EXHIBIT C

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FTX TERMS OF SERVICE

Date: May 13, 2022

The following terms and conditions of service, together with any other documents expressly 

incorporated herein, (collectively, the "Terms") constitute an agreement between you ("you", 

"your" or "User") and FTX Trading Ltd, a company incorporated and registered in Antigua and 

Barbuda (company number 17180) ("FTX Trading", "we", "our" or "us"), or a Service Provider in 

respect of a Specified Service, and apply to your use of: 

(A) the Exchange and any Specified Service that may be offered to you by a Service Provider

(collectively, the "Platform"), as a User to buy, sell, exchange, hold, stake, lend, borrow, 

send, receive or otherwise transact in (together, "transact in") or list Digital Assets; 

(B) the FTX Application Programming Interface ("API"); and 

(C) any other services offered through the FTX website (ftx.com) (the "Site") or any Mobile 

Application, 

(together, the "Services"). 

By registering for a Platform account ("Account") or using the Services, you agree that you have 

read, understand and accept the Terms, including our Privacy Policy, Security Policy and Fee 

Schedule, and you acknowledge and agree that you will be bound by and comply with the Terms. 

Do not proceed with registering for an Account, or using the Services, if you do not understand and 

accept the Terms in their entirety. 

Section 21 (Right to change, suspend or discontinue Services) and Section 22 (Updates to Terms) 

set out the terms on which we may, from time to time, change, suspend, or discontinue any aspect 

of the Services and amend any part of the Terms. 

Our Services are not offered to Restricted Persons (as defined in Section 3.3.1(A) below) or 

persons who have their registered office or place of residence in the United States of America or 

any Restricted Territory (as defined in Section 3.3.1(A) below).

FTX Trading's relationship with you under the Terms is as a trading platform provider only. FTX 

Trading does not act as principal or counterparty with respect to trades entered into on the 

Platform. Notwithstanding the foregoing:

(A) FTX Trading may act as a counterparty for limited trades made for the purpose of 

liquidating fees collected on User trades; and 

(B) Affiliates of FTX Trading may execute trades on the Platform provided, however, that such 

Affiliates shall not be afforded any priority in trade execution.

Save in certain limited circumstances set out in Section 38.13 (Exception to arbitration), Section

38.12 (Arbitration) requires all Disputes to be resolved by way of legally binding arbitration on an 

individual basis only and not as a claimant or class member in a purported class or representative 

action. There is no judge or jury in arbitration and court review of an arbitration award is limited. 

The laws of some jurisdictions may limit or not permit certain provisions of the Terms, such as 

arbitration, indemnification, the exclusion of certain warranties or the limitation of certain liabilities. 

In such a case, such provisions will apply only to the maximum extent permitted by the laws of 

such jurisdictions. 

In the Terms, unless the context otherwise requires, the definitions and rules of interpretation set 

out in Schedule 1 shall apply.

1. STRUCTURE OF TERMS 

1.1 The Terms comprise:

1.1.1 the general terms and conditions set out above, in Sections 1 (Structure of 

Terms) to 38 (General), and in Schedule 1 (Definitions and Interpretation), which 

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apply generally to you, your registration and use of an Account, and your use of 

the Services ("General Terms");

1.1.2 the policies, schedules and other documents of FTX Trading and its Affiliates 

incorporated by reference into the Terms, including our Privacy Policy, Security 

Policy and Fee Schedule ("FTX Policies"); and

1.1.3 the terms and conditions set out in each Service Schedule, which shall also apply 

to the Specified Service referred to therein.

1.2 To the extent there is any conflict or inconsistency between the modules of the Terms, 

such conflict or inconsistency shall be resolved in the following order of precedence, unless 

a term or condition set out in a document of lower precedence is expressly identified as 

taking precedence over a document of higher precedence: General Terms, Service 

Schedules, Fee Schedule, Privacy Policy, Security Policy and other FTX Policies.

1.3 IMPORTANT: You acknowledge and agree that any Specified Service referred to in a 

Service Schedule shall be provided to you by the Service Provider specified in that Service 

Schedule. In such case, the Specified Service shall be provided to you on and subject to 

the Terms, with references in these General Terms to "FTX Trading" (or "we", "our" or "us") 

being read as references to the Service Provider specified in the Service Schedule, unless 

the context provides otherwise, and under no circumstances shall any other person, 

including any Affiliate of the Service Provider, be liable to you for the performance of any of 

the Service Provider's obligations under the Terms. 

2. RISK DISCLOSURES

Before beginning to use the Services, you should ensure you have read and understand 

(and you represent and warrant that you have read and understand) the following risk 

disclosures and the risk disclosures set out in the Service Schedules. You should note that 

this is not an exhaustive list of all of the risks associated with Digital Assets and the 

Services.

2.1 No advice and no reliance

2.1.1 FTX Trading does not advise on the merits of any particular transaction, trading 

risks, or tax consequences, and FTX Trading does not provide any other 

financial, investment, taxation or legal advice in connection with the Services. To 

the extent that we or our representatives provide market commentary, or any 

other information, the act of doing so is incidental to your relationship with us and 

such information should not be construed as investment or financial advice. Any 

decision by you to use the Services and transact in Digital Assets is your own 

independent decision. You represent that you are not relying on any 

communication (written or oral) by us as investment advice or as a 

recommendation to use the Services and transact in Digital Assets. FTX Trading 

will not be liable for any loss suffered by you or any third party. 

2.1.2 You accept the risk of trading Digital Assets. In entering into any transaction on 

the Platform, you represent that you have been, are, and will be solely 

responsible for making your own independent appraisal and investigations into 

the risks of such transaction and the underlying Digital Asset. You represent that 

you have sufficient knowledge, market sophistication, professional advice and 

experience to make your own evaluation of the merits and risks of any transaction 

entered into on the Platform or any underlying Digital Asset.

2.1.3 FTX Trading is not your broker, intermediary, agent, or advisor and has no 

fiduciary relationship or obligation to you in connection with any trades or other 

decisions or activities effected by you using the Services.

2.2 Digital Asset transfers and volatility

2.2.1 Trading in Digital Assets can be extremely risky and volatile. Digital Assets may 

have unique features that make them more or less likely to fluctuate in value. 

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Factors beyond FTX Trading's control, such as regulatory activity or 

unexplainable price volatility, may affect market liquidity for a particular Digital 

Asset. Blockchain networks may go offline as a result of bugs, Forks (as defined 

in Section 17 below), or other unforeseeable reasons. As a general matter, you 

should not engage in active trading on the Platform if you have limited trading 

experience or low risk tolerance. Speculating on the value of Digital Assets is 

high risk and you should never trade more than you can afford to lose.

2.2.2 Understanding Digital Assets requires advanced technical knowledge. Digital 

Assets are often described in exceedingly technical language that requires a 

comprehensive understanding of applied cryptography and computer code in 

order to appreciate the inherent risks. The listing of a Digital Asset on the 

Platform does not indicate FTX Trading's approval or disapproval of the 

underlying technology of any Digital Asset and should not be used as a substitute 

for your own understanding of the risks specific to each Digital Asset. We provide 

no warranty as to the suitability of the Digital Assets traded under the Terms and 

assume no fiduciary duty to you in connection with such use of the Services.

2.2.3 You accept all consequences of sending Digital Assets to an address off the 

Platform. Digital Asset transactions may not be reversible. Once you send Digital 

Assets to an address, you accept the risk that you may lose access to your Digital 

Assets indefinitely. For example, an address may have been entered incorrectly 

and the true owner of the address may never be discovered, or an address may 

belong to a person that will not return your Digital Assets or may return your 

Digital Assets but first require action on your part, such as verification of your 

identity or compensation. 

2.3 Supply and value of Digital Assets

2.3.1 The value of Digital Assets may be derived from the continued willingness of 

market participants to exchange Digital Assets for fiat currency and other Digital 

Assets, which may result in the permanent and total loss of value of a particular 

Digital Asset should the market for that Digital Asset disappear.

2.3.2 You acknowledge and agree that Digital Assets and/or Services (in whole or in 

part) available in one jurisdiction may not be available for trading, use or access, 

as applicable, in another.

2.4 Margin trading

2.4.1 Margin trading is HIGH RISK. As a borrower, you may sustain a total loss of 

Digital Assets, fiat currency and E-Money (as defined in Section 8.3.2 below 

(collectively, "Assets") in your Account, or owe Assets beyond what you have 

deposited in your Account. When you lend Assets to other Users, you risk the 

loss of an unpaid principal if the borrower defaults on a loan and liquidation of the 

borrower’s Account fails to raise sufficient Assets to cover the borrower’s debt.

2.5 Complex products

2.5.1 Trading of complex products, including but not limited to Futures Contracts, 

Options Contracts, and MOVE Volatility Contracts (each as defined in the Service 

Schedules) (collectively, "Complex Products"), may not be suitable for all 

Users. Complex Product trading is designed to be utilised only by sophisticated 

Users, such as active traders employing dynamic strategies. You should use 

extreme caution when trading Complex Products and only trade them if you 

understand how they work, including but not limited to the risks associated with 

margin trading, the use of leverage, the risk of shorting, and the effect of 

compounding and market volatility risks on leveraged products.

2.5.2 Complex Product trading entails significant risk, and you may feel the effects of 

losses immediately. Complex Product trading requires initial posting of collateral 

to meet initial margin requirements. If movements in the markets for a Complex 

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Product or the underlying Digital Asset decrease the value of your position in 

such Complex Product, you may be required to have or make additional collateral 

available as margin to ensure that maintenance margin requirements are met. If 

your Account is under the minimum margin requirements, your position may be 

liquidated at a loss, and you may lose all of your Assets in your Account. If there 

are any additional deficits in your Account, you will also be liable for all such 

deficits.

2.5.3 USERS WHO DO NOT UNDERSTAND LEVERAGE OR MARGIN TRADING, OR 

DO NOT INTEND TO ACTIVELY MANAGE THEIR PORTFOLIO, SHOULD NOT 

ENGAGE IN COMPLEX PRODUCT TRADING.

2.5.4 FTX TRADING AND ITS AFFILIATES DO NOT TAKE ANY RESPONSIBILITY 

WHATSOEVER FOR ANY LOSSES OR DAMAGE INCURRED AS A RESULT 

OF YOUR USE OF ANY COMPLEX PRODUCT TRADING SERVICES 

OFFERED ON THE PLATFORM OR YOUR FAILURE TO UNDERSTAND THE 

RISKS ASSOCIATED WITH COMPLEX PRODUCT TRADING.

2.6 Blacklisted addresses and forfeited Assets

2.6.1 FTX Trading reserves the right to "blacklist" certain addresses and freeze 

associated Assets (temporarily or permanently) that it determines, in its sole 

discretion, are associated with illegal activity or activity that otherwise violates the 

Terms ("Blacklisted Addresses"). In the event that you send Assets to a 

Blacklisted Address or receive Assets from a Blacklisted Address, FTX Trading 

may freeze such Assets and take steps to terminate your Account.

2.6.2 In certain circumstances, FTX Trading may deem it necessary to report such 

suspected illegal activity to applicable law enforcement agencies and other 

Regulatory Authorities, and you may forfeit any rights associated with your 

Assets, including the ability to redeem or exchange your Digital Assets for other 

Digital Assets or fiat currency. FTX Trading may also freeze Assets held in your 

Account in the event that we receive a related order or request from a legal or 

Regulatory Authority.

2.7 Software protocols and operational challenges

2.7.1 The software protocols that underlie Digital Assets are typically open source 

projects or are otherwise operated by third parties, which means that: (i) the 

operations, functionalities, development and control of such Digital Assets and 

their underlying networks are outside of FTX Trading's control; and (ii) such 

software protocols are subject to sudden and dramatic changes that might have a 

significant impact on the availability, usability or value of a given Digital Asset.

2.7.2 You are aware of and accept the risk of operational challenges that may impact 

the Services. The Platform may experience sophisticated cyber-attacks, 

unexpected surges in activity or other operational or technical difficulties that may 

cause interruptions to the Services. You understand that the Services may 

experience operational issues that lead to delays. You agree to accept the risk of 

transaction failure resulting from unanticipated or heightened technical difficulties, 

including those resulting from sophisticated attacks. You agree not to hold FTX 

Trading liable for any related losses.

2.7.3 You understand that the technology underlying Digital Assets is subject to change 

at any time, and such changes may affect your Digital Assets stored on the 

Platform. You are fully responsible for monitoring such technological changes and 

understanding their consequences for your Digital Assets. 

2.7.4 Users conduct all trading on their own account and FTX Trading does not take 

any responsibility for any loss or damage incurred as a result of your use of any 

Services or your failure to understand the risks associated with Digital Assets use 

generally or your use of our Services.

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2.7.5 Digital Assets depend on the availability and reliability of power, connectivity, and 

hardware. Interruption or failure of any of these things may disrupt the networks 

on which the Digital Assets rely or your ability to access or transact in Digital 

Assets.

2.8 Compliance

You are responsible for complying with all Applicable Laws. You agree that FTX Trading is 

not responsible for determining whether or which laws and regulations may apply to your 

transactions, including but not limited to tax laws and regulations. You are solely 

responsible for reporting and paying any taxes arising from your use of the Services.

2.9 Legislative and regulatory changes

Legislative and regulatory changes or actions at the domestic or international level may 

adversely affect the use, transfer, ability to transact in, and value of Digital Assets, or your 

access to, and our ability to provide, the Services. You acknowledge and accept the risks 

that such changes may bring and that FTX Trading is not liable for any adverse impact that 

that you may suffer as a result.

2.10 No deposit protection

Neither Digital Assets nor any fiat currency or E-Money held in your Account is eligible for 

any public or private deposit insurance protection.

2.11 Digital Asset Distributions not supported

Certain Digital Assets are built on protocols that support Digital Asset Distributions (as 

defined in Section 17.4 below), including, but not limited to, Forks (as defined in Section 

17.1 below), Staking Rewards (as defined in Section 17.4 below) and Airdrops (as defined 

in Section 17.4 below). FTX Trading is not obligated to support any such Digital Asset 

Distributions for Users. If you hold these Digital Assets in your Account, you thereby forfeit 

the ability to claim any Digital Asset Distributions from FTX Trading. If you hold Digital 

Assets with proof-of-stake or delegated proof-of-stake consensus algorithms, FTX Trading 

may in its sole discretion stake these Digital Assets without any obligation to distribute 

Staking Rewards to you. Staking may subject your Digital Assets to additional risks and 

FTX Trading is not liable for losses you may incur related to staking.

2.12 Reliance on third parties

Your use of the Services and the value of certain Digital Assets may rely on the acts of 

third parties or the fulfilment of related obligations by third parties. FTX Trading is not 

responsible for the acts or omissions of such third parties.

3. APPLICABLE LAWS AND REGULATIONS

3.1 Compliance with Applicable Laws

3.1.1 You agree and understand that by opening an Account and using the Services in 

any capacity, you shall act in compliance with all Applicable Laws. Failure to do 

so may result in the suspension of your ability to use the Services or the closure 

of your Account.

3.1.2 Without limitation to the above, your access to and use of your Account and the 

Services, and the receipt of any fee discounts and rebates, is subject to your 

continued compliance with all Applicable Laws, including the rules and directions 

of any applicable Regulatory Authority and, without limitation, all applicable tax, 

anti-money laundering ("AML") and counter-terrorist financing ("CTF") laws and 

regulations.

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3.2 AML and CTF procedures

Our AML and CTF procedures are guided by all applicable rules and regulations regarding 

AML and CTF. These standards are designed to prevent the use of the Platform for money 

laundering or terrorist financing activities. We take compliance very seriously and it is our 

policy to take the necessary steps that we believe appropriate to prohibit fraudulent 

transactions, report suspicious activities, and actively engage in the prevention of money 

laundering and terrorist financing, any related acts that facilitate money laundering, terrorist 

financing or any other financial crimes.

3.3 Export controls

3.3.1 The Services are subject to all applicable export control restrictions and, by using 

the Services, you represent that your actions are not in violation of such export 

control restrictions. Without limiting the foregoing, you may not use the Services 

if:

(A) you are in a prohibited jurisdiction as set forth at Location Restrictions

("Restricted Territories"); 

(B) you are a member of any sanctions list or equivalent maintained by the 

United States government, the United Kingdom government, the 

European Union, the Singapore government, or The Bahamas 

government ("Restricted Persons"); 

(C) you intend to transact with any Restricted Territories or Restricted 

Persons; 

(D) you are located, incorporated or otherwise established in, or a citizen or 

resident of a jurisdiction where it would be illegal under Applicable Law 

for you (by reason of your nationality, domicile, citizenship, residence or 

otherwise) to access or use the Services; or 

(E) the publication or availability of the Services in the jurisdiction in which 

you are based is prohibited or contrary to local law or regulation or could 

subject FTX Trading to any local registration or licensing requirements.

3.3.2 We may, in our sole discretion, implement controls to restrict access to and use 

of the Services in any of the Restricted Territories or in any of the circumstances 

referred to in Section 3.3.1 above. If we determine that you are accessing or 

using the Services from any Restricted Territory, or any of the circumstances 

referred to in Section 3.3.1 above apply, we may suspend your ability to use the 

Services or close your Account at our discretion.

4. ELIGIBILITY

4.1 In order to be eligible to open an Account or use the Services (and to enter into the Terms), 

you must meet (and you represent and warrant that you do meet), the following eligibility 

criteria:

4.1.1 If you are an individual, you must be at least 18 years of age, have the capacity to 

accept the Terms, and not have been previously suspended or removed from 

access to the Services or any other service or product offered by FTX Trading or 

any of its Affiliates, and are otherwise eligible to use the Services under 

Applicable Law.

4.1.2 If you are registering to use the Services on behalf of a legal entity, then:

(A) you must be duly authorised by such legal entity to act on its behalf for 

the purpose of entering into the Terms;

(B) the legal entity must be duly organised and validly existing under the laws 

of the jurisdiction of its organisation; and

(C) the legal entity must not have been (and each of its Affiliates must not 

have been) previously suspended or removed from access to the 

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Services or any other service or product offered by FTX Trading or any of 

its Affiliates and must be otherwise eligible to use the Services under 

Applicable Law.

