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Disclosures

Last updated: October 23, 2024

Custody services are offered to eligible participants through BitGo Trust Company, a South Dakota-chartered trust company and registered money services business. BitGo Portfolio and BitGo Tax are software solutions offered through BitGo Inc. Digital asset trading is done with BitGo Prime LLC as the counterparty to all trades. Trading settlement services are provided by BitGo Trust Company. BitGo Prime LLC is not engaged in the offer, sale, or trading of securities. BitGo Trust Company is not engaged in the offer, sale, or trading of securities or digital assets. Custody, trading, and settlement services are not yet offered to residents of New York.BitGo Trust Company, BitGo Inc., BitGo New York Trust Company LLC, BitGo, Inc., BitGo Prime LLC, and BitGo Singapore Pte Ltd are separately operated, wholly-owned subsidiaries of BitGo Holdings, Inc.,a Delaware corporation headquartered in Palo Alto, CA. No legal, tax, investment, or other advice is provided by any BitGo entity.

BitGo Inc.

Digital assets software solutions provided by BitGo Inc., a separately operated, wholly-owned subsidiary of BitGo Holdings, Inc.

BitGo Trust Company

Custody services are offered to eligible participants through BitGo Trust Company, a trust company chartered in both South Dakota and BitGo New York Trust Company LLC, a limited purpose trust company in New York. BitGo Trust Company, Inc. and BitGo New York Trust Company LLC are not engaged in the offer, sale, trading, or lending of securities or digital assets. BitGo Trust Company, Inc. and BitGo New York Trust Company LLC are separately operated, wholly-owned subsidiaries of BitGo Holdings, Inc.

For customers located in the state of New York, please note the following disclosures associated with virtual currency:

(1) Virtual currency is not legal tender, is not backed by the government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections;

(2) Legislative and regulatory changes or actions at the State, Federal, or international level may adversely affect the use, transfer, exchange, and value of virtual currency;

(3) Transactions in virtual currency may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable;

(4) Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction;

(5) The value of virtual currency may be derived from the continued willingness of market participants to exchange fiat currency for virtual currency, which may result in the potential for permanent and total loss of value of a particular virtual currency should the market for that virtual currency disappear;

(6) There is no assurance that a person who accepts a virtual currency as payment today will continue to do so in the future;

(7) The volatility and unpredictability of the price of virtual currency relative to fiat currency may result in significant loss over a short period of time;

(8) The nature of virtual currency may lead to an increased risk of fraud or cyber attack;

(9) The nature of virtual currency means that any technological difficulties experienced by the licensee may prevent the access or use of a customer’s virtual currency; and

(10) Any bond or trust account maintained by the licensee for the benefit of its customers may not be sufficient to cover all losses incurred by customers.

BitGo New York Trust Company LLC is chartered as a limited purpose trust company and licensed to engage in Virtual Currency Business Activity by the New York State Department of Financial Services. If you have any questions or complaints, please first contact BitGo support at support@bitgo.com or by mailing to: BitGo Support, 2443 Ash Street, Palo Alto, CA 94306. You can also reach BitGo support by calling 833-242-1493.

If you are a customer of BitGo New York Trust Company LLC, you may also direct complaints to the attention of: New York State Department of Financial Services, One State Street, New York, NY 10004-1511; by phone at +1 (212) 480-6400. Please visit https://www.dfs.ny.gov.

BitGo Prime LLC

BitGo Prime LLC is not engaged in the offer, sale, trading, or lending of securities. Institutional digital asset lending services are provided by BitGo Prime LLC, a separately operated, wholly-owned subsidiary of BitGo Holdings, Inc.

BitGo Holdings LLC

BitGo Holdings LLC is not engaged in the business of the offer, sale or trading of securities. BitGo Holdings, Inc. is a Delaware corporation headquartered in Palo Alto, CA. None of these BitGo entities are registered with the U.S. Securities and Exchange (SEC), the Commodity Futures Trading Commission (CFTC), have a broker-dealer license in any jurisdiction, or are protected by the FDIC insurance. No legal, tax, investment, or other advice is provided by any BitGo entity. Please consult your legal/tax/investment professional for questions about your specific circumstances.

BitGo Singapore Pte Ltd 

THE DISCLOSURES IN THIS SECTION TITLED “BITGO SINGAPORE PTE LTD” ARE FOR PERSONS IN SINGAPORE ONLY. 

BitGo Singapore Pte Ltd is a Singapore-incorporated private limited company which is licensed by the Monetary Authority of Singapore (“MAS”) to provide digital payment token (“DPT”) and cross-border money transfer services. If you are a retail customer in Singapore as defined in the MAS Guidelines on Consumer Protection Measures by DPT Service Providers [PS-G03], BitGo Singapore Pte Ltd may provide you with its “Trading” and “Custodial Wallets” services. If you are a customer in Singapore other than a retail customer (i.e. an accredited investor), BitGo Singapore Pte Ltd may provide “Trading”, “Custodial Wallets” and “Staking” services to you. 

The key risks and features of the “Custodial Wallets” services are set out in a separate Custodial Services Agreement to be entered between you and BitGo Singapore Pte Ltd (“CSA”). The key risks and features of the “Trading” services are set out in a separate Master Purchase Agreement to be entered between you and BitGo Singapore Pte Ltd (“MPA”). The key risks of the “Staking” services are set out in the Staking & Delegation Services Terms. 

Risk Warning

The Monetary Authority of Singapore (MAS) requires us to provide this risk warning to you as a customer of a DPT service provider. 

Before you: 

(a) pay your DPT service provider any money or DPT; or 

(b) pay a third party any money or DPT under an arrangement by your DPT service provider, 

you should be aware of the following. 

  1. Your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider or any other third party referred to above, if your DPT service provider’s or the third party’s business fails. 

