Currency for another, as well as converting between Currencies and Crypto Assets or between different Crypto Assets, subject to any applicable fees, rates, and conditions as specified by JANUAR. 
• JANUAR Wallet: the crypto custody and storage service provided by JANUAR, allowing the Customer to securely store, manage, deposit, and withdraw supported Crypto Assets. The JANUAR Wallet operates through segregated vault infrastructure and adheres to applicable regulatory standards, ensuring that the Customer’s Crypto Assets remain secure, individually allocated, and accessible in their Crypto Account.
• Transportation Fees: refers to both fiat and crypto transportation costs related to a conversion. The crypto transportation fees are incurred when transferring cryptocurrencies from one wallet or address to another within a blockchain network. The magnitude of transportation fees is subject to dynamic factors, including network congestion, transaction size, and the priority assigned to the transaction by the sender. The Customer is hereby informed that transportation fees applicable to Crypto Asset transactions are determined by the relevant blockchain networks and are not set or controlled by JANUAR. Such transportation fees may fluctuate and vary depending on network conditions and market demand.

B. SERVICES 

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i. Custodial wallet

ii. JANUAR provides a Custodial Wallet service that enables Customers to deposit, store, and withdraw supported Crypto Assets, and to initiate transfers of such Crypto Assets to and from third parties, including third-party or Customer-controlled wallets.

iii. Each Customer’s wallet is managed within JANUAR’s secure infrastructure, operated through designated third-party wallet technology providers. All security measures and configurations are standardized and managed by JANUAR; Customers cannot modify or select individual security settings.

iv. The Custodial Wallet does not involve discretionary management of Crypto Assets and JANUAR does not provide investment or portfolio management services. Rather, it provides a safe and compliant infrastructure for the holding and movement of Crypto Assets.

v. Safeguarding and Segregation of Customer Assets: JANUAR’s Custodial Wallet safeguards Customer crypto assets through the use of an institutional-grade segregated vault structure. Customer holdings are recorded and allocated separately from those of other Customers and from JANUAR’s own assets. This structure provides a clear distinction between individual Customer holdings and enhances transparency and security. 

vi. Crypto services

vii. JANUAR provides a suite of Crypto Services enabling the movement and exchange of Crypto Assets. These include:

viii. Crypto Conversions – conversions between crypto-to-crypto, crypto-to-fiat, and fiat-to-crypto. Under MiCA, JANUAR executes such orders on behalf of the Customer through a straight-through-processing (STP) model.

ix. Crypto Transfer Services – transfers between supported wallets.

x. Crypto Payment Services – services enabling payments for goods or services in Crypto Assets. Where such services qualify as payment services under applicable law, including in relation to E-Money Tokens (EMTs), they are provided under the Danish implementation of Directive (EU) 2015/2366 (PSD2), and are subject to the applicable terms, conditions, and client rights set out in this Agreement and under governing national law. Such payment services are provided directly by JANUAR as a regulated payment institution.

Customers intending to facilitate crypto payment services to their own clients must ensure compliance with MiCA Article 70(4), as such activity requires both MiCA and PSD2 authorizations.

xi. Order execution of Crypto Asset transactions is carried out in accordance with Appendix III - Order Execution.

xii. Transfers of funds

xiii. To use JANUAR Wallet, Customers must transfer crypto funds into their Crypto Account. The address can be seen in the UI on the Platform and requested sent using the API. Once the deposit is confirmed, Customers can monitor their funds through a secure dashboard that reflects real-time updates based on blockchain transactions. 

xiv. To transfer funds out of the Crypto Account, Customers must provide the type and amount of the crypto asset to be transferred. This can be initiated either through JANUAR’s API by providing an API Key or directly through the user interface on the Platform. 

xv. The Platform underpins the security of JANUAR Wallet by employing timelocked address whitelisting for sending out funds, ensuring that there is time to halt any transactions to unintended wallets. This significantly reduces the risk of unauthorized access and fraud. Furthermore, the Customer has full control over their assets and can initiate withdrawals or transfers at any time through the Platform, ensuring they maintain full ownership and access. 

xvi. JANUAR Wallet also complies with stringent regulatory standards, segregating all Customer assets in a manner that ensures they are legally protected, even in the unlikely event of JANUAR’s insolvency. The use of dedicated wallets provides Customers with a high level of security and transparency, as they can independently verify the status of their assets via blockchain explorers. Additionally, Customers can, at any time, pull reports at will detailing their holdings and transaction history, ensuring clear and regular communication regarding their assets for any period of interest using the Platform UI. 