4.1.3 You have not: violated; been fined, debarred, sanctioned, the subject of economic 

sanctions-related restrictions, or otherwise penalised under; received any oral or 

written notice from any government concerning actual or possible violation by you 

under; or received any other report that you are the subject or target of sanctions, 

restrictions, penalties, or enforcement action or investigation under, any 

Applicable Law (including but not limited to AML, CTF, anti-corruption, or 

economic sanctions laws).

4.1.4 You do not have your registered office or place of residence in the United States 

of America or any Restricted Territory.

4.1.5 You are not a Restricted Person nor are you a resident of a Restricted Territory; 

and 

4.1.6 You will not be using the Services for any illegal activity including, but not limited 

to, those Restricted Activities listed in Section 13 below.

4.2 If we determine that you do not fulfil any of the above criteria, then we may suspend your 

ability to use the Services or close your Account at our discretion.

5. REGISTRATION PROCESS; IDENTITY VERIFICATION

5.1 When registering your Account, you must provide complete, accurate, up-to-date and not 

misleading information for all required elements on the registration page, including your full 

legal name. You also agree to provide us, when registering an Account and on an ongoing 

basis, with any additional information we request for the purposes of identity verification 

and the detection of money laundering, terrorist financing, fraud, or any other financial 

crime, including without limitation a copy of your government issued photo ID or evidence 

of residency such as a lease or utility bill. You permit us to keep a record of such 

information and authorise us to make any enquiries, directly or through third parties that we 

consider necessary to verify your identity or protect you and/or us against fraud or other 

financial crime, and to take any action we reasonably deem necessary based on the results 

of such inquiries. When we carry out these enquiries, you acknowledge and agree that 

your personal information may be disclosed to credit reference and fraud prevention or 

financial crime agencies and that these agencies may respond to our inquiries in full.

5.2 In certain circumstances, we may require you to submit additional information about 

yourself, your business, your source of wealth, or your transactions, provide records, and 

complete other verification steps (such process, "Enhanced Due Diligence"). 

5.3 You represent and warrant that any and all information provided to us in connection with 

registering your Account, using the Services, pursuant to the Terms or otherwise is 

complete, accurate, up-to-date and not misleading in any respect. If any such information 

changes, it is your obligation to update such information as soon as possible and provide 

such updates to us. 

5.4 Your access to the Services and the limits that apply to your use of the Services may be 

altered as a result of information collected about you on an ongoing basis.

5.5 If any (or we suspect that any) of the information that you have provided to us is not 

complete, accurate, up-to-date or misleading in any respect, or you fail to provide updates 

to any information that you have provided to us to ensure that it is complete, accurate, upto-date and not misleading in any respect on a timely basis, we may suspend your ability to 

use the Services or close your Account at our discretion.

5.6 We reserve the right to maintain your Account registration information after you close your 

Account for business and regulatory compliance purposes, subject to Applicable Laws.

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6. YOUR ACCOUNT; SECURITY OF USER INFORMATION

6.1 You may access your Account (and the Services) directly via the Site, via a Mobile 

Application or by such other mode of access (including but not limited to through the APIs) 

as FTX Trading may prescribe from time to time, using the account names, User IDs, 

passwords, and other security features ("User Credentials and Security Passwords") 

made available to you by FTX Trading for the purposes of enabling you to access your 

Account (and the Services). You are responsible for maintaining the confidentiality and 

security of any and all User Credentials and Security Passwords, which includes the 

enabling of all relevant security features. You are responsible for keeping your email 

address up to date in your Account profile.

6.2 You are only permitted to access your Account using your own User Credentials and 

Security Passwords. You must ensure that your Account is not used by any other third 

party and you must not share your User Credentials and Security Passwords with any third 

party. You are solely responsible for all activity on your Account.

6.3 You agree to notify FTX Trading immediately if you become aware of any breach of 

security, loss, theft or unauthorised use of your User Credentials and Security Passwords, 

or unauthorised use of the Services via your Account, or any other breach of security 

regarding the Services. FTX Trading will not be liable for any loss or damage arising from 

your failure to protect your Account or your User information. It is important that you 

regularly check your Account balance and your transaction history to ensure any 

unauthorised transactions or incorrect transactions are identified and notified to us at the 

earliest possible opportunity.

6.4 FTX Trading reserves the right to suspend your ability to use the Services or close your 

Account if we suspect that the person logged into your Account is not you or we become 

aware of or suspect that there has been any breach of security, loss, theft or unauthorised 

use of your User Credentials and Security Passwords.

6.5 In order to access your Account (and the Services) you must have the necessary 

equipment (such as a computer or smartphone) and access to the Internet. You are solely 

responsible for your own hardware used to access the Services and are solely liable for the 

integrity and proper storage of any data associated with the Services that is stored on your 

own hardware. You are responsible for taking appropriate action to protect your hardware 

and data from viruses and malicious software, and any inappropriate material. Except as 

provided by Applicable Law, you are solely responsible for backing up and maintaining 

duplicate copies of any information you store or transfer through our Services. Neither FTX 

Trading nor any other Indemnified Party shall be liable to you: (i) in the event that your 

hardware fails, is damaged or destroyed or any records or data stored on your hardware 

are corrupted or lost for any reason; (ii) for any damage or interruptions caused by any 

computer viruses, spyware, or other malware that may affect your computer or other 

equipment, or any phishing, spoofing, or other attack; or (iii) for your use of the Internet to 

connect to the Services or any technical problems, system failures, malfunctions, 

communication line failures, high internet traffic or demand, related issues, security

breaches or any similar technical problems or defects experienced.

7. ORDER BOOK AND CONVERT

7.1 FTX Trading operates Order Books on which Orders may be placed by Users to be 

matched with the Orders of other Users. The Order types that FTX Trading may offer from 

time to time in its sole discretion include but are not limited to “market” ,”limit”, "stop-loss 

limit", "stop-loss market", "trailing stop" and "take profit limit" orders. FTX Trading may 

issue trading rules from time to time that apply to Orders placed on the Order Book, in 

addition to these General Terms.

7.2 The Convert function on the Platform also allows you to submit instructions ("Convert

Instructions") to exchange (buy or sell) one spot Asset for another. Each Convert 

transaction is subject to the applicable Exchange Rate quoted for the given transaction and 

the applicable time limts for such quote. The "Exchange Rate" means the price of a given 

Digital Asset as quoted on your "Wallet" page on the Site or any Mobile Application. The 

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Exchange Rate is stated either as a "Buy Price" or as a "Sell Price", which is the price at 

which you may buy or sell the Asset, respectively.

7.3 The Exchange Rate quoted will depend on market conditions, and you are under no 

obligation to execute a Convert transaction at any Exchange Rate quoted to you. You 

acknowledge that the Buy Price Exchange Rate may not be the same as the Sell Price 

Exchange Rate at any given time, and that there may be a ‘spread’ to the quoted 

Exchange Rate. You agree to accept the Exchange Rate when you authorise a Convert 

transaction. 

7.4 We do not guarantee the availability of any Exchange Rate and we do not guarantee that 

you will be able to buy and/or sell your Assets using Convert or on the Order Book at any 

particular price or time.

7.5 You are solely responsible for accurately entering any Order or Convert Instruction, 

including but not limited to all the necessary information in order to enable us to carry out 

any Order or Convert Instruction. FTX Trading is not obliged to verify the accuracy or 

completeness of any such information, Order or Convert Instruction. 

7.6 You agree that any Order or Convert Instruction received or undertaken through your 

Account shall be deemed to be final and conclusive, and that FTX Trading may act upon 

such Order or Convert Instruction. We shall not be under any obligation to verify the 

identity or authority of any person giving any Order or Convert Instruction or the 

authenticity of such Order or Convert Instruction. 

7.7 Your Orders and Convert Instructions shall be irrevocable and unconditional and shall be 

binding on you, and such Orders and Convert Instructions may be acted or relied upon by 

us irrespective of any other circumstances. As such, once you give any Order or Convert 

Instruction, you have no right to rescind or withdraw such Order or Convert Instruction

without our written consent.

7.8 Each of your Orders and Convert Instructions shall not be considered to be received by 

FTX Trading unless and until it has been received by FTX Trading’s server. FTX Trading's

records of all Orders and Convert Instruction shall be conclusive and binding on you for all 

purposes.

7.9 Under no circumstances shall any of the Indemnified Parties be responsible or liable to you 

for any Losses suffered or incurred by you or any other person arising from any of the 

Indemnified Parties relying or acting upon any Order or Convert Instruction which is given 

or purported to be given by you, regardless of the circumstances prevailing at the time of 

such Order or Convert Instruction. 

7.10 You hereby authorise FTX Trading to credit or debit (or provide settlement information to 

third parties for the purposes of the third party crediting or debiting) your Assets from your 

Account in accordance with your Orders and Convert Instructions. We reserve the right not 

to effect any transaction if you have insufficient Assets in your Account. 

8. ACCOUNT FUNDING

8.1 Funding - General

8.1.1 In order to fund your Account and begin transacting in Digital Assets using the 

Platform, you must first procure Digital Assets (or deposit Digital Assets that you 

already own into your Account) and/or load fiat currency into your Account. 

8.1.2 You should be aware that FTX Trading: (i) may not support the loading into 

and/or storing of fiat currency in your Account in all jurisdictions; and (ii) does not 

support the use of all fiat currencies. A partial list of fiat currencies supported by 

FTX Trading can be found here. This list may be amended from time to time by 

FTX Trading at its sole discretion.

8.1.3 Any available Assets held in your Account is available to be locked and used as 

collateral for margin trading, or to fund trades, in relation to any Services or part 

thereof offered through the Platform by FTX Trading or its Affiliates. 

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8.2 Digital Assets 

8.2.1 The Platform supports deposits and withdrawals of certain Digital Assets, 

including certain U.S. Dollar-pegged stablecoins (each a "USD Stablecoin"). 

You may deposit Digital Assets that you already own into your Account by 

generating an address within your Account and sending your Digital Assets to 

such address, after which they should appear in your Account balance (USD 

Stablecoins will appear in your "USD Stablecoins (USD)" balance). 

8.2.2 You may purchase Digital Assets in exchange for certain supported fiat 

currencies (depending on your location) by linking a valid payment method to 

your Account. In such circumstances, you authorise us to debit the relevant 

amount of fiat currency using your selected payment method(s) to complete your 

purchase.

8.2.3 The Platform enables you to exchange one Digital Asset for another Digital Asset, 

send Digital Assets to and receive Digital Assets from other Users of the 

Services, or third parties outside of the Platform (where permitted by FTX Trading 

in its sole discretion). 

8.2.4 You may sell Digital Assets in exchange for certain supported fiat currencies 

(depending on your location). In such circumstances, you authorise us to debit 

your Account and to send instructions to credit your selected payment method(s) 

in settlement of sell transactions.

8.2.5 FTX Trading makes no representations or warranties regarding the amount of 

time, transaction fees or other requirements that may be required to complete the 

transfer of your Digital Assets to or from a third party wallet or other source and 

for said Digital Assets to become available in your Account.

8.2.6 All Digital Assets are held in your Account on the following basis:

(A) Title to your Digital Assets shall at all times remain with you and shall not 

transfer to FTX Trading. As the owner of Digital Assets in your Account, 

you shall bear all risk of loss of such Digital Assets. FTX Trading shall 

have no liability for fluctuations in the fiat currency value of Digital Assets 

held in your Account.

(B) None of the Digital Assets in your Account are the property of, or shall or 

may be loaned to, FTX Trading; FTX Trading does not represent or treat 

Digital Assets in User’s Accounts as belonging to FTX Trading. 

(C) You control the Digital Assets held in your Account. At any time, subject 

to outages, downtime, and other applicable policies (including the 

Terms), you may withdraw your Digital Assets by sending them to a 

different blockchain address controlled by you or a third party.

8.2.7 FTX Trading is under no obligation to issue any replacement Digital Asset in the 

event that any Digital Asset, password or private key is lost, stolen, 

malfunctioning, destroyed or otherwise inaccessible.

8.2.8 It is your responsibility to ensure that you send all Digital Assets, to the correct 

address provided for that particular Digital Asset, including with respect to any 

Digital Assets that you send to the Platform. If you send a Digital Asset to an 

address that does not correspond to that exact Digital Asset (such as an address 

not associated with your Account or the specific Digital Asset sent), such Digital 

Asset may be lost forever. By sending any Digital Assets to the Platform, you 

attest that you will only send a supported Digital Asset to the Platform wallet 

address provided to you. For example, if you select an Ethereum Platform wallet 

address to receive funds, you attest that you are initiating an inbound transfer of 

Ethereum alone, and not any other forms of Digital Assets. You agree that FTX 

Trading incurs no obligation whatsoever with regards to sending unsupported 

Digital Assets to an address provided to you on the Platform. Similarly, if you 

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send a Digital Asset from your Account to an external address that does not 

correspond to that exact Digital Asset, such Digital Asset may be lost forever.

8.2.9 You assume all liability for any Losses incurred as a result of sending Digital 

Assets to an incorrect address (such as typos, errors, copy-paste attacks, or an 

address not associated with your Account, or an address not associated with the 

specific Digital Asset). You are solely liable for verifying the accuracy of any 

external wallet address, and the identity of the recipient. All outbound transfers of 

Digital Assets cannot be reversed once they are broadcast to the underlying 

blockchain network. FTX Trading does not control any blockchain network and 

cannot guarantee that any transfer will be confirmed or transferred successfully 

by the network. FTX Trading is not responsible for any losses or for taking any 

actions to attempt to recover any lost, stolen, misdirected or irrecoverable Digital 

Assets. If the Digital Assets are recoverable, we may in our sole discretion 

attempt to recover them, but such recovery efforts are in no way guaranteed. 

Please be aware that if you attempt to deposit ETH to your Account by sending it 

via a smart contract, your ETH may not be automatically credited, and may take 

time to recover, and may not be recovered at all.

8.2.10 When you elect to transfer Digital Assets from your Account to a third party wallet 

address or other location, it is always possible that the party administering the 

new location may reject your transfer or that the transfer may fail due to technical 

or other issues affecting the Platform. You agree that you shall not hold FTX 

Trading liable for any damages arising from a rejected or failed transfer. 

8.2.11 You hereby represent and warrant to us that any Digital Assets used by you in 

connection with the Services (including any Digital Assets used to fund your 

Account) are either owned by you or that you are validly authorised to carry out 

transactions using such Digital Assets, and that all transactions initiated with your 

Account are for your own Account and not on behalf of any other person.

8.2.12 It is your responsibility entirely to provide us with correct details of any withdrawal 

address. We accept no liability resulting in you or any third party not receiving 

Digital Assets withdrawn by you due to you providing incorrect, erroneous, 

incompatible or out-of-date details.

8.3 Fiat currency

8.3.1 Where specified on the Site or in a Service Schedule, and depending on your 

location, the Platform may support various fiat currencies for deposit, withdrawal, 

and/or trading, using wire transfers, credit cards, or other appropriate methods. 

8.3.2 Once we receive fiat currency that you load into your Account, we may issue you 

with an equivalent amount of electronic money ("E-Money"), denominated in the 

relevant fiat currency, which represents the fiat currency that you have loaded. 

This amount will be displayed in your Account. 

8.3.3 E-MONEY IS NOT LEGAL TENDER. FTX TRADING IS NOT A DEPOSITORY 

INSTITUTION AND YOUR E-MONEY IS NOT A DEPOSIT OR INVESTMENT 

ACCOUNT. YOUR E-MONEY ACCOUNT IS NOT INSURED BY ANY PUBLIC 

OR PRIVATE DEPOSIT INSURANCE AGENCY.

8.3.4 E-Money held in your Account will not earn any interest. Your Account may hold 

E-Money denominated in different currencies and we will show the E-Money 

balance for each currency that you hold. 

8.3.5 You may purchase Digital Assets by using E-Money credited to your Account 

(depending on your location). To carry out a Digital Asset purchase using EMoney, you must follow the relevant instructions on the Site. You authorise us to 

debit E-Money from your Account to complete your purchase. Although we will 

attempt to deliver Digital Assets to you as promptly as possible, E-Money may be 

debited from your Account before Digital Assets are delivered to your Account.

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8.3.6 You may sell Digital Assets in exchange for certain fiat currencies (depending on 

your location). To carry out a Digital Asset sale, you must follow the relevant 

instructions on the Site. You authorise us to debit Digital Assets from your 

Account and send instructions to credit your Account with the relevant amount of 

fiat currency. Once we receive the fiat currency, we will issue you with an 

equivalent amount of E-Money denominated in the relevant fiat currency. 

8.3.7 You may redeem all or part of any E-Money held in your Account at any time

subject to outages, downtime, and other applicable policies (including the Terms),

by selecting the relevant option in the Site and following the instructions. Unless 

agreed otherwise, funds will be transferred to the bank account you have 

registered with us. You hereby represent and warrant that this bank account is 

your own, and that you have full control over it. It is your responsibility entirely to 

provide us with correct details of your withdrawal account. We accept no liability 

resulting in you not receiving any amounts withdrawn by you due to you providing 

incorrect or out-of-date details.

8.3.8 If the Terms are terminated, we may redeem any E-Money remaining in your 

Account and attempt to transfer the equivalent amount of fiat currency to the bank 

account you have registered with us. Prior to redeeming E-Money from your 

Account, we may conduct checks for the purposes of preventing fraud, money 

laundering, terrorist financing and other financial crimes, and as required by 

Applicable Law. This may mean you are prevented or delayed from withdrawing 

E-Money until those checks are completed to our reasonable satisfaction in order 

to comply with our regulatory requirements.

9. UNCLAIMED OR ABANDONED PROPERTY

9.1 If FTX Trading is holding Assets in your Account ("Unclaimed or Abandoned Property"), 

and we are unable to contact you and have no record of your use of the Services for a 

prolonged period of time or your Account has been closed, Applicable Laws may require us 

to report such Unclaimed or Abandoned Property as unclaimed property to the applicable 

jurisdiction. If this occurs, FTX Trading will try to locate you using the details shown in our 

records in relation to your Account, but if FTX Trading is unable to locate you, we may be 

required to deliver any such Unclaimed or Abandoned Property to the applicable 

jurisdiction as unclaimed property. FTX Trading reserves the right to deduct a dormancy 

fee or other administrative charges from such Unclaimed or Abandoned Property, as 

permitted by Applicable Laws. 

