REGULATORY STATUS AND LEGAL INFORMATION STATEMENT

Last updated: 01.07.2026

1. General Provisions

1.1. This Regulatory Status and Legal Information Statement, hereinafter referred to as the Statement, provides information concerning the legal identity, applicable regulatory framework, current status, and relevant limitations of UNITRADE INTERNATIONAL LLC, operating under the OurExchangeClub trademark.

1.2. The purpose of the Statement is to provide Users and other interested persons with clear, accurate, and non-misleading information concerning the Company’s legal status and the nature of its activities.

1.3. The Statement is an informational and public disclosure document and does not constitute a public offer, a standalone service agreement, an investment proposal, personalized advice, or a guarantee of the outcome of any transaction.

1.4. The Statement applies together with the Company’s Terms of Use and Public Offer, Privacy Policy, Customer Identification — KYC, Anti-Money Laundering and Counter-Terrorist Financing and Sanctions Compliance Policy, Cryptoasset Risk Disclosure Statement, and other documents published on the Website.

1.5. In the event of any inconsistency between the Statement and a document specifically governing a particular service or legal relationship, the document specifically governing that legal relationship shall prevail, unless otherwise provided by the legislation of the Republic of Armenia.

2. Company Identification Details

2.1. The OurExchangeClub platform is operated by UNITRADE INTERNATIONAL LLC, a limited liability company registered in the Republic of Armenia.

2.2. The Company’s details are as follows:

• Legal name: UNITRADE INTERNATIONAL LLC;
• State registration number: 273.110.112229;
• Taxpayer identification number: 02825175;
• Chief Executive Officer: Mr. Avetis Varosyan;
• Registered address: 31/3 Tumanyan Street, Yerevan 0002, Republic of Armenia;
• Website: ourexchange.club;
• Email: info@ourexchange.club;
• Telephone: +374 94 048 044.

2.3. OurExchangeClub is a trademark used by the Company and the commercial name of the services presented on the Website.

2.4. OurExchangeClub is not a legal entity separate from the Company and does not independently acquire rights or assume obligations.

2.5. The Company’s state registration in the State Register of Legal Entities of the Republic of Armenia does not, in itself, constitute a license to provide financial or cryptoasset-related services and must not be interpreted as an authorization granted by the Central Bank of the Republic of Armenia.

3. Applicable Regulatory Framework

3.1. The Company organizes its activities within the framework of the applicable legislation of the Republic of Armenia, including, where relevant:

1. the Law of the Republic of Armenia on Cryptoassets;
2. legislation governing anti-money laundering and counter-terrorist financing;
3. legislation governing the protection of personal data;
4. requirements applicable to non-cash transactions, payment and settlement relations, and cash transactions;
5. applicable tax, accounting, and consumer protection requirements;
6. applicable regulatory legal acts of the Central Bank of the Republic of Armenia;
7. other legal acts applicable to the Company’s activities.

3.2. The public offering of cryptoassets and the provision of cryptoasset-related services in the Republic of Armenia are regulated and supervised by the Central Bank of the Republic of Armenia.

3.3. Types of cryptoasset-related services for which registration and licensing by the Central Bank of the Republic of Armenia are required by law may be provided only where the relevant legal basis exists.

3.4. The Company’s compliance with applicable legislation, compliance requirements, or risk management procedures does not mean that the Company is a licensed financial institution.

4. Current Regulatory Status of the Company

4.1. As of the date on which this Statement was last updated, the Company is not registered or licensed by the Central Bank of the Republic of Armenia as a cryptoasset service provider.

4.2. The Company does not hold itself out or represent itself as:

1. a cryptoasset service provider registered and licensed by the Central Bank of the Republic of Armenia;
2. a bank;
3. a credit institution;
4. an investment company;
5. a licensed operator of a regulated market or cryptoasset trading platform;
6. an investment fund or investment fund manager;
7. an asset manager;
8. a payment and settlement organization;
9. an electronic money issuer;
10. a custodian or depositary;
11. a financial, investment, legal, or tax adviser.

4.3. Registration on the Website, completion of identification procedures, possession of a user account, or entering into a transaction with the Company does not mean that the User is receiving services from a bank, investment company, or other licensed financial institution.

4.4. The Company does not use the terms “licensed,” “approved by the Central Bank,” “guaranteed by the Central Bank,” or any expression of equivalent meaning unless and until the relevant status has been formally granted by the competent authority.