  2. You should be aware that MAS does not supervise or regulate your DPT service provider for the provision of unregulated services.* This includes any service of trading digital payment token derivatives such as futures.

  3. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by your DPT service provider. 

  4. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.

  5. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”.

*Please refer to Section 2.3.1 of the Guide to the Payment Services Act 2019 (which can be found on the MAS website) for the types of payment services which are regulated under the Payment Services Act. Services which do not fall within the list of services in Section 2.3.1 are unregulated services.

Losses of Customers’ Assets 

In the event of losses of customers' digital assets arising from fraud, gross negligence or wilful misconduct on the part of BitGo Singapore Pte Ltd:

(a) Customers are advised to promptly report any losses and associated suspicious activity to BitGo Singapore Pte Ltd’s support team through support@bitgo.com;

(b) BitGo Singapore Pte Ltd will investigate the matters and endeavour to provide a resolution within 90 days. In any event, BitGo Singapore Pte Ltd will provide the affected customer with an updated within this timeline; and

(c) As part of BitGo Singapore Pte Ltd’s investigations into the matter, BitGo Singapore Pte Ltd may contact the customer and/or any other relevant third parties for further information.

Safeguarding of Digital Assets 

BitGo Singapore Pte Ltd will safeguard the digital assets received from the customer in a trust account maintained by BitGo Singapore Pte Ltd (fees in respect of the safeguarding service are identical to those in respect of the Custodial services set out above). BitGo Singapore Pte Ltd will not commingle a customer’s digital assets with the digital assets of its other customers. The Digital Assets will be stored in devices, which may be located in a foreign jurisdiction. The laws and practices in the foreign jurisdiction may be different from the laws and practices in Singapore, and any such differences may affect the ability of the customer to recover the customer’s assets. Further information on the safeguarding procedures may be found in the CSA. 

Conflicts of Interest 

As a provider of a broad range of financial services, BitGo Singapore Pte Ltd may face actual and potential conflicts during the course of its activities. These may arise from any one or combination of the following:

(a) BitGo Singapore Pte Ltd and customer relationships;

(b) BitGo Singapore Pte Ltd and other third party service provider (including BitGo, Inc. and BitGo Trust Company, Inc.) duties;

(c) Employee interests which potentially compete with BitGo Singapore Pte Ltd products or services; and

(d) Potentially competing interests between two or more customers.

BitGo Singapore Pte Ltd utilises various means to prevent and manage conflicts of interest, which include the following:

(a) Employee compliance policies and directives that require disclosure, monitoring and reporting of conflicts of interest that arise involving an employee, BitGo Singapore Pte Ltd, and/or a customer;

(b) Clear governance rules relating to the handling and management of third-party relationships;

(c) Mandatory legal, risk and compliance reviews monitoring whether specific activities will give rise to conflicts of interest; and 

(d) Provision of internal guidance and training on the handling and disclosure of conflicts of interest.

BitGo Singapore Pte Ltd discloses conflict of interest in cases where it is not possible to avoid or resolve the conflict. Such disclosure is made in a clear and direct manner, using the appropriate medium. The disclosure must be able to be understood by the affected customer, particularly in respect of the risks of potential damage to the customer’s own interest.

Security Measures

BitGo Singapore Pte Ltd implements robust security measures to mitigate the risk of loss of customer digital assets due to cyber attacks. This includes storing the customer digital assets in cold wallets and requiring manual authorization by more than one person for any transfer of digital assets out of cold wallets, implementing MAS’s principles of “never alone”, “segregation of duties” and “least privilege” in our internal custody and wallet management policies, implementing a risk monitoring system for any withdrawals out of cold wallets, conducting independent audits on our custody and custody management systems and encouraging clients to create multiple cold wallets if assets exceed a certain threshold to reduce loss. The cold wallets’ private keys are stored offline. As cold wallets are not connected to the internet or any other form of online or wireless communications, they provide a higher level of security as they may be less susceptible to cyber-attacks."

Complaints

As a customer of BitGo Singapore Pte. Ltd. (“BitGo”), you may submit complaints regarding any of BitGo’s services and/or products. Complaints can be submitted electronically to the following email address: support@bitgo.com, with the subject line: “Official Complaint about BitGo Singapore Pte. Ltd.”.

Important: Please use this email address exclusively for submitting complaints. Complaints sent to any other email addresses will not be considered.

To process your complaint, the following information is required:

  • Subject: Official Complaint about BitGo Singapore Pte. Ltd.

  • Full contact details (name, address and email address)

  • A detailed description of the issue

  • Copies of all relevant supporting documents (if available)

BitGo will confirm receipt of your complaint within 5 business days from the date on which the complaint is received. Within 20 business days from the date on which the complaint is received, BitGo will send to you one of the following:

  • BitGo’s final response with: 

  • written reasons for rejection if the complaint is rejected; or

  • any remedial actions which have or will be carried out by BitGo; OR

  • if no final response is provided, a written response informing you of all the following:

    • the reason(s) for any delay in providing BitGo’s final response;

    • an indicative reasonable timeframe for the final response to be furnished; 

    • any escalation of the complaint to BitGo’s senior management; and

    • your right to refer the complaint to a dispute resolution scheme.

BitGo will document each complaint received and the outcome of the assessment properly.

Exchange Rate

For cross-border money withdrawals involving BitGo Singapore Pte. Ltd., clients are hereby informed that any conversion of fiat currency will be executed at an exchange rate determined based on the relevant spot rates as provided by DBS Bank to BitGo Singapore Pte. Ltd.

For other DPT transactions involving BitGo Singapore Pte. Ltd., any conversion will be executed at an exchange rate determined at the sole discretion of BitGo Singapore Pte. Ltd.