C. RISKS, RESPONSIBILITIES, AND LIABILITIES

i. Crypto Assets, including cryptocurrencies, are subject to various risks, such as market, liquidity, price volatility and technology risk, including potential losses resulting from theft, fraud, hacking, protocol failures, regulatory actions, and/or potential operational issues. By using JANUAR Crypto Wallet and Trade, the Customer recognizes these risks and agrees that JANUAR holds no responsibility for any losses or damages incurred, except in cases of JANUAR's gross negligence directly causing such losses.

ii. Without prejudice to Section 4 of the Terms, JANUAR is not responsible for failures, delays, forks, congestion, network upgrades, validator actions, or other technical issues attributable to blockchain networks or third-party infrastructure providers.

iii. The responsibility falls on the Customer to ensure the correctness of the recipient account information provided for the transfer of funds or Crypto Assets. If incorrect payment details have been provided, the payment or transfer may be delayed or credited to a wrong account/wallet. JANUAR shall not be held liable for any losses incurred by the Customer due to entering erroneous account information.

D. SAFEGUARDING, CUSTODIAL WALLET, AND ACTIVE BALANCE

i. Conversion of Funds or Crypto Assets 

ii. If the Customer uses the Service to convert one Currency into another, the conversion rate provided during conversion includes the FX Currency Conversion fee referred to in the Price List. The conversion rate is continuously updated and a final rate applied during conversion is determined after the Customer has decided to execute a conversion. 

iii. The Customer can use the Service to convert between supported Currencies and Crypto Assets. The conversion rate provided during order execution includes the Crypto Asset Conversion Fee referred to in the Price List. The conversion rate is continuously updated, and the final rate used for conversion is determined after the Customer confirms the execution. It can take several days for fiat funds to reflect in the Customer’s Payment Account at JANUAR. In case the Funds or Crypto Assets does not arrive at JANUAR’s designated liquidity venue within 144 hours (6 days), JANUAR reserves the right to refund and cancel the conversion. Additionally, upon conversion, there will be a deduction to cover estimated Crypto Asset Transportation Fees between JANUAR and the liquidity venue, as well as blockchain network fees. Variations in the transportation fee component are expected due to the constantly fluctuating blockchain network fees and their price volatility. Hence, the final amount depends on both the actual conversion timing and applicable Transportation Fees. There might be further limitations beyond JANUAR's control. Certain transactions may require the Customer to maintain a sufficient balance of network-native tokens to cover applicable blockchain network fees. The Customer is responsible for ensuring that adequate balances are available to facilitate such transactions. 

iv. Custody and Balance of Crypto Assets 

v. JANUAR holds the Crypto Asset balance of a Customer’s Crypto Wallet within a segregated wallet provided through a third party wallet infrastructure provider. This ensures the assets are stored separately from JANUAR’s operational assets and from the assets of other Customers. 

vi. The Customer’s Crypto Account reflects the total amount of Crypto Assets held by the Customer. Funds and Crypto Assets in transit, after a JANUAR Trade conversion or otherwise outside of the segregated vault, are not in JANUAR’s custody. Customers must recognize that risk during transit is borne by the Customer until credited. Incoming transfers will be credited to the account(s) only after sufficient blockchain confirmations. The Customer can consult their active balance via the Platform or API. 

vii. JANUAR reserves the right to restrict transactions into or out of the Crypto Account, where the origin cannot be confirmed, in accordance with the EU Transfer of Funds Regulation (TFR) also known as ‘Travel Rule’ or where there is a suspicion of Sanctions breach, or relation to financial crime until such a suspicion has been disproved.