4.5. The Company’s performance of preparatory, organizational, legal, technical, or internal work required for licensing does not, in itself, mean that a license application has been submitted, accepted for consideration, or approved.

4.6. The Company may publish information stating that it has submitted a license application or is undergoing a licensing process only where that fact is supported by an official and verifiable document.

5. Transitional Regulatory Framework

5.1. The Law of the Republic of Armenia on Cryptoassets entered into force on July 4, 2025.

5.2. The legislation provides a transitional period for persons that were providing cryptoasset-related services in the Republic of Armenia as of the date on which the Law entered into force, allowing them to register with the Central Bank of the Republic of Armenia as cryptoasset service providers and obtain the relevant license.

5.3. Under the applicable transitional arrangements, the relevant persons must register with and obtain a license from the Central Bank of the Republic of Armenia by January 31, 2027, or discontinue the provision and offering of services subject to licensing, unless another legal basis exists for the continuation of such services.

5.4. The Company organizes its activities taking into account the applicable transitional provisions, existing restrictions, and regulatory requirements.

5.5. This section does not constitute a representation that the Central Bank of the Republic of Armenia has confirmed, approved, or otherwise recognized the Company’s right to rely on the transitional arrangements.

5.6. The Company’s legal status may change as a result of legislative amendments, decisions of the Central Bank of the Republic of Armenia, the granting or refusal of a license, restructuring of the Company’s activities, or other legally significant circumstances.

6. Nature of the Services Presented by the Company

6.1. Within the scope of the terms published on the Website and the technical capabilities available at the relevant time, OurExchangeClub may offer Users the ability to create and execute transactions for the purchase or sale of cryptoassets.

6.2. The availability of each service or transaction is determined by taking into account:

1. applicable legislation;
2. the Company’s current regulatory status;
3. the results of User identification and verification;
4. sanctions compliance and anti-money laundering and counter-terrorist financing requirements;
5. verification of the origin of funds and cryptoassets;
6. the purpose and economic substance of the transaction;
7. the Company’s internal limits and risk management criteria;
8. technical and operational capabilities.

6.3. The Company may decline to offer, restrict, temporarily suspend, or discontinue any service where necessary for compliance with legislation, regulatory requirements, security, compliance, or risk management purposes.

6.4. The technical display of a service, function, cryptoasset, or payment method on the Website does not, in itself, guarantee its availability to every User or for every transaction.

6.5. Each transaction is subject to the terms, exchange rates, payments, fees, limits, and other material conditions published on the Website at the time the transaction is created and confirmed.

7. Services Not Provided by the Company

7.1. Unless expressly stated otherwise on the Website and in the applicable terms, and only where the necessary legal basis exists, the Company does not provide:

1. banking services;
2. deposit-taking services or the acceptance of other repayable funds;
3. loans or credit facilities;
4. investment services relating to securities;
5. portfolio management services in respect of cryptoassets or other assets;
6. personalized investment advice;
7. investment products offering guaranteed returns;
8. permanent custody of Users’ funds or cryptoassets;
9. custodial or depositary services;
10. insurance services;
11. the opening or maintenance of payment or bank accounts;
12. any other service requiring a license or specific authorization under applicable law where the relevant legal basis is absent.

7.2. Information provided by the Company concerning cryptoassets, markets, exchange rates, technologies, or transactions is of a general informational or transactional nature and does not constitute personalized investment, financial, legal, or tax advice.

7.3. Where appropriate, the User must obtain independent professional advice based on their personal circumstances, financial capacity, and risk tolerance.

8. Absence of Regulatory Approval or Guarantee

8.1. The Company’s state registration, tax registration, operation of the Website, cooperation with any public or private organization, or compliance with legal requirements does not mean that the Central Bank of the Republic of Armenia or any other public authority:

1. has approved the Company’s activities;
2. has approved the Company’s business model;
3. has assessed or confirmed the quality or value of the cryptoassets offered;
4. guarantees the execution of transactions;
5. guarantees the return of Users’ funds;
6. bears responsibility for the Company’s actions or obligations.

8.2. The Company’s use of a third party’s services or cooperation with a licensed organization does not transfer that third party’s license, status, or authority to the Company.

8.3. The publication of a third party’s license, name, or details relates exclusively to that third party’s status and may not be interpreted as a representation that the Company is licensed.