9.2 If FTX Trading is holding Unclaimed or Abandoned Property, and we are unable to contact 

you and have no record of your use of the Services for a prolonged period of time or your 

Account has been closed, and Applicable Laws do not require us to report such Unclaimed 

or Abandoned Property as unclaimed property to the applicable jurisdiction, then you 

acknowledge and agree that your Account may be transferred to FTX Trading, or an 

Affiliate of FTX Trading, as Trustee of the Unclaimed or Abandoned Property. FTX Trading 

or the Affiliate of FTX Trading (as applicable), as Trustee, will hold the Unclaimed or 

Abandoned Property on your behalf and shall, on demand, repay to you the Unclaimed or 

Abandoned Property subject to your payment of any dormancy fee or other administrative 

charges that the Trustee may deduct from the Unclaimed or Abandoned Property. If no 

such demand is made by you, the Trustee may pay the Unclaimed or Abandoned Property 

into court in the applicable jurisdiction in accordance with Applicable Laws. 

9.3 If we receive legal documentation confirming your death or other information leading us to 

believe you have died, we will freeze your Account and during this time, no transactions 

may be completed until: your designated fiduciary has opened a new Account, as further 

described below, and the entirety of your Account has been transferred to such new 

account, or (ii) we have received proof in a form satisfactory to us that you have not died. If 

we have reason to believe you may have died but we do not have proof of your death in a 

form satisfactory to us, you authorise us to make enquiries, whether directly or through 

third parties, that we consider necessary to ascertain whether you have died. Upon receipt 

by us of proof satisfactory to us that you have died, the fiduciary you have designated in a 

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valid will or similar testamentary document will be required to open a new Account. If you 

have not designated a fiduciary, then we reserve the right to treat as your fiduciary any 

person entitled to inherit your Account, as determined by us upon receipt and review of the 

documentation we, in our sole and absolute discretion, deem necessary or appropriate, 

including (but not limited to) a will, a living trust or other similar documentation, or (ii) 

require an order designating a fiduciary from a court having competent jurisdiction over 

your estate. In the event we determine, in our sole and absolute discretion, that there is 

uncertainty regarding the validity of the fiduciary designation, we reserve the right to 

require an order resolving such issue from a court of competent jurisdiction before taking 

any action relating to your Account. Pursuant to the above, the opening of a new Account 

by a designated fiduciary is mandatory following the death of an Account owner, and you 

hereby agree that your fiduciary will be required to open a new Account in order to gain 

access to the contents of your Account.

10. DEBIT ACCOUNT BALANCE

10.1 If at any time your Account has a debit balance, you agree to pay us: (i) the applicable fees 

set out in the Fee Schedule; (ii) the total debit balance; and (iii) such other amounts 

specified in the Terms.

10.2 If you fail to pay such amounts, we may suspend your ability to use the Services or close 

your Account. We also reserve the right to debit your Account accordingly and/or to 

withhold amounts from fiat currency and Digital Assets that you may transfer to your 

Account.

10.3 If, after a demand is made by FTX Trading, you have not made payment of the outstanding 

debit balance by the time stated in the demand, then:

10.3.1 you authorise us to sell any Digital Assets or redeem any fiat currency or EMoney in your Account to recover the outstanding debit balance; 

10.3.2 you agree to indemnify us and each other Indemnified Party against all Losses 

that we suffer or incur as a result of your not paying the outstanding debit 

balance; and

10.3.3 you will be liable for all costs which we incur in relation to instructing a collection 

agency, law firm or other third party to assist with and advise on the collection of 

such outstanding debit balance (where applicable).

11. THIRD PARTY PERMISSIONS TO CONNECT TO OR ACCESS YOUR ACCOUNT

If you grant express permission to a third party to connect to your Account, either through 

the third party's product or through the Platform, you acknowledge that granting permission 

to a third party to take specific actions on your behalf does not relieve you of any of your 

responsibilities under the Terms. Further, you acknowledge and agree that you will not hold 

FTX Trading responsible for, and will indemnify FTX Trading from, any liability arising from 

the actions or inactions of such third party in connection with the permissions you grant.

12. ACCOUNT SUSPENSION AND CLOSURE; SERVICE SUSPENSION AND 

TERMINATION

12.1 FTX Trading may, in its sole and absolute discretion and at any time, without liability to you 

or any third party: 

12.1.1 refuse to let you open an Account, suspend your Account, or terminate your 

Account;

12.1.2 decline to process any instruction or Order submitted by you; and/or

12.1.3 limit, suspend or terminate your use of one or more, or part of, the Services.

12.2 Such actions will not relieve you from your obligations pursuant to the Terms.

12.3 Such actions may be taken as a result of a number of factors, including without limitation:

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12.3.1 as a result of account inactivity, your failure to respond to customer support 

requests, our failure or inability to positively identify you;

12.3.2 as a result of a court order or your violation of Applicable Laws or the Terms; or

12.3.3 where we believe that a transaction is suspicious or may involve fraud, money 

laundering, terrorist financing or other misconduct.

12.4 If you do not agree with any actions taken by us under Section 12.1, then your sole and 

exclusive remedy is to terminate your use of the Services and close your Account. You 

agree that neither we nor any other Indemnified Party shall be liable to you or any third 

party for any Losses suffered as a result of any actions taken by us under Section 12.1. 

12.5 Without limitation to the foregoing, we may temporarily suspend access to your Account in 

the event that a technical problem causes a system outage or Account errors until the 

problem is resolved.

12.6 Where required by Applicable Laws, we will notify you promptly if we have suspended 

processing your Orders or Convert Instructions and, if possible, provide our reasons for 

doing so and anything you can do to correct or remedy the matters giving rise to such 

suspension.

12.7 You may close your Account or terminate your access to and use of the Services at any 

time upon request to FTX Trading, in accordance with the Terms. In order to close your 

Account or terminate your access to and use of the Services, you should contact us for 

assistance. You may not close an Account if we determine, in our sole discretion, that such 

closure is being performed in an effort to evade a legal or regulatory investigation or to 

avoid paying any amounts otherwise due to FTX Trading or its Affiliates. 

12.8 We encourage you to withdraw any remaining balance of Assets prior to issuing a request 

to close your Account. We reserve the right to restrict or refuse to permit withdrawals from 

your Account if:

12.8.1 your Account has otherwise been suspended or closed by us in accordance with 

the Terms; 

12.8.2 to do so would be prohibited by Applicable Laws or court order, or we have 

determined that the Assets in your Account were obtained fraudulently; or 

12.8.3 you have not completed the required identity verification procedure. You can 

check whether or not your identity has been verified by reviewing your verification 

status under the "Settings" section of your Account. 

12.9 Upon closure or suspension of your Account, you authorise FTX Trading to cancel or 

suspend pending transactions.

12.10 Notwithstanding that you or FTX Trading closes or deactivates your Account or terminates 

or suspends your access to and use of any Services, or the termination or expiry of the 

Terms, you shall remain liable for all activity conducted with or in connection with your 

Account while it was open, and for all amounts due in connection with such activity. 

13. RESTRICTED ACTIVITIES

In connection with your use of the Services, you agree that you will not:

13.1.1 violate or assist any party in violating any Applicable Laws or any rule of any selfregulatory or similar organisation of which you are or are required to be a 

member through your use of the Services;

13.1.2 provide false, inaccurate, incomplete, out-of-date or misleading information;

13.1.3 infringe upon FTX Trading's or any third party's copyrights, patents, trademarks, 

or other intellectual property rights;

13.1.4 engage in any illegal activity, including without limitation illegal gambling, money 

laundering, fraud, blackmail, extortion, ransoming data, the financing of terrorism, 

other violent activities or any prohibited market practices;

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13.1.5 distribute unsolicited or unauthorised advertising or promotional material, written 

media releases, public announcements and public disclosures, junk mail, spam or 

chain letters;

13.1.6 use a web crawler or similar technique to access our Services or to extract data;

13.1.7 reverse engineer or disassemble any aspect of the Site, the API, or the Services 

in an effort to access any source code, underlying ideas and concepts and 

algorithms;

13.1.8 perform any unauthorised vulnerability, penetration or similar testing on the API 

or Services;

13.1.9 take any action that imposes an unreasonable or disproportionately large load on 

our infrastructure, or detrimentally interfere with, intercept, or expropriate any 

system, data or information;

13.1.10 transmit or upload any material to the Site that contains viruses, Trojan horses, 

worms, or any other harmful or deleterious programs;

13.1.11 otherwise attempt to gain unauthorised access to or use of the Site, the API,

other FTX Accounts, computer systems, or networks connected to the Site, 

through password mining or any other means;

13.1.12 transfer any rights granted to you under the Terms;

13.1.13 engage in any activity which, in our reasonable opinion, amounts to or may 

amount to market abuse including without limitation the carrying out of fictitious 

transactions or wash trades, front running or engaging in disorderly market 

conduct;

13.1.14 engage in any behaviour which is unlawful, violates the Terms, or is otherwise 

deemed unacceptable by FTX Trading in its sole discretion; or

13.1.15 assist, facilitate or encourage any third party in undertaking any activity otherwise 

prohibited by the Terms.

14. ELECTRONIC TRADING TERMS

14.1 FTX Trading may, in its sole discretion, choose to discontinue support for a currently listed 

or supported Digital Asset at any time, including without limitation where there are changes 

in the characteristics of such Digital Asset.

14.2 A transaction on the Platform may fail for several reasons including, without limitation, as a 

result of a change in prices, insufficient margin, or unanticipated technical difficulties. FTX 

Trading makes no representation or warranty that any transaction will be executed 

properly. Under no circumstances are we liable for any loss or injury suffered by a failure of 

a transaction to complete properly or in a timely manner. Further, we are in no way 

responsible for notifying you of a transaction failure, although you are able to see any such 

failures via your Account. You have full responsibility for determining and inquiring into the 

failure of any transaction which you initiate.

14.3 In the event that you receive any data, information, or software through our Services other 

than that which you are entitled to receive pursuant to the Terms, you will immediately 

notify us and will not use, in any way whatsoever, such data, information or software. If you 

request a withdrawal of Digital Assets and we cannot comply with it without closing some 

part of your open positions, we will not comply with the request until you have closed 

sufficient positions to allow you to make the withdrawal.

14.4 We may refuse to execute a trade or impose trade amount limits or restrictions at any time, 

in our sole discretion without notice. Specifically, we reserve the right to refuse to process, 

and the right to cancel or reverse, any transaction, as well as to revoke access to a User's 

deposit address on the Platform, where we suspect the transaction involves money 

laundering, terrorist financing, fraud, or any other type of crime or if we suspect the 

transaction relates to a prohibited use as stated in the Terms. FTX Trading reserves the 

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right to halt deposit activity at our sole discretion. A User may not change, withdraw, or 

cancel its authorisation to make a transaction, except with respect to partially filled Orders.

14.5 FTX Trading may correct, reverse, or cancel any trade impacted by an error in processing 

a User's transaction or otherwise. The User's remedy in the event of an error will be limited 

to seeking to cancel an Order or Convert Instruction or obtaining a refund of any amounts 

charged to the User. FTX Trading cannot guarantee such cancellations or refunds will 

always be possible.

14.6 Orders placed on the Order Book may be partially filled or may be filled by one or more

Orders placed on the Order Book by other Users, depending on the trading activity on the 

Order Book at the time an Order is placed. 

14.7 The Digital Assets available for purchase through the Platform may be subject to high or 

low transaction volume, liquidity, and volatility at any time for potentially extended periods. 

You acknowledge that while FTX Trading uses commercially reasonable methods to 

provide Exchange Rate information to you through the Platform, the Exchange Rate 

information we provide may differ from prevailing exchange rates made available by third 

parties. Similarly, the actual market rate at the time of your trade may be different from the 

indicated Exchange Rate. You agree that you assume all risks and potential losses 

associated with price fluctuations or differences in any actual versus indicated Exchange 

Rates.

15. STAKING

15.1 When you hold Digital Assets on the Platform you may be given the option to "stake" these 

assets via staking services provided by FTX Trading or its Affiliates. You are not required 

to stake any Digital Assets and you can opt out of any staking services (subject to 

applicable early withdrawal limits or penalties as specified on the staking page for such 

Digital Asset). If you stake your Digital Assets, FTX Trading or its Affiliate will facilitate the 

staking of such Digital Assets on your behalf. You agree and acknowledge that you have 

no right to any staking rewards whatsoever. FTX TRADING DOES NOT GUARANTEE 

THAT YOU WILL RECEIVE ANY STAKING REWARDS OVER TIME, INCLUDING THE 

DISPLAYED STAKING REWARDS RATES.

15.2 The tax treatment of staking Digital Assets is uncertain, and it is your responsibility to 

determine what taxes, if any, arise from the transactions. You are solely responsible for 

reporting and paying any applicable taxes arising from staking services and all related 

transactions, and acknowledge that FTX Trading does not provide investment, legal, or tax 

advice to you in connection with such election to participate. You should conduct your own 

due diligence and consult your advisors before making any investment decision including 

whether to participate in staking and related transactions.

16. MARGIN TRADING

16.1 This Section 16 applies only to the extent you are permitted to engage in margin trading on 

the Platform. Margin trading is prohibited in certain jurisdictions, and you may not be able 

to engage in margin trading on the Platform. We reserve the right to amend and/or remove 

margin trading functionality at any time.

16.2 Margin trading is HIGH RISK. As a borrower, you may sustain a total loss of Assets or owe 

Assets beyond what you have deposited to your Account. The high volatility and 

substantial risk of illiquidity in markets means that you may not always be able to liquidate 

your position. You agree to maintain a sufficient amount of Assets at all times to meet our 

margin requirements, as such requirements may be modified from time to time. If the value 

of the Assets in your Account falls below the margin maintenance requirement or we 

determine, in our sole discretion, that your Account appears to be in danger of defaulting 

on a loan, we may seize and/or liquidate any or all of your positions and Assets on any 

balance in your Account in order to reduce your leverage or settle your debt to other Users, 

in which case, you may sustain a total loss of all Assets in your Account. Our liquidation 

mechanism is described at https://help.ftx.com/hc/en-us/articles/360027668712-

Liquidations. If, after your positions and Assets are liquidated, your Account still contains 

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insufficient Assets to settle your debts to other Users, you will be responsible for any 

additional Assets owed. Intentionally defaulting on a loan may result in our reporting your 

activities to authorities and/or in legal prosecution.

16.3 When you lend Assets to other Users, you risk the loss of an unpaid principal if the 

borrower defaults on a loan and liquidation of the borrower’s Account fails to raise sufficient 

Assets to cover the borrower’s debt. Although we take precautions to prevent borrowing 

Users from defaulting on loans, the high volatility and substantial risk of illiquidity in 

markets means that we cannot make any guarantees to any Users using the Services 

against default. 

16.4 Under certain market conditions, it may become difficult or impossible to liquidate a 

position. This can occur, for example, if there is insufficient liquidity in the market or due to 

technical issues on the Platform. Placing contingent Orders, such as "stop-loss" or "stoplimit" Orders, will not necessarily limit your losses to the intended amounts, since market 

conditions may make it impossible to execute such Orders. In such an event, our backstop 

liquidity provider program may come into play, but there is no assurance or guarantee that 

any such program activities will be sufficient or effective in liquidating your position. As a 

result, you may lose all of your Assets or incur a negative balance in your Account. In 

addition, even if you have not suffered any liquidations or losses, your Account balance 

may be subject to clawback due to losses suffered by other Users.

16.5 The use of leverage can work against you as well as for you and can lead to large losses 

as well as gains. Users conduct all trading, margin trading, lending, and/or borrowing on 

their own account and we do not take any responsibility for any loss or damage incurred as 

a result of your use of any Services or your failure to understand the risks associated with 

margin trading on the Platform.

17. FORKS AND DISTRIBUTIONS

17.1 As a result of the decentralised and open source nature of Digital Assets it is possible that 

sudden, unexpected, controversial or other changes ("Forks") can be made to any Digital 

Asset that may change the usability, functions, compatibility, value or even name of a given 

Digital Asset. Such Forks may result in multiple versions of a Digital Asset and could lead 

to the dominance of one or more such versions of a Digital Asset (each a "Dominant 

Digital Asset") and the partial or total abandonment or loss of value of any other versions 

of such Digital Asset (each a "Non-Dominant Digital Asset").

17.2 FTX Trading is under no obligation to support a Fork of a Digital Asset that you hold in your 

Account, whether or not any resulting version of such forked Digital Asset is a Dominant 

Digital Asset or Non-Dominant Digital Asset or holds value at or following such Fork. Forks 

of Digital Assets can be frequent, contentious and unpredictable, and therefore cannot be 

consistently supported on the Platform. When trading or holding Digital Assets using your 

Account, you should operate under the assumption that the Platform will never support any 

Fork of such Digital Asset.

17.3 If FTX Trading elects, in its sole discretion, to support a Fork of a Digital Asset, it may 

choose to do so by making a public announcement through its Site or otherwise notifying 

customers and shall bear no liability for any real or potential losses that may result based 

on the decision to support such Fork or the timing of implementation of support. If FTX 

Trading, in its sole discretion, does not elect to support a Fork of a given Digital Asset, 

including the determination to support, continue to support, or cease to support any 

Dominant Digital Asset or Non-Dominant Digital Asset, FTX Trading assumes no 

responsibility or liability whatsoever for any losses or other issues that might arise from an 

unsupported Fork of a Digital Asset.

17.4 The Platform does not generally offer support for the distribution of Digital Assets based on 

a triggering fact or event, such as the possession of another Digital Asset (each an 

"Airdrop"), the provision of rewards or other similar payment for participation in a Digital 

Asset's protocol ("Staking Rewards"), or any other distributions or dividends that Users 

might otherwise be entitled to claim based on their use or possession of a Digital Asset 

outside of the Platform (collectively, "Digital Asset Distributions"). FTX Trading may, in 

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its sole discretion, elect to support any Digital Asset Distribution, but is under no obligation 

to do so and shall bear no liability to Users for failing to do so, or for initiating and 

subsequently terminating such support.