APPENDIX III - ORDER EXECUTION

1. JANUAR facilitates the execution of orders for crypto-assets on behalf of its Customers in full compliance with applicable regulations, including the Markets in Crypto-Assets Regulation (MiCA). JANUAR is committed to achieving the best possible execution outcome by considering factors such as price, cost, speed, likelihood of execution and settlement, order size, and other relevant considerations.
2. To ensure efficient execution, JANUAR employs a variety of methods:

i. Request for Quote (RFQ): Orders are executed via our primary liquidity provider, which is an EU VASP in the process of becoming a CASP, where a time-sensitive price quote is provided.

ii. Market Orders: For specific assets that require immediate execution at the prevailing market price, orders are executed through the API of a MiCA licensed crypto exchange.

Iii. Minting/Burning: For stablecoin conversions—such as minting or redeeming USDC through Circle—direct transactions are conducted without reliance on a traditional exchange.

3. Januar determines the optimal execution method based on asset type, liquidity considerations, and cost efficiency. By using JANUAR’s services, Customers consent to the execution of their orders under these terms. Any material changes to this policy will be communicated to Customers via email.
4. Please note that certain orders may be executed outside regulated trading platforms (crypto exchanges). Such transactions, which may be facilitated through liquidity providers or stablecoin issuers, are carried out with the express consent provided during onboarding and through continued use of JANUAR’s services.
5. JANUAR continually monitors execution quality by tracking key performance indicators, including execution speed, settlement efficiency, and pricing metrics. Periodic assessments of our execution venues and liquidity providers are performed to identify and address any deficiencies, thereby ensuring ongoing regulatory compliance and optimal execution quality.
6. Furthermore, JANUAR discloses that its primary liquidity provider, may act as a counterparty in some Customer transactions. To mitigate any potential conflicts of interest, robust controls are implemented to monitor pricing fairness and maintain competitive spreads in line with market conditions.
7. Finally, JANUAR maintains comprehensive records of all executed orders—including details on pricing, timing, and execution venues—to support regulatory reporting obligations. This order execution policy is reviewed and updated periodically in response to evolving regulatory requirements, market conditions, or operational needs, with any material modifications communicated to Customers in accordance with the Terms of Service.

APPENDIX IV - API SERVICE

1. DEFINITIONS

• Secret: refers to the confidential, non-public string of characters associated with an API Key that is issued to the Customer upon approval of their API access. This Secret, when used together with the API Key, serves as a secure authentication credential that enables the Customer to access and interact with JANUAR’s API Services. The Customer is responsible for safeguarding the Secret at all times to prevent unauthorized access or misuse of the API Services.
• User or Users: person authorised by the Customer to access and use the Platform and/or API Services, including employees, directors, officers, or other representatives of the Customer. 
• API Key: text string sent to Customer, allowing access to the API Service. 
• API Service: access to the Service via an API solution. 
• API Form: the application form or onboarding documentation required by JANUAR to grant API access.
• Production: JANUAR’s live API environment used for executing real transactions.