9. Non-Applicability of State Fund Protection Schemes

9.1. Transactions carried out through OurExchangeClub are not bank deposits.

9.2. Funds or cryptoassets transferred by a User to the Company do not constitute a bank deposit and are not protected by any bank deposit compensation guarantee scheme applicable to deposits held by individuals.

9.3. The value, liquidity, transferability, or recovery of cryptoassets is not guaranteed by the Republic of Armenia, the Central Bank of the Republic of Armenia, any other public authority, or any deposit guarantee scheme.

9.4. Transactions involving cryptoassets may result in partial or total financial loss, and the User must review the Cryptoasset Risk Disclosure Statement in advance.

10. Engagement of Third Parties

10.1. In the course of its activities, the Company may engage third parties providing identification, payment, banking, software, information security, communication, or other services.

10.2. Each third party operates within the scope of its own legal status, terms, authority, and responsibility.

10.3. The engagement of a third party does not mean that:

1. the third party controls or guarantees the Company’s entire operations;
2. the Company acquires the third party’s license or authorization;
3. the third party is liable for all obligations of the Company;
4. the Company is liable for every decision independently made by the third party within the scope of its own activities.

10.4. Additional information concerning third parties may be provided in the Terms of Use, Privacy Policy, Payments and Cash Transactions Policy, or on the relevant transaction page.

11. User Responsibility

11.1. Before registering on the Website or creating a transaction, the User must review:

1. the Company’s current regulatory status;
2. the Terms of Use and Public Offer;
3. the Cryptoasset Risk Disclosure Statement;
4. applicable exchange rates, payments, and limits;
5. the terms governing transaction execution and cancellation;
6. the legal and tax consequences applicable to the User.

11.2. The User must not assume that using the Company’s services or completing the identification process constitutes approval by any public authority of the User’s transaction, financial position, or decision.

11.3. The User makes decisions relating to cryptoassets independently and at their own responsibility, taking into account their knowledge, experience, financial capacity, and ability to bear the relevant risks.

11.4. In case of doubt, the User should obtain independent legal, tax, financial, or technical advice before entering into a transaction.

12. Verification of Regulatory Status

12.1. Users may independently verify whether the Company has been granted the relevant registration or license through the official website and public registers of the Central Bank of the Republic of Armenia.

12.2. If a license is granted, the Company will publish on the Website at least:

1. the type of license;
2. the license number;
3. the date of issuance;
4. the scope of licensed services;
5. a link to the relevant register of the Central Bank of the Republic of Armenia;
6. any material restrictions applicable to the license.

12.3. Until such information is officially published, any unofficial statement made by an employee, representative, partner, or third party may not be treated as confirmation of the Company’s licensed status.

13. Amendments to the Statement

13.1. The Company may amend or supplement the Statement due to:

1. a change in the Company’s regulatory status;
2. the submission of a license application or a decision made in relation to such application;
3. legislative or regulatory changes;
4. changes to the services provided or the Company’s business model;
5. changes to the Company’s identification or contact details.

13.2. An amended version of the Statement enters into force upon publication on the Website unless a later date is specified in that version.

13.3. In the event of a material change in regulatory status, the Company may also notify Users by email, through their user account, or by publishing an appropriate notice on the Website.

13.4. Users are advised to review the current version of the Statement periodically.

14. Official Communications

14.1. Official information concerning the Company’s legal or regulatory status may be provided only through:

1. documents published on the Website;
2. communications sent from the Company’s official email addresses;
3. a written statement issued by a person duly authorized by the Company;
4. an official publication of a competent public authority.

14.2. Information published on social media, messaging applications, in comments, or through other unverified sources does not constitute official confirmation of the Company’s regulatory status.

14.3. Questions concerning the Statement, the Company’s legal details, or its regulatory status may be sent to info@ourexchange.club.

14.4. Reports concerning ethics, conflicts of interest, corruption, or other possible violations may be sent to ethics@ourexchange.club.

15. Final Provisions

15.1. The Statement is published on the Company’s official Website and is available to all Users and interested persons.

15.2. The Statement is governed by and shall be interpreted in accordance with the legislation of the Republic of Armenia.

15.3. If any provision of the Statement is held to be invalid, unlawful, or unenforceable, this shall not affect the validity or enforceability of the remaining provisions.

15.4. The Armenian-language version of the Statement shall prevail over versions published in other languages.

15.5. Matters not governed by the Statement shall be governed by the legislation of the Republic of Armenia, the Company’s Terms of Use, other documents published on the Website, and applicable agreements.