17.5 In the event of a Fork of a Digital Asset, we may be forced to suspend all activities relating 

to such Digital Asset (including trades, deposits, and withdrawals) on the Platform for an 

extended period of time, until FTX Trading has determined in its sole discretion that such 

functionality can be restored ("Downtime"). This Downtime may occur at the time that a 

Fork of a given Digital Asset occurs, potentially with little to no warning. During such 

Downtime, you understand that you may not be able to trade, deposit, or withdraw the 

Digital Asset subject to such Fork. FTX Trading does not bear any liability for losses 

incurred during any Downtime due to the inability to trade or otherwise transfer Digital 

Assets.

18. ATTACKS ON BLOCKCHAIN NETWORKS

18.1 FTX Trading cannot prevent or mitigate attacks on blockchain networks and has no 

obligation to engage in activity in relation to such attacks. In the event of an attack, FTX 

Trading reserves the right to take (or to not take) actions, including, but not limited to, 

immediately halting trading, deposits and withdrawals for a Digital Asset if we believe that 

the Digital Asset's network is compromised or under attack. If such an attack caused the 

Digital Asset to greatly decrease in value, we may discontinue trading in such Digital Asset 

entirely.

18.2 Resolutions concerning deposits, withdrawals and User balances for a Digital Asset that 

has had its network attacked will be determined on a case-by-case basis by FTX Trading in 

its sole discretion. FTX Trading makes no representation and does not warrant the safety 

of the Services and you assume all liability for any lost value or stolen property.

19. SITE; THIRD PARTY CONTENT

19.1 FTX Trading strives to provide accurate and reliable information and content on the Site, 

but such information may not always be correct, complete, or up to date. You should 

always carry out your own independent appraisal and investigations in relation to such 

information and not rely on it in any way. 

19.2 The Site may also contain links to third party websites, applications, events or other 

materials ("Third Party Content"). Such information is provided for your convenience and 

links or references to Third Party Content do not constitute an endorsement by FTX 

Trading of any products or services. FTX Trading makes no representation as to the 

quality, suitability, functionality or legality of Third Party Content, or to any goods and 

services available from third party websites, and FTX Trading shall have no liability for any 

losses incurred as a result of actions taken in reliance on the information contained on the 

Site or in any Third Party Content.

19.3 We have no control over, or liability for, the delivery, quality, safety, legality or any other 

aspect of any goods or services that you may purchase from a third party (including other 

Users of the Platform). We are not responsible for ensuring that a third party buyer or seller 

you transact with will complete the transaction or is authorised to do so. If you experience a 

problem with any goods or services purchased from, or sold to, a third party purchased 

using Digital Assets in connection with the Services, you must resolve the dispute directly 

with that third party.

20. AVAILABILITY

20.1 We do not represent that you will be able to access your Account or the Services 100% of 

the time. Your Account and the Services are made available to you without warranty of any 

kind, either express or implied. There are no guarantees that access will not be interrupted, 

or that there will be no delays, failures, errors, omissions or loss of transmitted information. 

This could result in the inability to trade on the Platform for a period of time and may also 

lead to time delays. We may, from time to time, suspend access to your Account and the 

Services, for both scheduled and emergency maintenance.

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20.2 You acknowledge and agree that neither FTX Trading nor any other Indemnified Party shall 

have any liability to you or any third party for the correctness, quality, accuracy, security, 

completeness, reliability, performance, timeliness, pricing or continued availability of the 

Services or for delays or omissions of the Services, or for the failure of any connection or 

communication service to provide or maintain your access to the Services, or for any 

interruption in or disruption of your access or any erroneous communications between FTX 

Trading (or any other Indemnified Party) and you, regardless of cause.

20.3 FTX Trading may determine not to make the Services, in whole or in part, available in 

every market, either in its sole discretion or due to legal or regulatory requirements. In 

addition, FTX Trading may determine not to make the Services, in whole or in part, 

available to you, depending on your location. If you travel to a Restricted Territory, our 

Services may not be available and your access to our Services may be blocked. You 

acknowledge that this may impact your ability to trade on the Platform and/or monitor any 

existing Orders or open positions or otherwise use the Services. You must not attempt in 

any way to circumvent any such restriction, including by use of any virtual private network 

to modify your internet protocol address.

21. RIGHT TO CHANGE, SUSPEND OR DISCONTINUE SERVICES 

21.1 We reserve the right to change, suspend, or discontinue any aspect of the Services at any 

time and in any jurisdiction, including hours of operation or availability of any feature, 

without notice and without liability. We may advise you of any such changes, suspensions 

or discontinuations via your Account or the other contact details that you have provided to 

us but shall have no obligation to do so.

21.2 If you do not agree with any change, suspension, or discontinuance of any aspect of the 

Services, then your sole and exclusive remedy is to terminate your use of the Services and 

close your Account. You agree that neither we nor any other Indemnified Party shall be 

liable to you or any third party for any Losses suffered as a result of any such changes, 

suspensions, discontinuations or decisions.

22. UPDATES TO THE TERMS

22.1 We reserve the right to amend any part of the Terms, at any time, by posting the revised 

version of the Terms on the Site, with an updated revision date. The changes will become 

effective, and shall be deemed accepted by you, the first time you use the Services after 

the initial posting of the revised Terms and shall apply on a going-forward basis with 

respect to transactions initiated after the posting date. You acknowledge that it is your 

responsibility to check the Terms periodically for changes.

22.2 If you do not agree with any amendments to the Terms, your sole and exclusive remedy is 

to terminate your use of the Services and close your Account. You agree that neither we 

nor any other Indemnified Party shall be liable to you or any third party for any Losses 

suffered as a result of any amendment of the Terms.

23. FEES

23.1 In consideration for the use of the Services, you agree to pay to FTX Trading the 

appropriate fees, as set forth in our Fee Schedule displayed on the Site ("Fee Schedule"), 

which FTX Trading may revise or update in its sole discretion from time to time. If you do 

not agree with any amendments to the Fee Schedule, your sole and exclusive remedy is to 

terminate your use of the Services and close your Account.

23.2 On request, FTX Trading may make available an alternative fee schedule ("Alternative 

Fee Schedule") to Users who satisfy certain criteria (such as in relation to trading volume), 

which are determined by FTX Trading in its sole discretion from time to time. 

23.3 You authorise FTX Trading to deduct any applicable fees from your Account at the time 

you make a given transaction. Changes to the Fee Schedule or Alternative Fee Schedule 

are effective as of the date set forth in any revision and will apply prospectively from that 

date forward.

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24. TAXES

24.1 You will be able to see a record of your transactions via your Account which you may wish 

to use for the purposes of making any required tax filings or payments. It is your 

responsibility to determine what, if any, taxes apply to your activities on the Platform, and 

to collect, report, and remit the correct tax to the appropriate tax authority. 

24.2 FTX Trading is not responsible for determining whether taxes apply to your transaction, or 

for collecting, reporting, or remitting any taxes arising from any transaction.

25. RIGHT TO USE SERVICES; API USE; THIRD PARTY APPLICATIONS

25.1 License

25.1.1 FTX Trading grants you a limited, non-exclusive, non-sublicensable, and nontransferable license, subject to the Terms, to access and use the Services solely 

for approved purposes as determined by FTX Trading. Any other use of the 

Services is expressly prohibited. FTX Trading and its licensors reserve all rights 

in the Services, and you agree that the Terms do not grant you any rights in, or 

licenses to, the Services except for the limited license set forth above.

25.1.2 Except as expressly authorised by FTX Trading, you agree not to modify, reverse 

engineer, copy, frame, scrape, rent, lease, loan, sell, distribute, or create 

derivative works based on the Services, in whole or in part. If you violate any 

portion of the Terms, your permission to access and use the Services may be 

terminated pursuant to the Terms. 

25.1.3 "FTX.com," "FTX" and all logos related to the Services are either trademarks, or 

registered marks of FTX Trading or its licensors. You may not copy, imitate, or 

use them without FTX Trading's prior written consent. All right, title, and interest 

in and to the Site and any Mobile Application, any content thereon, the Services, 

and any and all technology or content created or derived from any of the 

foregoing is the exclusive property of FTX Trading and its licensors.

25.2 API use

25.2.1 Subject to your compliance with the Terms and any other agreement which may 

be in place between you and FTX Trading relating to your use of the API, FTX 

Trading grants you a limited, revocable, non-exclusive, non-transferable, nonsublicensable license, to use the API solely for the purposes of trading on the 

Platform. You agree to not use the API or data provided through the API for any 

other purpose. You agree your access and use of the API shall be entirely at your 

own risk, and that FTX Trading will not be responsible for any liabilities that you 

incur as a result of the use of the API or actions you take based on the API.

25.2.2 FTX Trading may, at its sole discretion, set limits on the number of API calls that 

you can make, for example, to maintain market stability and integrity. You 

acknowledge and agree that if you exceed these limits, FTX Trading may 

moderate your activity or cease offering you access to the API (or any other API 

offered by FTX Trading), each in its sole discretion. 

25.2.3 FTX Trading may immediately suspend or terminate your access to the API 

without notice if we believe you are in violation of the Terms or any other 

agreement which may be in place between you and FTX Trading related to your 

use of the API.

25.3 Third Party Applications

25.3.1 We offer our Services to users both directly and via third party websites, 

platforms, applications and other access portals (collectively, “Third Party 

Portals”). If you are accessing these Terms via a Third Party Portal, you agree 

(a) to comply with all applicable terms of service of such Third Party Portal, (b) 

that you are solely responsible for payment of any and all costs and fees 

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associated with such Third Party Portals, and (c) we do not owe you any duty of 

care with respect to such Third Party Portals, nor do we accept any responsibility 

for them. 

25.3.2 If you grant express permission to a third party to connect to your Account, either 

through the third party’s product or through the Services, you acknowledge that 

granting permission to a third party to take specific actions on your behalf does 

not relieve you of any of your responsibilities under these Terms.

25.3.3 You acknowledge and agree that you will not hold us responsible for, and will 

indemnify us from, any liability arising from the actions or inactions of such third 

party in connection with the permissions you grant. You expressly agree that your 

use of any Third Party Portal is at your own risk and we will not be liable to you 

for any inaccuracies, errors, omissions, delays, damages, claims, liabilities or

losses, arising out of or in connection with your use of Third Party Portals. 

25.3.4 In the event that access to the Services via any Third Party Portal is suspended, 

terminated or cancelled for any reason, you agree that you shall remain bound by 

these Terms and our Privacy Policy as a user of the Services.

26. PRIVACY POLICY

We are committed to protecting your personal information and to helping you understand 

exactly how your personal information is being used. You should carefully read our Privacy 

Policy, which provides details on how your personal information is collected, stored, 

protected, and used.

27. CONFIDENTIALITY

27.1 You shall treat as strictly confidential and not use or disclose any information or documents 

which you receive (or have received) from us, whether before, during or after the term of 

the Terms, and whether communicated orally, in writing, in electronic form or otherwise, 

relating to our business, financial situation, products and services (including the Services), 

expectations, processes and methods, customers or employees, in each case which is 

designated as being "confidential" or which by its very nature should obviously be treated 

as secret and confidential (together "Confidential Information").

27.2 You may use the Confidential Information solely to the extent necessary to receive the 

benefit of the Services in accordance with the Terms.

27.3 The obligation to maintain confidentiality under this Section 27 shall not apply to any 

Confidential Information to the extent that such information is: 

27.3.1 in the public domain through no breach of the Terms; 

27.3.2 known to you at the time of disclosure without restrictions on use, or 

independently developed by you, and in each case, there is appropriate 

documentation to demonstrate either condition; or

27.3.3 required to be disclosed to a Regulatory Authority or by Applicable Laws.

27.4 If you are required under Applicable Laws or by any Regulatory Authority to disclose 

Confidential Information in the circumstances set out in Section 27.3.3 you shall give us 

such notice as is practical in the circumstances of such disclosure and shall provide all 

cooperation reasonably requested by us in relation to mitigating the effects of, or avoiding 

the requirements for, any such disclosure. 

27.5 Any Confidential Information shall remain the property of FTX Trading and may be copied 

or reproduced only with our prior written consent. 

27.6 Upon request, you shall return or destroy all materials containing our Confidential 

Information and, where such materials have been destroyed, confirm such destruction in 

writing. You shall be under no obligation to return or destroy such materials if and to the 

extent you are required to retain such materials under Applicable Laws, provided that you 

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shall notify us in writing of such requirement, giving details of the materials which have not 

been destroyed or returned, and this Section 27 shall continue to apply to such materials.

27.7 The parties agree and acknowledge that a breach of this Section 27 constitutes a matter of 

urgency for the purposes of section 12A(4) of Singapore's International Arbitration Act 

(Chapter 143A) both before, and after, the formation of the arbitral tribunal.

27.8 The availability of relief from an emergency arbitrator or the expedited formation of an 

arbitral tribunal under SIAC Rules (as defined in Section 38.12.1 below) shall not prejudice 

any party's right to apply to a state court or other judicial authority for any interim or 

conservatory measures before the formation of the arbitral tribunal and it shall not be 

treated as an alternative to or substitute for the exercise of such right. Where a party 

applies for relief from a state court or other judicial authority, the parties agree that failure 

to make an application for expedited appointment of the arbitral tribunal and/or for the 

appointment of an emergency arbitrator under the SIAC Rules shall not indicate, or be 

deemed to indicate, a lack of urgency. The parties also agree that any refusal by the 

President of the Court of Arbitration of SIAC to appoint an emergency arbitrator or allow the 

expedited formation of the arbitral tribunal shall not be determinative of the question of 

urgency.

27.9 The parties agree that an application to a state court or other judicial authority for interim or 

conservatory measures after the formation of the arbitral tribunal in respect of this Section 

27 shall be considered "exceptional circumstances" under Rule 30.3 of the SIAC Rules. 

The parties also agree that an application may be made for interim relief on a non-urgent 

basis under section 12A(5) of Singapore's International Arbitration Act and agree that this 

Section 27.9 constitutes agreement in writing for the purposes of section 12A(5) of 

Singapore's International Arbitration Act. 

28. COOKIES

By accessing the Site, you agree to use cookies in agreement with FTX Trading's Privacy 

Policy. The Site uses cookies to enable us to retrieve User details for each visit, and to 

enable the functionality of certain areas of the Site to make it easier for Users visiting the 

Site to access and use the Services.

29. INDEMNIFICATION; RELEASE

29.1 You shall and agree to defend, indemnify and hold harmless FTX Trading, its Affiliates and 

service providers and, in each case, their Personnel (collectively, "Indemnified Parties"

and each an "indemnified Party") from and against any and all claims and liabilities, 

costs, expenses, damages and losses (including any direct, indirect or consequential 

losses, loss of profit, loss of reputation and all interest, penalties and legal and other 

reasonable professional costs and expenses) ("Losses" or "Loss") which any Indemnified 

Party may suffer or incur, arising directly or indirectly out of or in connection with: (i) your 

use of your Account and/or the Services; (ii) your breach or anticipatory breach of the 

Terms; or (iii) your violation or anticipatory violation of any Applicable Laws.

29.2 You will cooperate as fully required by the Indemnified Parties in the defence of any such 

claims and Losses. The Indemnified Parties retain the exclusive right to assume the 

exclusive defence and control of any claims and Losses. You will not settle any claims and 

Losses without FTX Trading's prior written consent.

29.3 You hereby agree to release each of the Indemnified Parties from any and all claims and 

demands (and waive any rights you may have against any of the Indemnified Parties in 

relation to any Losses you may suffer or incur), arising directly or indirectly out of or in 

connection with any dispute that you have with any other User or other third party in 

connection with the Services (including any Digital Asset transactions) or the subject matter 

of the Terms.

30. LIMITATION OF LIABILITY; NO WARRANTY

30.1 NOTHING IN THE TERMS SHALL LIMIT OR EXCLUDE A PARTY'S LIABILITY:

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30.1.1 FOR DEATH OR PERSONAL INJURY CAUSED BY ITS NEGLIGENCE;

30.1.2 FOR FRAUD OR FRAUDULENT MISREPRESENTATION; OR

30.1.3 TO THE EXTENT SUCH LIABILITY CANNOT BE EXCLUDED BY APPLICABLE 

LAWS.

30.2 SUBJECT TO SECTION 30.1, NEITHER FTX TRADING NOR ANY OF THE OTHER 

INDEMNIFIED PARTIES SHALL BE LIABLE TO YOU IN CONTRACT, TORT (INCLUDING 

NEGLIGENCE), EQUITY, STATUTE OR ANY OTHER CAUSE ARISING OUT OF OR IN 

CONNECTION WITH THE TERMS (OR ARISING OUT OF OR IN CONNECTION WITH: 

YOUR USE OR INABILITY TO USE THE SERVICES; THE COST OF PROCURING 

SUBSTITUTE GOODS AND SERVICES IN CIRCUMSTANCES WHERE YOU DO NOT 

OR ARE UNABLE TO USE THE SERVICES; ANY GOODS, DATA, INFORMATION, OR 

SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR 

TRANSACTIONS ENTERED INTO THROUGH OR FROM THE SERVICES; 

UNAUTHORISED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR 

DATA; OR ANY OTHER MATTER RELATING TO THE SERVICES) FOR: 

30.2.1 INCIDENTAL, PUNITIVE, EXEMPLARY OR OTHER SPECIAL LOSS OR 

DAMAGE; OR LOSS OF PROFIT, LOSS OF REVENUE, LOSS OF GOODWILL, 

LOSS OF USE, LOSS OF BUSINESS OR CONTRACT, LOST 

OPPORTUNITIES, INCREASED COSTS OR EXPENSES (OR WASTED 

EXPENDITURE INCLUDING PRE-CONTRACT EXPENDITURE), LOSS OF 

SAVINGS, ANY LIABILITY VOLUNTARILY ASSUMED BY YOU, OR LOSS OF 

OR DAMAGE TO DATA, IN EACH CASE REGARDLESS OF WHETHER SUCH 

LOSS OR DAMAGE WAS DIRECT OR INDIRECT, FORESEEABLE OR 

UNFORESEEABLE, OR WHETHER FTX TRADING OR ANY OF THE OTHER 

INDEMNIFIED PARTIES HAD BEEN ADVISED OF THE POSSIBILITY OF 

SUCH LOSS OR DAMAGE; OR

30.2.2 INDIRECT OR CONSEQUENTIAL LOSS OR DAMAGE.

30.3 YOU ACKNOWLEDGE AND AGREE THAT FTX TRADING AND ITS AFFILIATES MAY 

RELY ON ONE OR MORE THIRD PARTY INTERMEDIARIES FOR THE PURPOSES OF 

PROVIDING THE SERVICES. THE THIRD PARTY INTERMEDIARIES ARE 

INDEPENDENT THIRD PARTIES AND ARE NOT FTX TRADING'S AGENTS OR 

SUBCONTRACTORS. SUBJECT TO SECTION 30.1, FTX TRADING SHALL NOT BE 

LIABLE FOR THE ACTS OR OMISSIONS OF ANY THIRD PARTY INTERMEDIARY, OR 

ANY LOSSES ARISING FROM THE FAULT OF ANY THIRD PARTY INTERMEDIARY, 

SUCH AS A FAILURE BY A THIRD PARTY INTERMEDIARY TO COMPLY WITH 

APPLICABLE LAWS OR ANY REASONABLE INSTRUCTIONS PROVIDED BY FTX 

TRADING.