2. JANUAR’s Products and Services can be accessed. Customers can use the Web App or use API integration.
3. Customers that want API access to JANUAR’s API production environment (“Production”) must apply by completing and filing an API form. API access to the Production will enable the Customer to view, initiate, and/or authorize payments or transfers from their Accounts with JANUAR API Services. 
4. To use the API Services, the Customer must register one or several Users by completing the API form and submitting the API with JANUAR. 
5. Users must be duly authorised representatives of the Customer and legally capable of entering into binding agreements under applicable law.
6. Following JANUAR’s approval of a User, the user will receive a personal API Key and Secret. 
7. The API Services will allow the Customer to use the Services while engaging with live data. 
8. JANUAR provides the API Services on an “as is” basis without any warranty of any kind, whether explicitly expressed or implied, including without limitation the implied warranties of merchantability, fitness for a particular purpose, and non-infringement of third party rights. Nothing in this clause limits JANUAR’s obligations under applicable law.
9. JANUAR has no direct or indirect liability for any loss or issue that might occur due to the Customer's misuse or misinterpretation of documentation, software, or specifications, especially when it is determined that it is a result of the Customer’s own actions. 
10. The information and functionalities of the API Services including API endpoints may be subject to changes from time to time. In case of substantial changes to API endpoints, JANUAR will, to the extent possible, provide 3 months notice to the Customer prior to implementing such a change. 
11. The API Services must only be used in accordance with these Terms and JANUAR’s guidance and documentation.
12. Suspension and Cancellation 
13. After one(1) year of inactivity of a User, the User will be deactivated and terminated. After one(1) year of inactivity of a Customer, the Customer will be deactivated and terminated, any developer organizations/teams will be deleted together with the Customer and any members of the Customer’s organizations will have their Users and access terminated. 
14. JANUAR may suspend or terminate the Customer’s right to access the API Service in case of violation of these Terms. 

APPENDIX V - EMT CUSTODY

1. Scope and Legal Basis
   
   1. JANUAR provides EMT custody and transfer support services as a regulated payment institution, enabling Customers licensed as crypto-asset service providers (CASPs) to offer e-money token (EMT) custody and transfer services to their end clients in accordance with Article 70(4) of Regulation (EU) 2023/1114 (MiCA).
      
      
   2. Under this arrangement, the Customer remains the regulated service provider vis-à-vis its end clients. JANUAR performs safeguarding functions and related payment services within the scope of its own regulatory permissions.
   3. Nothing in this Appendix constitutes a transfer of regulatory responsibility from the Customer to JANUAR, except to the extent expressly required by applicable law.
2. Interaction Between MiCA and PSD2
   
   1. EMT-related services may qualify as payment services under Directive (EU) 2015/2366 (PSD2) and applicable national implementing legislation. Where this is the case, PSD2 applies in principle in its entirety, including Titles III and IV on transparency, rights, and obligations.
      
      
   2. The European Banking Authority (EBA) has acknowledged that certain PSD2 provisions may raise implementation challenges due to the characteristics of distributed ledger technology and has advised national competent authorities not to prioritise supervision of specific requirements in limited circumstances. Such supervisory prioritisation does not constitute a legal exemption.
      
      
   3. Accordingly, the Customer remains responsible for complying with all applicable provisions of PSD2, including strong customer authentication, fraud prevention and reporting, liability rules, operational and security requirements, and relevant transparency obligations, to the extent EMT-related services qualify as payment services.
      
      
   4. Where EMT-related payment services are provided in connection with the services described in this Appendix, the Customer shall comply with Article 70(4) of MiCA.
      
      
   5. In particular, the Customer shall clearly inform its end clients of all of the following:
      
      
      
      1. The nature, scope, and applicable terms and conditions of the EMT-related payment services, including:

• reference to the applicable national law governing those services; and
• A description of the rights of clients under such law.
  
  

2. Whether the relevant payment services are:

• provided directly by the Customer; or
• provided by a third party, including where JANUAR performs regulated safeguarding or related payment services.
  
  

6. The Customer remains solely responsible for ensuring that such disclosures are accurate, complete, clear, fair, and not misleading in accordance with MiCA and applicable national law.
   
   
7. Failure by the Customer to comply with these disclosure obligations shall not transfer any regulatory liability to JANUAR.

3. Safeguarding Arrangements
   
   1. To align with the safeguarding objectives under PSD2 within the technical framework of EMTs:
      
      1. JANUAR will establish:
         
         1. one designated safeguarding wallet; and
         2. one operational/company wallet.
            
