Last Modified: August 21, 2025

Use of assets managed by Paxos Trust Company, LLC, a New York State chartered limited purpose trust company (“Paxos Trust”) or its applicable affiliates, including Paxos Global PTE LTD (“Paxos Global”), Paxos Digital Singapore Pte. Ltd. (“Paxos Digital”), Paxos Issuance Europe Oy (“PIE”) and Bruntal S.A. (dba Paxos Uruguay) (“PUY”), (collectively, “Paxos,” “we,” “us” or “our”), for illegal activity is strictly prohibited as further provided herein: 

1. We may freeze, temporarily or permanently, your use of, and access to PYUSD, USDP, USDG and/or BUSD or the US dollars backing your PYUSD, USDP, USDG and/or BUSD with or without advance notice, if we are required to do so by law, including by court order or other legal process.

2. Your PYUSD, USDP, USDG and/or BUSD and the US dollars backing your PYUSD, USDP, USDG and/or BUSD may be subject to seizure or forfeiture by law enforcement, and we will comply with legal process in respect thereof.

3. If we determine after investigation that PYUSD, USDP, USDG and/or BUSD has been used, or is being used, for illegal (or sanctioned) activity, we may not permit you to redeem your PYUSD, USDP, USDG and/or BUSD for US dollars from Paxos, and, if presented for redemption, such PYUSD, USDP, USDG and/or BUSD and the US dollars backing such PYUSD, USDP, USDG and/or BUSD may be forfeited.

4. Any PYUSD, USDP, USDG and/or BUSD or fiat currency underlying PYUSD, USDP, USDG and/or BUSD that is subject to freeze, seizure, forfeiture or similar limitation on its use imposed by law may become wholly and permanently unrecoverable and unusable, and in appropriate circumstances, may be destroyed.

5. This applies to all holders of PYUSD, USDP, USDG and/or BUSD, regardless of whether the holder is a registered customer of Paxos.

6. By using PYUSD, USDP, USDG and/or BUSD, you agree that we may take the actions set forth above and that we will not be liable to you therefore.

7. Paxos’s Compliance Department must comply with any legal directive to freeze, temporarily or permanently, user access to Paxos issued asset-backed tokens including USD stablecoins and gold-backed stablecoins (PAXG). Paxos will only freeze such assets (a) if required to do so by law, specifically when Paxos receives a formal legal directive from a regulator, judicial body, law enforcement agency, or other legal entity having jurisdiction over Paxos, or (b) pursuant to a formal notification by a Paxos partner according to previously agreed contractual terms. Required legal directive formats include court-ordered subpoenas, national security letters, and formal written directives from a regulator with oversight over Paxos.

8. If any party is aware of improper conduct involving a Paxos supported asset backed token, the party should immediately contact Paxos at support.paxos.com, as well as law enforcement to work towards filing a law enforcement report. Paxos will make reasonable efforts to cooperate with law enforcement inquiries and assist with investigations pertaining to Paxos supported asset backed tokens. 

9. Tokens held by non-registered customers of Paxos may subsequently also be subject to seizure or forfeiture if Paxos is instructed to seize such funds by formal written legal directive from a regulator, judicial body, law enforcement agency, or other legal entity having jurisdiction over Paxos. Seizure may not occur under any circumstances absent such a legal directive.

10. If tokens are seized, the Paxos transaction generation will ensure that the seized funds are sent to a segregated wallet address held by Paxos for the purposes of seizure/forfeiture, until such time as they may be disposed of or otherwise handled as required by law.