30.4 YOU ACKNOWLEDGE AND AGREE THAT THE SERVICES ARE PROVIDED ON AN "AS 

IS" BASIS, WITHOUT ANY WARRANTY OR REPRESENTATION OF ANY KIND AND, TO 

THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, EACH OF FTX TRADING 

AND THE OTHER INDEMNIFIED PARTIES EXPRESSLY DISCLAIM ANY WARRANTIES 

OR CONDITIONS, EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, WITH 

RESPECT TO THE SERVICES, INCLUDING, WITHOUT LIMITATION, ANY IMPLIED 

WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR 

PURPOSE OR NON-INFRINGEMENT. NEITHER FTX TRADING NOR ANY OTHER 

INDEMNIFIED PARTY MAKES ANY WARRANTY THAT:

30.4.1 THE SERVICES WILL MEET YOUR REQUIREMENTS;

30.4.2 THE SERVICES WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERRORFREE; OR 

30.4.3 THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER 

MATERIAL PURCHASED OR OBTAINED BY YOU WILL MEET YOUR 

EXPECTATIONS.

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30.5 SUBJECT TO SECTION 30.1, NEITHER FTX TRADING NOR ANY OF THE OTHER 

INDEMNIFIED PARTIES WILL BE RESPONSIBLE OR LIABLE TO YOU FOR ANY LOSS 

AND TAKE NO RESPONSIBILITY FOR, AND WILL NOT BE LIABLE TO YOU FOR, ANY 

USE OF THE SERVICES, INCLUDING BUT NOT LIMITED TO ANY LOSSES, DAMAGES 

OR CLAIMS ARISING FROM: USER ERROR SUCH AS FORGOTTEN PASSWORDS, 

INCORRECTLY CONSTRUCTED TRANSACTIONS, OR MISTYPED WALLET 

ADDRESSES; SERVER FAILURE OR DATA LOSS; CRYPTOCURRENCY WALLETS OR 

CORRUPT FILES; UNAUTHORISED ACCESS TO SERVICES; OR ANY THIRD PARTY 

ACTIVITIES, INCLUDING WITHOUT LIMITATION THE USE OF VIRUSES, PHISHING, 

BRUTEFORCING OR OTHER MEANS OF ATTACK AGAINST YOUR COMPUTER OR 

ANY BLOCKCHAIN NETWORK UNDERLYING THE SERVICES. 

31. COUNTRY-SPECIFIC ADDENDA

If you are a resident of Australia, Japan, or South Africa, additional terms and conditions 

will apply to your use of the Services as set forth in the Schedules attached hereto. 

32. COMMUNICATIONS IN ENGLISH

The Terms are provided to you and concluded in English. We will communicate with you in 

English for all matters related to your use of our Services unless we elect, in our sole 

discretion, to provide support for other languages.

33. FEEDBACK

You acknowledge and agree that any materials, including without limitation questions, 

comments, feedback, suggestions, ideas, plans, notes, drawings, original or creative 

materials or other information or commentary you provide to us or one of our social media 

accounts, regarding the Services (collectively, "Feedback") that are provided by you, 

whether by email, posting to the Site or social channels, or otherwise, are non-confidential 

and will become the sole property of FTX Trading. FTX Trading will own exclusive rights, 

including all intellectual property rights, in and to such Feedback, and will be entitled to the 

unrestricted use and dissemination of such Feedback for any purpose, commercial or 

otherwise, without acknowledgment or compensation to you.

34. QUESTIONS AND CONTACT INFORMATION

34.1 We often post notices and relevant Services information in our Telegram channel and on 

our Twitter account, so we advise You to check those channels before contacting support.

Telegram: https://t.me/FTX_Official 

Twitter: https://twitter.com/FTX_Official 

WeChat: ftexchange

Blog: https://blog.ftx.com/

34.2 To contact us, please visit one of the links or channels above. For support with your 

Account, you may submit a support ticket at https://ftx.com/support. For legal and media 

inquiries, please contact legal@ftx.com and media@ftx.com, respectively. Please provide 

all relevant information, including your Account username and transaction IDs of any 

related deposits. Although we make no representations or provide no warranties as to the 

speed of response, we will endeavour to get back to you as soon as possible.

35. PROMOTIONS

FTX Trading does not, as a general rule, participate in promotions without an official 

pronouncement, either on the Site or elsewhere. You shall obtain prior written approval 

prior to releasing any statements, written media releases, public announcements and 

public disclosures, including promotional or marketing materials, relating to the Platform. 

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36. FORCE MAJEURE AND RELIEF EVENTS

36.1 FTX Trading shall not be responsible (and shall have no liability) for any failure, interruption 

or delay in relation to the performance of the Services or its obligations under the Terms 

that results from any abnormal or unforeseeable circumstances outside our reasonable 

control, including without limitation:

36.1.1 any Force Majeure Event; or 

36.1.2 any failure by you to comply with your obligations under the Terms or Applicable 

Laws ("Relief Event").

37. ASSIGNMENT AND SUBCONTRACTING

37.1 You may not assign, novate, or otherwise transfer, any of your rights or obligations under 

the Terms, or sub-contract the performance of any of your obligations under the Terms, 

without the prior written consent of FTX Trading. Any attempted assignment, novation, 

transfer or sub-contracting without our consent shall be void.

37.2 FTX Trading may assign, novate, or otherwise transfer any of its rights or obligations under 

the Terms to any other person, or sub-contract the performance of any of its obligations 

under the Terms (including the performance of the Services), at any time and without your 

consent, and you hereby consent to such assignment, novation, transfer or subcontracting, 

and agree to take all actions (including by way of executing documents) and other 

assistance required by FTX Trading to ensure that any such assignment, novation, transfer 

or subcontracting is effective and enforceable. If you object to such assignment, novation, 

transfer or sub-contracting you may stop using our Services and terminate the Terms by 

contacting us and requesting us to close your Account.

38. GENERAL

38.1 Entire agreement

38.1.1 You agree that the Terms constitute the entire agreement between you and FTX 

Trading with respect to the use of the Services.

38.1.2 You agree that in agreeing to and entering into the Terms you have not been 

induced to do so by, and have not relied on, any statement, representation, 

warranty, assurance, covenant, indemnity, undertaking or commitment 

("Representation") which is not expressly set out in the Terms.

38.1.3 You agree that your only right of action in relation to any innocent or negligent 

Representation set out in the Terms or given in connection with the Terms shall 

be for breach of contract. All other rights and remedies in relation to any such 

Representation (including those in tort or arising under statute) are excluded.

38.2 Survival

Upon the later of the closure of your Account and the termination of your access to and use 

of the Services the Terms shall terminate. All rights and obligations of the parties that by 

their nature are continuing will survive the termination of the Terms.

38.3 Severability

If any provision or part of the Terms is void or unenforceable due to any Applicable Laws, it 

shall be deemed to be deleted and the remaining provisions of the Terms shall continue in 

full force and effect. If any invalid, unenforceable or illegal provision of the Terms would be 

valid, enforceable and legal if some part of it were deleted, the provision shall apply with 

the minimum deletion necessary to make it valid, legal and enforceable.

38.4 Successors and assigns

The Terms shall be binding on, and enure to the benefit of, the parties to the Terms and their 

respective personal representatives, successors and permitted assigns, and references to 

any party shall include that party's personal representatives, successors and permitted 

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assigns.

38.5 Variation and waiver

38.5.1 Subject to Section 22, no variation of the Terms shall be effective unless it is in 

writing (which for this purpose, does not include email) and signed by, or on 

behalf of, each of the parties. The expression "variation" includes any variation, 

supplement, deletion or replacement however effected.

38.5.2 No waiver by FTX Trading of any right or remedy provided by the Terms or by law 

shall be effective unless it is in writing (which for this purpose, does not include 

email) and signed by, or on behalf of, FTX Trading. The failure by FTX Trading to 

exercise, or delay in exercising, any right or remedy provided by the Terms or by 

law does not: (i) constitute a waiver of that right or remedy; (ii) restrict any further 

exercise of that right or remedy; or (iii) affect any other rights or remedies. A 

single or partial exercise by FTX Trading of any right or remedy does not prevent 

any further or other exercise of that right or remedy or the exercise of any other 

right or remedy.

38.6 No partnership or agency

Nothing in the Terms or in any matter or any arrangement contemplated by it is intended to 

constitute a partnership, association, joint venture, fiduciary relationship or other cooperative entity between the parties for any purpose whatsoever. Except as expressly 

provided in the Terms, neither party has any power or authority to bind the other party or 

impose any obligations on it and neither party shall purport to do so or hold itself out as 

capable of doing so. Each party confirms it is acting on its own behalf and not for the 

benefit of any other person.

38.7 Set off

38.7.1 Notwithstanding that any amount is from time to time payable by FTX Trading to 

you under or by virtue of the Terms or otherwise, you shall not set off such 

amount against any amount payable by you to FTX Trading under the Terms.

38.7.2 FTX Trading may set off any amounts which from time to time are payable by 

FTX Trading to you under or by virtue of the Terms or otherwise against any 

amounts payable by you to FTX Trading under the Terms.

38.8 Equitable remedies 

Without prejudice to any other rights or remedies that FTX Trading may have, you 

acknowledge and agree that damages alone may not be an adequate remedy for your 

breach of the Terms. The remedies of injunction and specific performance as well as any 

other equitable relief for any threatened or actual breach of such provisions of the Terms 

may be more appropriate remedies.

38.9 Third party rights

Save as otherwise expressly provided in the Terms (such as in Sections 29, 30 and 

38.12.8):

38.9.1 the Terms are not intended and shall not be construed to create any rights or 

remedies in any parties other than you and FTX Trading and its Affiliates, which 

each shall be a third party beneficiary of the Terms; and 

38.9.2 no other person shall assert any rights as a third party beneficiary hereunder 

(notwithstanding any legislation to the contrary anywhere in the world).

38.10 Electronic signature

The Terms may be entered into by electronic means.

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38.11 Governing law 

The Terms and any Dispute shall be governed by, and construed in accordance with, 

English law.

38.12 Arbitration

38.12.1 Subject to Section 38.13 below, any Dispute shall be referred to and finally 

determined by arbitration administered by the Singapore International Arbitration 

Centre ("SIAC") in accordance with the Arbitration Rules of the SIAC ("SIAC 

Rules") for the time being in force.

38.12.2 This arbitration agreement shall be governed by English law.

38.12.3 The seat of the arbitration shall be Singapore.

38.12.4 The language of the arbitration shall be English.

38.12.5 The number of arbitrators shall be one.

38.12.6 Each party agrees that:

(A) any Dispute shall be referred to arbitration in accordance with this Clause 

38.12 on an individual basis only and not as a claimant or class member 

in a purported class or representative action; 

(B) combining or consolidating individual arbitrations into a single arbitration 

is not permitted without the consent of all parties.

38.12.7 This agreement to arbitrate shall:

(A) be binding upon the parties, their successors and assigns;

(B) survive the termination of these Terms.

38.12.8 Where a User alleges or claims that a Dispute has arisen between it and any of 

the Indemnified Parties who is not otherwise a party to these Terms, that

Indemnified Party may require that the Dispute be finally settled by arbitration in 

accordance with this Section 38.12 (without prejudice to that Indemnified Party's 

right to make a jurisdictional challenge), provided that such Indemnified Party 

exercises its right to arbitration under this Section 38.12 by notice in writing to all 

parties to the Terms within 7 days of being notified in writing of the Dispute. For 

the avoidance of doubt, the User provides express consent to the joinder of such 

Indemnified Party to an arbitration commenced pursuant to this Section 38.12.

38.13 Exception to arbitration

If you are a resident of a jurisdiction where the law prohibits arbitration of Disputes, Section 

38.12 above will not apply to you. Instead, each party irrevocably agrees that the Courts of 

England and Wales located in London, England shall have exclusive jurisdiction in relation 

to any Dispute and each party irrevocably waives any right that it may have to object to an 

action being brought in those Courts, to claim that the action has been brought in an 

inconvenient forum, or to claim that those Courts do not have jurisdiction.

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SCHEDULE 1

DEFINITIONS AND INTERPRETATION

1. DEFINITIONS

1.1 As used throughout the Terms unless the context requires otherwise:

"Affiliate" means, in relation to a party, any person that directly, or indirectly through one 

or more intermediaries, controls, is controlled by, or is under common control with, such 

party. A person shall be deemed to control another person if such person possesses, 

directly or indirectly, the power to direct, or cause the direction of, the management and 

policies of such other person, whether through the ownership of voting securities, by 

contract or otherwise.

"Applicable Laws" means all laws, including rules of common law, principles of equity, 

statutes, regulations, directives, proclamations, ordinances, by-laws, rules, regulatory 

principles and requirements, mandatory codes of conduct, writs, orders, injunctions, 

judgments and any awards of other industrial instruments, which are applicable to the 

provision, receipt or use of the Services or any products or other deliverables provided, 

used or received in connection with the Services.

"Assets" means the Digital Assets, fiat currency and E-Money held in your Account.

"BTC" means the cryptocurrency Bitcoin.

"Digital Assets" means BTC, ETH, FTT and any other digital asset, cryptocurrency, virtual 

currency, token, leveraged token, stablecoin, tokenised stock, volatility token, tokenised 

futures contract, tokenised option or other tokenised derivatives product that is supported 

by and made available from time to time to transact in using the Platform.

"Dispute" means any dispute, claim, controversy or difference arising out of or in 

connection with the Terms, including any question regarding its existence, validity, subject 

matter, interpretation, negotiation, termination or enforceability, and any dispute, claim, 

controversy or difference regarding any non-contractual obligations arising out of or in 

connection with the Services.

"ETH" means the cryptocurrency Ethereum.

"Exchange" means the trading platform operated by FTX Trading or its Affiliates through 

which the Services may be offered to Users to transact in Digital Assets with other Users. 

"fiat currency" means any government issued national currency.

"Force Majeure Event" means any circumstance not within a party's reasonable control 

including:

(i) acts of God, flood, drought, earthquake or other natural disaster;

(ii) epidemic or pandemic;

(iii) terrorist attack, civil war, civil commotion or riots, war, threat of or preparation for 

war, armed conflict, imposition of sanctions, embargo, or breaking off of diplomatic 

relations;

(iv) nuclear, chemical or biological contamination or sonic boom;

(v) any law or any action taken by a Regulatory Authority, including the imposition of 

an export or import restriction, quota or prohibition;

(vi) collapse of buildings, fire, explosion or accident; and

(vii) any labour or trade dispute, strikes, industrial action or lockouts (other than in each 

case by the party (or its Affiliates) seeking to rely on this clause).

"FTT" is the exchange token of the Exchange ecosystem and is not offered in the United 

States or to U.S. persons.

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"Mobile Application" means any mobile application developed or provided by FTX

Trading and/or any of its Affiliates through which Users can access the Platform.

"Order" means each instruction placed by you on the Order Book to purchase or sell a 

specified quantity of a Digital Asset at a specified price in the Digital Asset in which trading 

is denominated on the Order Book; the second Digital Asset in a trading pair (e.g. USD in 

the BTC/USD trading pair).

"Order Book" means the central limit order book operated by FTX Trading on the Platform.

"parties" means the parties to the Terms, being you and FTX Trading (or, where applicable, 

the Service Provider responsible for providing a Specified Service to you as specified in a 

Service Schedule, insofar as that Specified Service is concerned), and "party" shall mean 

any one of the foregoing (as the context requires).

"Personnel" means the directors, officers, employees, agents, joint venturers, and 

contractors or subcontractors of a person.

"Regulatory Authority" means any foreign, domestic, state, federal, cantonal, municipal 

or local governmental, executive, legislative, judicial, administrative, supervisory or 

regulatory authority, agency, quasi-governmental authority, court, commission, government 

organisation, self-regulatory organisation having regulatory authority, tribunal, arbitration 

tribunal or panel or supra-national organisation, or any division or instrumentality thereof, 

including any tax authority.

"Service Provider" means the entity specified in a Service Schedule as responsible for 

providing the Specified Service referred to in that Service Schedule.

"Service Schedule" means the Service Schedules set out in the Schedules (other than 

this Schedule 1) to the General Terms.

"Specified Service" means any service specified in a Service Schedule.

"transaction" or "trade" means each transaction or trade carried out (or to be carried out) 

via the Platform relating to buying, selling, exchanging, holding, staking, lending, 

borrowing, sending, receiving or otherwise transacting in a Digital Asset.

"User" means a user of the Services, including you.