            
      2. JANUAR will provide a written and signed statement identifying the safeguarding wallet address.
         
         
      3. The safeguarding wallet shall:
         
         1. contain only EMTs belonging to end clients of the Customer;
         2. be segregated from the Customer’s own funds; and
         3. be structured so that such assets are held separately in accordance with applicable safeguarding requirements and shall not form part of the Customer’s insolvency estate, subject to applicable law.
            
            
   2. The Customer is responsible for ensuring that no proprietary or non-client funds are transferred to the safeguarding wallet.
4. Strong Customer Authentication
   
   1. To comply with applicable strong customer authentication requirements, the Customer shall ensure that its end clients are subject to SCA measures when:

• accessing custodial wallets; and
• initiating EMT transfers or EMT conversions.
  
  

2. SCA must meet the requirements of applicable law and regulatory technical standards in force from time to time. Compliance with this obligation remains the sole responsibility of the Customer.

5. Fraud Monitoring and Reporting
   
   1. JANUAR reserves the right to provide the Customer with a standardised fraud reporting template for regulatory reporting purposes. Where such template is provided, the Customer shall complete and submit it to JANUAR on a semi-annual basis, no later than:

• 1 March (covering the period 1 July – 31 December); and
• 1 September (covering the period 1 January – 30 June).
  
  

2. The Customer shall ensure that all information submitted is complete, accurate, and not misleading. Failure to submit the required report within the applicable deadline may constitute a breach of this Agreement.

6. Transitional Regulatory Framework
   
   1. The regulatory interaction between MiCA and PSD2 reflects a transitional environment pending the implementation of PSD3 and the Payment Services Regulation (PSR). The Customer acknowledges that regulatory interpretations and supervisory expectations may evolve and agrees to cooperate with JANUAR in implementing necessary adjustments to ensure continued compliance.
7. Regulatory Responsibility
   
   1. The regulatory requirements set out in this Appendix form part of the contractual framework governing the EMT partnership between JANUAR and the Customer and are binding obligations under this Agreement.
      
      
   2. However, compliance with this Agreement does not constitute legal or regulatory advice and does not represent or guarantee that adherence to the contractual requirements herein will ensure the Customer’s compliance with MiCA, PSD2, national implementing legislation, or any other applicable laws or regulations.
      
      
   3. JANUAR makes no representation or warranty that compliance with this Appendix is sufficient to satisfy all regulatory obligations applicable to the Customer. The Customer remains solely and independently responsible for assessing and ensuring its full compliance with all applicable laws and regulatory requirements in the jurisdictions in which it operates.
      
      
   4. Nothing in this Appendix shall be construed as transferring regulatory responsibility from the Customer to JANUAR, except to the extent expressly required under applicable law.

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APPENDIX VI - LIGHTNING SERVICES

1. JANUAR provides access to Lightning Network functionality through the following services:

• Lightning Wallet – enables Customers to hold and transact over the Bitcoin Lightning Network.
• Lightning Transfers – transfers between Lightning Wallets.
• Lightning Payments – enables Customers to make or receive payments using the Lightning Network.

2. Pricing for Lightning services is separate from traditional crypto payments.

APPENDIX VII - JANUAR EMBEDDED ACCOUNTS

1. JANUAR’s Embedded Accounts product line enables Partners to organize and manage their relationships with their clients while centralizing fee routing and account control. Through this setup, the Partner may decide which products and services their clients can access.
2. Each Embedded Client has access to the same types of products and features available to regular Customers; however, fees are deducted from the Partner’s Account, except where specified otherwise.
3. Under the Embedded Accounts setup:

• IBANs are only issued to legal entities that have been KYCed and approved by JANUAR.
• Both the Partner and each Client are issued separate Wallets.
• Wallet Transfer Fees may be deducted from the Partner’s Account.
• FX and Crypto Transfer Fees are routed to the fiat side (Partner Account).

4. Crypto Conversion Fees remain deducted from the Client’s wallet in crypto, as these cannot be rerouted to the fiat account due to operational limitations. 
5. This structure allows Partners to maintain full control and branding over their client relationships while ensuring regulatory compliance through JANUAR’s licensed infrastructure.

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