2. INTERPRETATION

2.1 References to the Terms and other agreements

In the Terms, except where the context otherwise requires:

2.1.1 a reference to the Terms includes a reference to the Service Schedules and any 

other Schedules to it, each of which forms part of the Terms;

2.1.2 a reference to a Section or Schedule (other than to a schedule to a statutory 

provision) is a reference to a Section or Schedule (as the case may be) of, or to, 

the Terms and reference to a paragraph is to a paragraph of the relevant 

Schedule;

2.1.3 the headings are for convenience only and shall not affect the interpretation of the 

Terms;

2.1.4 a reference to the Terms includes the Terms as amended or supplemented in 

accordance with its terms; and

2.1.5 a reference to any agreement or other instrument (other than an enactment or 

statutory provision) is to that agreement or instrument as from time to time 

amended, varied, supplemented, substituted, novated or assigned otherwise than 

in breach of the Terms.

2.2 Singular, plural and gender

Words in the singular include the plural and vice versa and a reference to one gender 

includes other genders.

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2.3 References to persons and companies

In the Terms, except where the context otherwise requires:

2.3.1 a reference to a person includes a reference to any individual, firm, company, 

government, state or agency of a state, local or municipal authority or 

government body or any joint venture, association or partnership (whether or not 

having separate legal personality);

2.3.2 a reference to a company includes any company, corporation or other body 

corporate wherever and however incorporated or established; and

2.3.3 a reference to an individual includes that individual's estate and personal 

representatives.

2.4 References to time periods

In the Terms, except where the context otherwise requires, any reference to a date or time 

is a reference to that date or time in the principal financial centre of the country in which the 

registered office of FTX Trading (or the relevant Affiliate of FTX Trading) is located, unless 

otherwise agreed in writing. A reference to a day means a period of 24 hours ending at 

midnight. Any period of time shall be calculated exclusive of the day from which the time 

period is expressed to run or the day upon which the event occurs which causes the period 

to start running.

2.5 References to legislation and legal terms

In the Terms, except where the context otherwise requires, a reference to an enactment or 

statutory provision shall include a reference to any subordinate legislation made under the 

relevant enactment or statutory provision, and is a reference to that enactment, statutory 

provision or subordinate legislation as from time to time amended, modified, incorporated 

or reproduced and to any enactment, statutory provision or subordinate legislation that 

from time to time (with or without modifications) re-enacts, replaces, consolidates, 

incorporates or reproduces it.

2.6 Includes and including

In the Terms, except where the context otherwise requires:

2.6.1 the words and phrases "includes", "including", "in particular" (or any terms of 

similar effect) shall not be construed as implying any limitation; and

2.6.2 general words shall not be given a restrictive meaning because they are 

preceded or followed by particular examples.

2.7 To the extent that

In the Terms, except where the context otherwise requires, the phrase "to the extent that" 

is used to indicate an element of degree and shall mean "to the extent that" and not solely 

"if", and similar expressions shall be construed in the same way.

2.8 Writing

A reference to writing includes any modes of reproducing words in any legible form and, 

except where expressly stated otherwise, shall include email).

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SCHEDULE 2 

SERVICE SCHEDULE

Specified Service Spot Market

Specified Service 

description

The Spot Market is a trading platform through which you can spot trade 

certain Digital Assets with other Users in exchange for fiat currency 

(depending on your location) or Digital Assets.

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Digital Markets Ltd, an International Business Company incorporated in 

The Bahamas (company registration number 207269 B), to all eligible 

Users other than persons who have their registered office or place of 

residence in the United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

The Digital Assets that are available for spot trading on the Spot Market 

are listed on the Site. This list may be amended from time to time by the 

Service Provider at its sole discretion.

The Service Provider reserves the right to final interpretation of this 

Specified Service.

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SCHEDULE 3 

SERVICE SCHEDULE

Specified Service Spot Margin Trading

Specified Service 

description

Spot Margin Trading enables you to spot trade certain Digital Assets that 

you do not have by posting collateral in the form of fiat currency 

(depending on your location) or Digital Assets held in your Account and 

borrowing the required Digital Assets from other Users. You can then spot 

trade the borrowed Digital Assets through the Spot Market on the 

Platform.

You may also lend your Digital Assets to other Users who need them to 

spot trade.

Digital Asset borrowers pay a lending fee to Digital Asset lenders.

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Digital Markets Ltd, an International Business Company incorporated in 

The Bahamas (company registration number 207269 B), to all eligible 

Users other than persons who have their registered office or place of 

residence in the United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

IMPORTANT: Section 16 of the General Terms applies to this service.

You may be asked to sign other documents in some cases in relation to 

Spot Margin Trading, including but not limited to the FTX Institutional 

Customer Margin and Line of Credit Agreement. 

The Service Provider and its Affiliates may, in its sole discretion, perform 

measures to mitigate potential losses to you on your behalf, or to other 

Users. Such measures include attempts by the Platform's risk engine to 

liquidate any Users before they could get a negative net Account balance. 

Using spot margin trading therefore opens you up to liquidation risk.

The Service Provider may impose margin position limits or decreasing 

collateral on large positions of illiquid coins.

The Digital Assets that are available for borrowing/lending are listed on 

the Site. This list may be amended from time to time by the Service 

Provider at its sole discretion.

Digital Assets that are lent to other Users are effectively locked, and 

cannot be withdrawn/sold/used as collateral/staked/etc. However, they 

can be used as maintenance margin to prevent liquidations.

The Service Provider reserves the right to final interpretation of this 

Specified Service.

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Risk disclosures Margin trading may not be suitable for all Users and should only be used 

by those who understand the risks. Also see Section 2.4 of the General 

Terms.

THE SERVICE PROVIDER AND ITS AFFILIATES DO NOT TAKE ANY 

RESPONSIBILITY WHATSOEVER FOR ANY LOSSES OR DAMAGE 

INCURRED AS A RESULT OF YOUR USE OF ANY MARGIN TRADING 

SERVICES OFFERED ON THE PLATFORM OR YOUR FAILURE TO 

UNDERSTAND THE RISKS ASSOCIATED WITH MARGIN TRADING.

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SCHEDULE 4 

SERVICE SCHEDULE

Specified Service OTC / Off-exchange Portal (OEP Portal) 

Specified Service 

description

The OEP Portal enables you to connect with other Users to request 

quotes for spot Digital Assets. In response to a request for a quote, other 

Users will return prices offered by them in respect of the Digital Assets 

and you may decide whether or not you wish to trade at the price offered 

by the other User. Affiliates of FTX Trading may participate on the OEP 

Portal as Users and execute trades (as principal) with other Users, on 

terms no more favourable to such Affiliate than terms offered to other 

similarly situated Users. If you agree, the trade is confirmed, and you will 

trade directly with the other User. The Service Provider will carry out posttrade clearing and settlement of the trade between you and the other 

User.

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Digital Markets Ltd, an International Business Company incorporated in 

The Bahamas (company registration number 207269 B), to all eligible 

Users other than persons who have their registered office or place of 

residence in the United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

The Service Provider shall have no liability in relation to your use of the 

OEP Portal or for any trades that you enter into with other Users that you 

connect with through the OEP Portal. 

The Service Provider reserves the right to final interpretation of this 

Specified Service.

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SCHEDULE 5 

SERVICE SCHEDULE

Specified Service Futures Market 

Specified Service 

description

The Futures Market is a trading platform on which you can trade Quarterly 

Futures Contracts and Perpetual Futures Contracts (collectively, Futures 

Contracts) on certain Digital Assets and Digital Asset indexes with other 

Users, with or without leverage.

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Digital Markets Ltd, an International Business Company incorporated in 

The Bahamas (company registration number 207269 B), to all eligible 

Users other than persons who have their registered office or place of 

residence in the United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

Quarterly Futures Contracts represent obligations to buy or sell a Digital 

Asset at a specific price, on a specified future date. Quarterly Futures 

Contracts expire to a time-weighted average price ("TWAP") of their 

associated index on the last Friday of every quarter between 2am and 

3am UTC. If you hold an expiring position, you will be credited with USD 

profit and loss equal to the expiration price shortly after.

Perpetual Futures Contracts represent obligations to buy or sell a Digital 

Asset at a specific price, at any time while the contract remains open. 

Perpetual Futures Contracts do not have an expiry date but instead, 

continuously roll over, i.e. every hour, each perpetual futures contract has 

a funding payment where longs pay shorts equal to 1 hour TWAP of 

Premium / 24.

You can trade Futures Contracts on the Futures Market by posting 

collateral in the form of fiat currency (depending on your jurisdiction) and 

Digital Assets to cover initial and maintenance margin.

Instead of delivery of the underlying Digital Asset, your profit or loss is 

settled in stablecoins.

IMPORTANT: Section 16 of the General Terms applies to this service.

Futures Contracts are Complex Products and the trading of Futures 

Contracts is high risk. The market price of any Futures Contract may not 

reflect the price of spot markets in the applicable underlying Digital Assets 

and may fluctuate significantly in response to the value of the underlying 

Digital Asset’s(s') price, supply and demand, and other market factors.

In order to trade Futures Contracts on the Futures Market, you must post 

collateral. Depending on market movements, your positions may be 

liquidated, and you may sustain a total loss of the Assets in your Account. 

This is because Futures Contract trading can be highly leveraged, with a 

relatively small amount of funds used to establish a position in a Digital 

Asset or index having a much greater value. For instance, a small price 

decrease on a 20x leveraged Futures Contact’s underlying Digital Asset 

could result in 20x loss in your leveraged position in the Futures Contract. 

Further, short positions will lose money when the price of the underlying 

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Digital Asset rises, a result that is opposite from holding the underlying 

Digital Asset. 

YOU AGREE AND HEREBY AUTHORISE THE SERVICE PROVIDER 

AND ITS AFFILIATES TO TAKE ANY MEASURES IN THEIR SOLE 

DISCRETION, INCLUDING BUT NOT LIMITED TO, FORCED POSITION 

REDUCTION AND LIQUIDATION UNDER MARKET VOLATILITY, 

ILLIQUIDITY AND OTHER CIRCUMSTANCES, FOR THE PURPOSES 

OF MITIGATING POTENTIAL LOSSES TO YOU, OTHER USERS, AND 

THE SERVICE PROVIDER AND ITS AFFILIATES.

By trading in Futures Contracts on the Futures Market on the Platform, 

you acknowledge and agree that you have sufficient investment 

knowledge, financial expertise, and experience and the capacity to take 

on the increased risks arising from Futures Contract trading. You further 

agree to independently assume all the risks arising from conducting 

Futures Contract trading on your own account. If you are uncomfortable 

with this level of risk, you should not trade Futures Contracts.

THE SERVICE PROVIDER AND ITS AFFILIATES DO NOT TAKE ANY 

RESPONSIBILITY WHATSOEVER FOR ANY LOSSES OR DAMAGE 

INCURRED AS A RESULT OF YOUR TRADING FUTURES 

CONTRACTS ON THE PLATFORM OR YOUR FAILURE TO 

UNDERSTAND THE RISKS ASSOCIATED WITH FUTURES 

CONTRACT TRADING.

The Service Provider reserves the right to final interpretation of this 

Specified Service.

Risk disclosures See Section 2 of the General Terms.

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SCHEDULE 6 

SERVICE SCHEDULE

Specified Service Volatility Market (Options Contacts)

Specified Service 

description

The Volatility Market is a trading platform on which you can trade Call 

Options or Put Options (collectively, Options Contracts) on certain 

Digital Assets with other Users, with or without leverage.

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Digital Markets Ltd, an International Business Company incorporated in 

The Bahamas (company registration number 207269 B), to all eligible 

Users other than persons who have their registered office or place of 

residence in the United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

Options Contracts give you the option (i.e. the right, but not the 

obligation), to either buy (Call Option) or sell (Put Option) Digital Assets 

for a specific price (the strike or exercise price) on a specified expiry date.

If, at the expiration of a Call Option, the market price of the underlying 

Digital Asset is higher than the strike price, the Service Provider will 

automatically exercise the option and credit your Account with the 

difference between the market price and the strike price. If the market 

price is lower, the option expires to USD 0.00. In the case of Put Options, 

the reverse applies.

You can trade Options Contracts on the Volatility Market by posting 

collateral in fiat currency (depending on your location) and Digital Assets, 

to cover initial and maintenance margin.

Instead of delivery of the underlying Digital Asset on the specified expiry 

date, your profit or loss is settled in stablecoins.

IMPORTANT: Section 16 of the General Terms applies to this service.

The Options Contracts on the Volatility Market are European style. This 

means that you will not be able to exercise the option before the specified 

expiry date.

The Options Contracts auto-expire, which means that the Service 

Provider will automatically exercise all options "in the money" and no 

options "out of the money".

The Options Contracts expire on their specified expiry date at 3:00:00AM 

UTC. The expiration price of the underlying Digital Asset is based on a 1-

hour TWAP of the underlying index the hour before expiration.

Options Contracts are Complex Products and the trading of Options 

Contracts is high risk. In order to trade Options Contracts on the Volatility 

Market, you must post collateral. Depending on market movements, your 

positions may be liquidated, and you may sustain a total loss of the 

Assets in your Account. This is because Options Contract trading is highly 

leveraged, with a relatively small amount of funds used to establish a 

position in a Digital Asset having a much greater value. 

If you are uncomfortable with this level of risk, you should not trade 

Options Contracts.

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THE SERVICE PROVIDER AND ITS AFFILIATES DO NOT TAKE ANY 

RESPONSIBILITY WHATSOEVER FOR ANY LOSSES OR DAMAGE 

INCURRED AS A RESULT OF YOUR TRADING OPTIONS 

CONTRACTS ON THE PLATFORM OR YOUR FAILURE TO 

UNDERSTAND THE RISKS ASSOCIATED WITH OPTIONS 

CONTRACTS TRADING.

The Service Provider reserves the right to final interpretation of this 

Specified Service.

Risk disclosures See Section 2 of the General Terms.

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SCHEDULE 7 

SERVICE SCHEDULE

Specified Service Volatility Market (MOVE Volatility Contracts)

Specified Service 

description

The Volatility Market is a trading platform on which you can trade Daily 

MOVE Volatility Contracts, Weekly MOVE Volatility Contracts and 

Quarterly MOVE Volatility Contracts (collectively, MOVE Volatility 

Contracts) with other Users, with or without leverage.

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Digital Markets Ltd, an International Business Company incorporated in 

The Bahamas (company registration number 207269 B), to all eligible 

Users other than persons who have their registered office or place of 

residence in the United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

MOVE Volatility Contracts represent the absolute value of the amount a 

Digital Asset moves in a period of time, i.e. a day, week or quarter.

MOVE Volatility Contracts expire to the absolute value of the difference 

between the TWAP price of the underlying Digital Asset over the first hour 

and the TWAP price of the underlying Digital Asset over the last hour of 

their expiration time, measured in UTC.

1. Daily MOVE Volatility Contracts expire to the movement of BTC 

over a single day's period. Their ticker is [underlying]-MOVE-

[expiration date]; e.g. BTC-MOVE-1116 is the BTC-MOVE Volatility 

Contract expiring at the end of 16 November UTC.

2. Weekly MOVE Volatility Contracts expire to the movement of BTC 

over a 7 day period. Their ticker is [underlying]-MOVE-WK-

[expiration date]; e.g. BTC-MOVE-WK-1122 expires to the amount 

that BTC moves between the start of 16 November and the end of 

22 November.

3. Quarterly MOVE Volatility Contracts expire to the move of BTC 

over a roughly 3 month period. Their ticker is [underlying]-MOVE-

[expiration year]Q[quarter number]; e.g. BTC-MOVE-2020Q2 

expires to the amount that BTC moves during Q2 2020, from 27 

March 2020 to 25 June 2020.

You can trade Move Volatility Contracts on the Volatility Market by posting 

collateral in the form of fiat currency (depending on your location) and 

Digital Assets to cover initial and maintenance margin.

IMPORTANT: Section 16 of the General Terms applies to this service.

MOVE Volatility Contracts are Complex Products and the trading of 

MOVE Volatility Contracts is high risk. In order to trade MOVE Volatility 

Contracts on the Volatility Market, you must post collateral. Depending on 

market movements, your positions may be liquidated, and you may 

sustain a total loss of the Assets in your Account. This is because MOVE 

Volatility Contract trading is highly leveraged, with a relatively small 

amount of funds used to establish a position in a Digital Asset having a 

much greater value. 

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If you are uncomfortable with this level of risk, you should not trade 

MOVE Volatility Contracts.

THE SERVICE PROVIDER AND ITS AFFILIATES DO NOT TAKE ANY 

RESPONSIBILITY WHATSOEVER FOR ANY LOSSES OR DAMAGE 

INCURRED AS A RESULT OF YOUR TRADING MOVE VOLATILITY 

CONTRACTS ON THE PLATFORM OR YOUR FAILURE TO 

UNDERSTAND THE RISKS ASSOCIATED WITH MOVE VOLATILITY 

CONTRACTS TRADING.

The Service Provider reserves the right to final interpretation of this 

Specific Service.

Risk disclosures See Section 2 of the General Terms.

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SCHEDULE 8

SERVICE SCHEDULE

Specified Service Leveraged Tokens Spot Market 

Specified Service 

description

The Leveraged Tokens Market is a trading platform on which you can 

spot trade Leveraged Tokens on certain Digital Assets with other Users.

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Trading Ltd, a company incorporated and registered in Antigua and 

Barbuda (company number 17180), to all eligible Users other than 

persons who have their registered office or place of residence in the 

United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

Leveraged Tokens are "ERC-20" digital tokens issued by LT Baskets Ltd, 

an Affiliate of FTX Trading. Each Leveraged Token has an associated 

account on the Platform that takes leveraged positions on Perpetual 

Futures Contracts on an underlying Digital Asset or Digital Asset index

(collectively "Underlying") and can be created or redeemed for its share 

of the Digital Assets of that account.

Leveraged Tokens seek (but under no circumstances guarantee) daily 

results, before fees and expenses, that correspond to 300% or 3x 

("BULL"), -100% or -1x ("HEDGE"), or -300% or -3x ("BEAR") of the daily 

return of the Underlying (in U.S. Dollars) for a single day, not for any other 

period. A Leveraged Token's returns for a period longer than a single day 

will be the result of its return for each day, compounded over that period, 

and could differ in amount and direction from the return of the Underlying 

over the same period.

A Leveraged Token's returns may also deviate from expected returns in a 

period shorter than a single day for reasons including, but not limited to, 

scheduled or unscheduled rebalancing. Scheduled rebalancing occurs 

once daily in order to maintain the Leveraged Token's intended exposure 

to the market price of the Underlying. Unscheduled rebalancing may 

occur, for example, if the market price of the Underlying moves more than 

10% in either direction within a single day in order to maintain the 

Leveraged Token's intended returns.

Leverage Tokens are Complex Products, and the trading of Leveraged 

Tokens is high risk. The market price of any Leveraged Token may not 

reflect the price of spot markets in the applicable Underlying and may 

fluctuate significantly in response to the value of the Underlying’s price, 

supply and demand, and other market factors.

Leveraged Tokens reduce the risk of liquidation (as compared to Futures 

Contracts for example) but it is still possible that liquidation may occur; if 

markets instantaneously gap down 50%, there is nothing that can stop a 

+3x leveraged position from getting liquidated. 

YOU AGREE AND HEREBY AUTHORISE THE SERVICE PROVIDER 

AND ITS AFFILIATES TO TAKE ANY MEASURES IN THEIR SOLE 

DISCRETION, INCLUDING BUT NOT LIMITED TO, FORCED POSITION 

REDUCTION AND LIQUIDATION UNDER MARKET VOLATILITY, 

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ILLIQUIDITY AND OTHER CIRCUMSTANCES, FOR THE PURPOSES 

OF MITIGATING POTENTIAL LOSSES TO YOU, OTHER USERS, AND 

THE PLATFORM.

By trading in Leveraged Tokens on the Platform, you acknowledge and 

agree that you have sufficient investment knowledge, financial expertise, 

and experience and the capacity to take on the increased risks arising 

from Leveraged Tokens trading. You further agree to independently 

assume all the risks arising from conducting Leveraged Tokens trading on 

your own account. 

If you are uncomfortable with this level of risk, you should not trade 

Leveraged Tokens.

THE SERVICE PROVIDER AND ITS AFFILIATES DO NOT TAKE ANY 

RESPONSIBILITY WHATSOEVER FOR ANY LOSSES OR DAMAGE 

INCURRED AS A RESULT OF YOUR TRADING LEVERAGED TOKENS 

ON THE PLATFORM OR YOUR FAILURE TO UNDERSTAND THE 

RISKS ASSOCIATED WITH LEVERAGED TOKEN TRADING.

The Service Provider reserves the right to final interpretation of this 

Specific Service.

Risk disclosures Leveraged Tokens do not require Users to trade on margin. However, 

they remain subject to certain risks that you should understand before 

trading Leveraged Tokens, including but not limited to:

x Market price variance risk: Holders buy and sell Leveraged Tokens 

in the secondary market at market prices, which may be different from 

the value of the Underlying. The market price for a Leveraged Token 

will fluctuate in response to changes in the value of the Leveraged 

Token’s holdings, supply and demand for the Leveraged Token and 

other market factors.

x Inverse correlation risk: Holders of Leveraged Tokens that target an

inverse return will lose money when the price of the Underlying rises, 

a result that is opposite from holding the Underlying.

x Portfolio turnover risk: Leveraged Tokens may incur high portfolio 

turnover to manage the exposure to the Underlying. Additionally, 

active market trading of a Leveraged Token’s holding may cause 

more frequent creation or redemption activities that could, in certain 

circumstances, increase the number of portfolio transactions. High 

levels of transactions increase transaction costs. Each of these 

factors could have a negative impact on the performance of a 

Leveraged Token.

x Interest rates: Leveraged Tokens take positions in Perpetual Futures 

Contracts to achieve their desired leverage. These Perpetual Futures 

Contracts might trade at a premium or discount to spot markets in the 

applicable Underlying as a reflection of prevailing interest rates in 

cryptocurrency markets. Thus, a Leveraged Token could outperform 

or underperform the Underlying’s spot market returns due to a 

divergence between the two markets.

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SCHEDULE 9

SERVICE SCHEDULE

Specified Service Volatility Market (BVOL/iBVOL Tokens)

Specified Service 

description

The Volatility Market is a trading platform on which you can trade BVOL 

Tokens and iBVOL Tokens (collectively, BVOL/iBVOL Tokens) with 

other Users, with or without leverage. 

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Trading Ltd, a company incorporated and registered in Antigua and 

Barbuda (company number 17180), to all eligible Users other than 

persons who have their registered office or place of residence in the 

United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

BVOL/iBVOL Tokens are "ERC-20" digital tokens issued by LT Baskets 

Ltd, an Affiliate of FTX Trading. Each BVOL/iBVOL Token has an 

associated account on the Platform that holds MOVE Volatility Contracts

and Perpetual Futures Contracts on BTC (collectively, "Underlying"), in 

an attempt to track the implied percent-based volatility of BTC. In 

particular, BVOL Tokens attempt to track the daily returns of being 1x 

long the implied volatility of BTC and iBVOL Tokens attempt to track the 

daily returns of being 1x short the implied volatility of BTC.

In order to get their volatility exposure, BVOL Tokens trade MOVE 

Volatility Contracts and Perpetual Futures on BTC. In particular, they aim 

to hold 1/6th each of each MOVE Volatility Contract that has not yet had 

its strike price determined as of each rebalance. That means 1/6th each 

of:

x Tomorrow's MOVE Volatility contract

x Next weeks' MOVE contract, and the two weeks after that

x Next Quarter's MOVE contract, and the quarter after that

and

x -1x BTC-PERP (Short) 

IBVOL, conversely, aims to hold -1/6th each of those MOVE Volatility 

contracts and 1x Perpetual Futures Contract on BTC (Long).

BVOL targets +1x leverage, and IBVOL targets -1x leverage. As such, 

BVOL should not need to significantly alter its leverage at rebalance time 

(00:02:00 UTC every day): there may be small amounts of slippage but by 

and large its leverage should always be 1. IBVOL, however, will need to. 

If volatility is down, iBVOL will have gains and will reinvest them by selling 

more MOVE contracts; if volatility is up, iBVOL will have losses and will 

buy back MOVE contracts to reduce risk and attempt to avoid liquidation. 

Because of this BVOL almost completely avoids liquidation risk, but 

IBVOL is at risk if volatility doubles in a day. To mitigate this, iBVOL also 

has daily rebalances. If market moves cause iBVOL's leverage to reach -

4/3, it will do an intraday rebalance to reduce risk. 

YOU AGREE AND HEREBY AUTHORISE THE SERVICE PROVIDER 

AND ITS AFFILIATES TO TAKE ANY MEASURES IN THEIR SOLE 

DISCRETION, INCLUDING BUT NOT LIMITED TO, FORCED POSITION 

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REDUCTION AND LIQUIDATION UNDER MARKET VOLATILITY, 

ILLIQUIDITY AND OTHER CIRCUMSTANCES, FOR THE PURPOSES 

OF MITIGATING POTENTIAL LOSSES TO YOU, OTHER USERS, AND 

THE PLATFORM.

BVOL/iBVOL Tokens are Complex Products and the trading of 

BVOL/iBVOL Tokens is high risk. The market price of any BVOL/iBVOL 

Token may not reflect the price of spot markets in BTC and may fluctuate 

significantly in response to the value of BTC’s price, supply and demand, 

and other market factors.

By trading in BVOL/iBVOL Tokens on the Platform, you acknowledge and 

agree that you have sufficient investment knowledge, financial expertise, 

and experience and the capacity to take on the increased risks arising 

from BVOL/iBVOL Tokens trading. You further agree to independently 

assume all the risks arising from conducting BVOL/iBVOL Tokens trading 

on your own account. 

If you are uncomfortable with this level of risk, you should not trade 

BVOL/iBVOL Tokens.

THE SERVICE PROVIDER AND ITS AFFILIATES DO NOT TAKE ANY 

RESPONSIBILITY WHATSOEVER FOR ANY LOSSES OR DAMAGE 

INCURRED AS A RESULT OF YOUR TRADING BVOL/iBVOL TOKENS 

ON THE PLATFORM OR YOUR FAILURE TO UNDERSTAND THE 

RISKS ASSOCIATED WITH BVOL/iBVOL TOKEN TRADING.

The Service Provider reserves the right to final interpretation of this 

Specified Service.

Risk disclosures BVOL/iBVOL Tokens do not require Users to trade on margin. However, 

they remain subject to certain risks that you should understand before 

trading BVOL/iBVOL Tokens, including but not limited to:

x Market price variance risk: Holders buy and sell BVOL/iBVOL 

Tokens in the secondary market at market prices, which may be 

different from the value of BTC. The market price for a BVOL/iBVOL 

Tokens will fluctuate in response to changes in the value of the 

BVOL/iBVOL Tokens holdings, supply and demand for the 

BVOL/iBVOL Tokens and other market factors.

x Portfolio turnover risk: BVOL/iBVOL Tokens may incur high 

portfolio turnover to manage the exposure to the Underlying. 

Additionally, active market trading of a BVOL/iBVOL Token’s holding 

may cause more frequent creation or redemption activities that could, 

in certain circumstances, increase the number of portfolio 

transactions. High levels of transactions increase transaction costs. 

Each of these factors could have a negative impact on the 

performance of a BVOL/iBVOL Tokens.

x Interest rates: BVOL/iBVOL Tokens take positions in MOVE Volatility 

Contracts and Perpetual Futures Contracts to achieve their desired 

implied volatility of BTC. These MOVE Volatility Contracts and 

Perpetual Futures Contracts might trade at a premium or discount to 

spot markets in BTC as a reflection of prevailing interest rates in 

cryptocurrency markets. Thus, a BVOL/iBVOL Token could 

Case 1:22-cv-23753-KMM Document 153-3 Entered on FLSD Docket 04/14/2023 Page 45 of

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outperform or underperform BTC’s spot market returns due to a 

divergence between the two markets.

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SCHEDULE 10

SERVICE SCHEDULE

Specified Service Issuing and redeeming Leveraged Tokens and BVOL/iBVOL Tokens

Specified Service 

description

The issuance and redemption of Leveraged Tokens and BVOL/iBVOL 

Tokens.

Service Provider This Specified Service forms part of the Services and is provided by LT 

Baskets Ltd, a company incorporated in Antigua and Barbuda (company 

number 17336), to all eligible Users other than persons who have their 

registered office or place of residence in the United States of America or 

any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms)

and risk 

disclosures

Leveraged Tokens and BVOL/iBVOL Tokens are "ERC-20" digital tokens 

issued by the Service Provider. 

Each Leveraged Token has an associated account on the Platform that 

takes leveraged positions on Perpetual Futures Contracts on an 

underlying Digital Asset or Digital Asset index. 

Each BVOL/iBVOL Token has an associated account on the Platform that 

holds MOVE Volatility Contracts and Perpetual Futures Contracts on 

BTC, in an attempt to track the implied percent-based volatility of BTC. In 

particular, BVOL Tokens attempt to track the daily returns of being 1x 

long the implied volatility of BTC and iBVOL Tokens attempt to track the 

daily returns of being 1x short the implied volatility of BTC.

You may place orders with the Service Provider to issue new Leveraged 

Tokens or BVOL/iBVOL Tokens by depositing stablecoins. 

You can redeem an existing Leveraged Token for its share of the Digital 

Assets of the Leveraged Token's associated account on the Platform.

You can redeem existing BVOL/iBVOL Contracts for an equivalent 

amount of stablecoins. 

Creating or redeeming Leveraged Tokens and BVOL/iBVOL Tokens will 

have market impact and you won't know what price you ultimately get until 

after you have created or redeemed the Leveraged Token or 

BVOL/iBVOL Token (as applicable). 

THE SERVICE PROVIDER AND ITS AFFILIATES DO NOT TAKE ANY 

RESPONSIBILITY WHATSOEVER FOR ANY LOSSES OR DAMAGE 

INCURRED AS A RESULT OF YOUR ORDERING OR REDEEMING 

LEVERAGED TOKENS OR BVOL/iBVOL TOKENS ON THE PLATFORM 

OR YOUR FAILURE TO UNDERSTAND THE RISKS ASSOCIATED 

WITH LEVERAGED TOKENS AND BVOL/iBVOL TOKENS. 

The Service Provider reserves the right to final interpretation of this 

Specified Service.

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SCHEDULE 11 

SERVICE SCHEDULE

Specified Service NFT Market

Specified Service 

description

The NFT Market is a trading platform on which you can trade non-fungible 

tokens ("NFT") with other Users for fiat currency or Digital Assets and 

offer to sell them by auction.

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Trading Ltd, a company incorporated and registered in Antigua and 

Barbuda (company number 17180), to all eligible Users other than 

persons who have their registered office or place of residence in the 

United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms) 

and risk 

disclosures

NFTs are controllable electronic records recorded on the Ethereum and/or 

Solana blockchains, or any other blockchain(s) as determined by us in our 

sole discretion. 

Unlike most cryptocurrencies, there may be very few or only one of an 

NFT, and they might be indivisible, meaning it may not be fungible with 

any other tokens.

NFTs can take a number of forms. Sometimes, they can be redeemed for 

a physical object. Sometimes the owner is entitled to an experience, like a 

movie or a phone call. Sometimes they are associated with a digital 

image. Sometimes they are associated with nothing at all.

NFTs do not necessarily have any intrinsic value. They might also be 

illiquid. If you buy an NFT, you are not necessarily going to be able to sell 

it for much later or gain any specific utility from it.

While the Service Provider may facilitate the ability to sell, re-sale, buy, 

transfer, withdraw, or otherwise engage in transactions involving the 

purchase, sale, or other transfer of a NFT through the NFT Market, this 

functionality is provided without any guarantees of uptime, functionality, or 

serviceability. The Service Provider reserves the right to remove or 

otherwise limit any and all functionality, or to require additional conditions 

of access, for all Users or any User or group of Users of the NFT Market, 

as determined by the Service Provider in its sole discretion. 

You are welcome to buy NFTs if it would make you happy to own them. 

But there is no implied economic return associated with doing so.

There are no refunds for NFTs, and the Service Provider and its Affiliates 

will not field customer complaints. You should only buy NFTs if you 

understand that doing so does not necessarily give any direct economic 

value.

NFTS ARE INTANGIBLE DIGITAL ASSETS. THEY EXIST ONLY BY 

VIRTUE OF THE OWNERSHIP RECORD MAINTAINED IN THE 

APPLICABLE BLOCKCHAIN NETWORK. ANY TRANSFER OF TITLE 

THAT MIGHT OCCUR IN ANY UNIQUE DIGITAL ASSET OCCURS ON 

THE DECENTRALISED LEDGER WITHIN SUCH BLOCKCHAIN 

NETWORK, WHICH WE DO NOT CONTROL. THE SERVICE 

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PROVIDER DOES NOT GUARANTEE THAT IT CAN EFFECT THE 

TRANSFER OF TITLE OR RIGHT IN ANY NFT.

THE SERVICE PROVIDER AND ITS AFFILIATES DO NOT TAKE ANY 

RESPONSIBILITY WHATSOEVER FOR ANY LOSSES OR DAMAGE 

INCURRED AS A RESULT OF YOUR TRADING NFT ON THE 

PLATFORM OR YOUR FAILURE TO UNDERSTAND THE RISKS 

ASSOCIATED WITH NFT TRADING.

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SCHEDULE 12 

SERVICE SCHEDULE

Specified Service NFT Listing

Specified Service 

description

Creating an NFT on the portal located at https://ftx.com/nfts/list (the "NFT 

Site") that, as of its genesis issuance, is linked to the artwork, digital 

content or other collectible that is provided by you to the Service Provider

("Artwork"). 

Service Provider This Specified Service forms part of the Services and is provided by FTX 

Trading Ltd, a company incorporated and registered in Antigua and 

Barbuda (company number 17180), to all eligible Users other than 

persons who have their registered office or place of residence in the 

United States of America or any Restricted Territory.

Specified Service 

specific terms (in 

addition to the 

General Terms) 

and risk 

disclosures

By submitting a request and creating an NFT on the NFT Site, you 

acknowledge that you have carefully read and agree to the Terms.

If there is a conflict between the General Terms and this Service 

Schedule with respect to your use of the NFT Site or your NFTs, this 

Service Schedule shall prevail.

Your access to and use of the NFT Site is also governed by the terms in 

the General Terms that apply to the Site and references in the General 

Terms to "Site" should be read as including the NFT Site, unless the 

context provides otherwise. 

Intellectual property 

You represent and warrant that you own and control all rights in and to 

your Artwork and have the right to grant licenses to the Service Provider

and its Affiliates and respective licensees and successors. In submitting 

any Artwork, you must not include any third party intellectual property 

(such as copyrighted materials) unless you have explicit permission from 

that party or are otherwise legally entitled to do so. You are legally 

responsible for all Artwork submitted by you. The Service Provider

reserves the right to review and analyse your Artwork to help detect 

infringement and abuse, such as spam, malware and illegal content.

By submitting any Artwork, you grant the Service Provider a worldwide, 

non-exclusive, royalty-free, perpetual, sublicensable and transferable 

license to use the Artwork for any purpose, including for the minting of the 

NFT linked to your Artwork and hosting such Artwork for you and future 

transferees of the NFT, as well as for the promotion of the Services

provided by the Service Provider and its Affiliates. 

You also grant all other Users and future holders of your NFT a 

worldwide, non-exclusive, perpetual, and royalty-free license to view and 

access your Artwork.

Prohibited activities

You will not:

Case 1:22-cv-23753-KMM Document 153-3 Entered on FLSD Docket 04/14/2023 Page 50 of

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x submit any Artwork that (a) violates or encourages any conduct 

that would violate any Applicable Law or regulation or would give 

rise to civil or criminal liabilities; (b) is fraudulent, false, misleading 

or deceptive; (c) is defamatory, obscene, vulgar, pornography or 

offensive; (d) promotes discrimination, bigotry, racism, hatred, 

harassment or harm against any individual or group; (e) is violent 

or threatening or promotes violence or actions that are 

threatening to any person or entity; or (f) promotes illegal or 

harmful activities or substantives;

x attack, hack, DDOS, interfere with, or otherwise tamper with the 

NFT or its underlying smart contract; 

x access, tamper with or attempt to access the Service Provider 

and its Affiliates' computer systems or networks;

x attempt to probe, scan or test the vulnerability of the Service 

Provider and its Affiliates' system or network or breach any 

security or authentication measures;

x avoid, bypass, remove, deactivate, impair or otherwise 

circumvent any technological measures; 

x interfere with, or attempt to interfere with, any other User or 

network, including without limitation sending a virus, overloading, 

flooding, spamming or mail-bombing;

x impersonate or misrepresent your identity or affiliation;

x use the NFT, the NFT Site or the Services, to conceal or transfer 

any proceeds relating to illegal or criminal activity;

x violate the Terms or any Applicable Law or regulation; or

x encourage or enable any third party to do any of the foregoing.

No obligations

The Service Provider and its Affiliates are not responsible for repairing, 

supporting, replacing or maintaining any website or network hosting your 

Artwork, nor do they have the obligation to maintain any connection or link 

between your NFT and the underlying Artwork. The Service Provider

reserves the right to terminate, delete, take down or otherwise remove the 

Artwork and disconnect the link between the applicable NFT and the 

underlying Artwork at any time for any reason, including but not limited to 

if (a) you or any other NFT holder engage in any illegal or unlawful 

activity, (b) you or any other NFT holder are deemed to be in violation of 

the intellectual property rights of third parties, in each case as determined 

by the Service Provider in its sole discretion.

While the Service Provider may facilitate the ability to sell, re-sale, buy, 

transfer, withdraw, or otherwise engage in transactions involving the 

purchase, sale, or other transfer of a NFT, this functionality is provided 

without any guarantees of uptime, functionality, or serviceability. The 

Service Provider reserves the right to remove or otherwise limit any and 

all functionality, or to require additional conditions of access, for all Users 

or any User or group of Users, as determined by the Service Provider in 

its sole discretion. 

Disclaimers and risk disclosures

NFTS ARE INTANGIBLE DIGITAL ASSETS. THEY EXIST ONLY BY 

VIRTUE OF THE OWNERSHIP RECORD MAINTAINED IN THE 

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APPLICABLE BLOCKCHAIN NETWORK. ANY TRANSFER OF TITLE 

THAT MIGHT OCCUR IN ANY UNIQUE DIGITAL ASSET OCCURS ON 

THE DECENTRALISED LEDGER WITHIN SUCH BLOCKCHAIN 

NETWORK, WHICH WE DO NOT CONTROL. THE SERVICE 

PROVIDER DOES NOT GUARANTEE THAT IT CAN EFFECT THE 

TRANSFER OF TITLE OR RIGHT IN ANY NFT. 

ANY NFTS MINTED FOR YOU ARE PROVIDED “AS IS,” WITHOUT 

WARRANTY OF ANY KIND. WITHOUT LIMITING THE FOREGOING, 

THE SERVICE PROVIDER EXPLICITLY DISCLAIMS ANY IMPLIED 

WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR 

PURPOSE, QUIET ENJOYMENT AND NON-INFRINGEMENT, AND 

ANY WARRANTIES ARISING OUT OF COURSE OF DEALING OR 

USAGE OF TRADE. THE SERVICE PROVIDER MAKES NO 

WARRANTY THAT THE NFTS WILL MEET YOUR REQUIREMENTS OR 

BE AVAILABLE ON AN UNINTERRUPTED, SECURE, OR ERRORFREE BASIS. THE SERVICE PROVIDER MAKES NO WARRANTY 

REGARDING THE QUALITY, ACCURACY, TIMELINESS, 

TRUTHFULNESS, COMPLETENESS OR RELIABILITY OF ANY 

INFORMATION OR CONTENT ON THE NFT OR ITS UNDERLYING 

SMART CONTRACT OR BLOCKCHAIN NETWORK. SOME 

JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED 

WARRANTIES IN CONTRACTS WITH CONSUMERS, SO THE ABOVE 

EXCLUSION MAY NOT APPLY TO YOU.

THE SERVICE PROVIDER AND ITS AFFILIATES WILL NOT BE 

RESPONSIBLE OR LIABLE TO YOU FOR ANY LOSS AND TAKE NO 

RESPONSIBILITY FOR, AND WILL NOT BE LIABLE TO YOU FOR, ANY 

USE OF THE NFTS, INCLUDING BUT NOT LIMITED TO ANY LOSSES, 

DAMAGES OR CLAIMS ARISING FROM: (I) USER ERROR SUCH AS 

FORGOTTEN PASSWORDS, INCORRECTLY CONSTRUCTED 

TRANSACTIONS, OR MISTYPED WALLET ADDRESSES; (II) SERVER 

FAILURE OR DATA LOSS; (III) CORRUPTED CRYPTOCURRENCY 

WALLET FILES; (IV) UNAUTHORISED ACCESS; OR (V) ANY 

UNAUTHORISED THIRD PARTY ACTIVITIES, INCLUDING WITHOUT 

LIMITATION THE USE OF VIRUSES, PHISHING, BRUTEFORCING OR 

OTHER MEANS OF ATTACK AGAINST BLOCKCHAIN NETWORK 

UNDERLYING THE NFTS.

THE SERVICE PROVIDER AND ITS AFFILIATES ARE NOT 

RESPONSIBLE FOR ANY KIND OF FAILURE, ABNORMAL BEHAVIOR 

OF SOFTWARE (E.G., WALLET, SMART CONTRACT), BLOCKCHAINS 

OR ANY OTHER FEATURES OF THE NFTS. 

Indemnification; release

You shall and agree to defend, indemnify and hold harmless the Service 

Provider, its Affiliates and service providers and, in each case, their 

Personnel (collectively, "NFT Indemnified Parties" and each an "NFT 

Indemnified Party") from and against any and all claims and liabilities, 

costs, expenses, damages and losses (including any direct, indirect or 

consequential losses, loss of profit, loss of reputation and all interest, 

penalties and legal and other reasonable professional costs and 

expenses) ("NFT Losses" or "NFT Loss") which any Indemnified Party 

may suffer or incur, arising directly or indirectly out of or in connection 

with: (a) your use of the NFT Site, including the minting and creation of 

your NFT, (b) your violation or anticipatory violation of any Applicable 

Laws in connection with your use of the NFT Site or the NFTs, (c) any 

actual or alleged infringement of the intellectual property rights of others 

Case 1:22-cv-23753-KMM Document 153-3 Entered on FLSD Docket 04/14/2023 Page 52 of

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by you, and (d) any act of gross negligence, willful or intentional conduct 

by you. 

You will cooperate as fully required by the NFT Indemnified Parties in the 

defence of any such claims and NFT Losses. The NFT Indemnified 

Parties retain the exclusive right to assume the exclusive defence and 

control of any claims and NFT Losses. You will not settle any claims and 

NFT Losses without the Service Provider's prior written consent.

You hereby agree to release each of the NFT Indemnified Parties from 

any and all claims and demands (and waive any rights you may have 

against any of the NFT Indemnified Parties in relation to any NFT Losses 

you may suffer or incur), arising directly or indirectly out of or in 

connection with any dispute that you have with any other User or other 

third party in connection with the NFT Site or the NFTs.

Limitation of liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, NEITHER THE 

SERVICE PROVIDER NOR ITS AFFILIATES OR SERVICE PROVIDERS 

INVOLVED IN CREATING, PRODUCING, OR DELIVERING THE NFTS 

WILL BE LIABLE FOR ANY INCIDENTAL, SPECIAL, EXEMPLARY OR 

CONSEQUENTIAL DAMAGES, OR DAMAGES FOR LOST PROFITS, 

LOST REVENUES, LOST SAVINGS, LOST BUSINESS OPPORTUNITY, 

LOSS OF DATA OR GOODWILL, SERVICE INTERRUPTION, 

COMPUTER DAMAGE OR SYSTEM FAILURE OR THE COST OF 

SUBSTITUTE PRODUCTS OR SERVICES OF ANY KIND ARISING OUT 

OF OR IN CONNECTION WITH THIS SERVICE SCHEDULE OR FROM 

THE USE OF OR INABILITY TO USE OR INTERACT WITH THE NFTS 

OR ACCESS THE ARTWORK, WHETHER BASED ON WARRANTY, 

CONTRACT, TORT (INCLUDING NEGLIGENCE), PRODUCT LIABILITY 

OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT THE 

SERVICE PROVIDER, ITS AFFILIATES, OR ITS SERVICE PROVIDERS 

HAS BEEN INFORMED OF THE POSSIBILITY OF SUCH DAMAGE, 

EVEN IF A LIMITED REMEDY SET FORTH HEREIN IS FOUND TO 

HAVE FAILED OF ITS ESSENTIAL PURPOSE.

TO THE MAXIMUM EXTENT PERMITTED BY THE LAW OF THE 

APPLICABLE JURISDICTION, IN NO EVENT WILL THE SERVICE 

PROVIDER AND ITS AFFILIATES' TOTAL LIABILITY ARISING OUT OF 

OR IN CONNECTION WITH THIS SERVICE SCHEDULE, YOUR USE 

OF THE NFT SITE, OR YOUR USE OF OR INABILITY TO USE OR 

INTERACT WITH THE NFTS OR ACCESS THE ARTWORK EXCEED 

TEN U.S. DOLLARS (USD $10.00).

THE EXCLUSIONS AND LIMITATIONS OF DAMAGES SET FORTH 

ABOVE ARE FUNDAMENTAL ELEMENTS OF THE BASIS OF THE 

BARGAIN BETWEEN THE SERVICE PROVIDER AND YOU.

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SCHEDULE 13

SERVICE SCHEDULE

TERMS APPLICABLE TO AUSTRALIAN USERS ONLY

(Updated September 18, 2022)

Appendix A will form part of the Terms and apply to you if you are using the Exchange to buy,

sell, exchange hold or otherwise transact in Digital Assets that are being provided by FTX 

Australia.

1. FIAT CURRENCY TO DIGITAL ASSET (AND VICE VERSA) CONVERSION SERVICES

If you are depositing fiat currency, or instructing the conversion of Digital Assets to fiat

currency, the conversion of:

a) your deposit of fiat currency to Digital Assets; and

b) your withdrawal of Digital Assets to fiat currency,

will be processed by a third-party DCE provider. The name of the DCE provider is provided

on the FTX Website at the time you enter into any transaction.

You agree that you only place orders to convert fiat currency to Digital Assets (and vice

versa) with the DCE provider. You do not place orders with FTX Trading or FTX Australia 

for the conversion of fiat currency to Digital Assets or vice-versa.

If you send fiat currency to the DCE provider, the DCE provider shall convert your fiat 

currency to stablecoins automatically by default. FTX Trading does not hold client money 

or E-Money for clients of FTX Australia. Any account balances shown in fiat currency are 

provided for convenience only. All such balances are held by FTX Trading in stablecoins.

You also agree to accept any additional terms and conditions of the DCE provider relevant 

to the conversion services it is providing and disclosed to you at the time any

2. FINANCIAL SERVICES OR FINANCIAL PRODUCTS PROVIDED BY FTX AUSTRALIA

Only FTX Australia will, or may, provide you with financial services or financial products 

under its Australian Financial Services Licence.

Neither FTX Trading or the DCE provider will, or may, provide you with financial services 

or financial products.

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3. STANDING AUTHORISATION PROVIDED TO FTX AUSTRALIA

As a pre-condition to you acquiring any service or product from FTX Australia, you

acknowledge that you will provide FTX Australia with a ‘Standing Authorisation’ as set out

in the FTX Australia Terms and Conditions (“FTX Australia Terms”) to issue sell order(s)

on your behalf to the DCE, which orders will impact the Digital Assets held in your FTX 

Digital Wallet.

4. YOUR DIGITAL ASSETS ARE ONLY HELD BY FTX TRADING

Please note that you never provide Digital Assets to FTX Australia, and FTX Australia 

does not hold any client property as defined in Part 7.8, Division 3 of the 

Corporations Act 2001 (Cth).

For the avoidance of doubt, you only provide Digital Assets to FTX Trading and it is only 

FTX Trading that will ever hold your Digital Assets.

FTX Australia only maintains a Standing Authorisation in relation your Digital Assets (as

set out in the FTX Australia Terms).

5. DATA SHARING

Both FTX Trading and FTX Australia will share your personal data with each other and with

the DCE for the purposes of providing you with ‘Services’ set out in the FTX Terms, and

DCE Terms and the FTX Australia Terms.

For the avoidance of doubt, FTX Trading will only collect, maintain, use and disclose 

personal information provided to us strictly in accordance with the Australian Privacy 

Principles in the Privacy Act 1988 (Cth) and our Privacy Policy. You should carefully read 

the FTX Australia Privacy Policy, which provides details on how your personal information 

is collected, stored, protected and used by FTX Australia and any corresponding Privacy 

Policy provided by the DCE.

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SCHEDULE 14

SERVICE SCHEDULE

TERMS APPLICABLE TO SOUTH AFRICAN USERS ONLY

You acknowledge that any marketing, promotional, sales or similar activities contemplated in 

these Terms (South African activities) which take place in the Republic of South Africa are 

pursuant to FTX Trading being appointed as the juristic representative of Ovex FSP (Pty) Ltd 

(authorized FSP 50776) (Ovex) in terms of section 13(1)(b)(i)(aa) of the Financial Advisory and

Intermediary Services Act, 2002 (FAIS) and that any such South African activities will not be 

performed by FTX Trading as principal.

Where you are domiciled in South Africa, you confirm that you have voluntarily elected, pursuant 

to any South African activities performed by FTX Trading as the juristic representative of and in 

the name of Ovex, to open an Account with, use the Services and trade on the Exchange of FTX 

Trading pursuant to these Terms. You acknowledge that any client support in relation to your 

Account, the Services and the Exchange which occur within South Africa will be effected by FTX 

Trading as the juristic representative of and in the name of Ovex.

You undertake to comply with any applicable exchange control regulations or any other applicable 

laws or regulations which may, from time to time, become applicable pursuant to you opening an 

Account, using the Services and the Exchange.

Case 1:22-cv-23753-KMM Document 153-3 Entered on FLSD Docket 04/14/2023 Page 56 of

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SCHEDULE 15 

SERVICE SCHEDULE

TERMS APPLICABLE TO JAPAN USERS ONLY

(Updated September 19, 2022)

The following terms will form part of the Terms and will apply to you if you are a resident of Japan 

who is using FTX Earn or has enabled Peer-to-Peer Crypto Borrowing and Lending (“P2P Crypto 

Loans”) provided by FTX Trading. 

FTX Trading provides and operates a peer-to-peer crypto asset borrowing and lending platform for 

matching Borrowers and Lenders of P2P Crypto Loans to users of FTX Japan Corporation 

(Cryptocurrency Exchange Business Kanto Finance Bureau Director No. 00002 and Type 1 Financial 

Instruments Business registrant) (“FTX Japan”). P2P Crypto Loans are available both via the Site 

as well as via the FTX Earn program on the Mobile Application. 

By enabling and agreeing to borrow or lend P2P Crypto Loans (either via the Site or the FTX Earn 

program), you hereby acknowledge and agree that:

x you are an authorized and verified user of FTX Japan; 

x P2P Crypto Loans are not provided by FTX Japan and all P2P Crypto Loan services are 

provided solely by FTX Trading;

x you have read and understood, and agree to the Terms of Service and FTX’s Privacy Policy, 

each as amended from time to time;

x you authorize FTX Japan to share any information collected from you with FTX Trading as 

may be required under anti-money laundering laws or otherwise in compliance with 

applicable financial regulatory and other laws;

x if you’re participating in the FTX Earn program, you are lending your crypto assets to third 

party borrowers in return for rewards which are variable for each crypto asset and changes 

hourly;

x you hereby authorize FTX Trading to instruct FTX Japan to borrow from and lend assets to 

Lenders and Borrowers, respectively, and to take all such actions as may be required to 

complete such P2P Crypto Loans on your behalf;

x you will only participate in P2P Crypto Loans for your own account and not for the account 

of others; 

x you will not use P2P Crypto Loans for any illegal activities, unlawful conduct or other 

restricted purposes as set forth in the Terms; 

x FTX Trading does not act as borrower or lender of any P2P Crypto Loans; and 

Only FTX Japan users are eligible to participate in P2P Crypto Loans, either as a borrower or as a 

lender.

Case 1:22-cv-23753-KMM Document 153-3 Entered on FLSD Docket 04/14/2023 Page 57 of

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Lending

To become a P2P Crypto Loan lender (“Lender”), you must have first deposited assets with FTX 

Japan into your FTX Japan account (“Account”). As a Lender, you can select “LEND” on the P2P 

Crypto Loans website or participate in the FTX Earn program on the Mobile Application, and specify 

the amount, minimum rate and type of crypto asset that you wish to lend out in order to become 

eligible to lend out your crypto assets. Your lending offer will then be submitted to FTX Trading’s P2P 

Crypto Loan order book and automatically matched with borrowers, if any. 

The amount of funds borrowed, funding rates and estimated funding rates are based solely on 

historical data, are not guaranteed and are subject to frequent change on an hourly basis. There is 

no assurance that you will be able to lend out your crypto assets, that there will be any borrowers 

available to you, that there will be any demand for crypto borrowing, or that any of the displayed 

lending rates are accurate. FTX Trading reserves the right, in its sole discretion, to determine the 

ordering and matching of Lenders and Borrowers. You further agree to pay any platform charges or 

fees that FTX Trading may provide from time to time. 

You are not required to lend out any assets at any time. To stop lending out your assets, (a) go to 

the P2P Crypto Loans website and click on “STOP LENDING” at any time, or (b) if you are 

participating in the FTX Earn program on the Mobile Application, click on “Disable” in “Profile” Æ

“Earn rewards on assets”.

All loans of crypto assets via the P2P Crypto Loans website are non-recourse loans. You agree that 

your sole recourse in the event of default of a Borrower’s P2P Crypto Loan is the seizure and/or 

liquidation of assets held in the Borrower’s Account. You agree, and shall cause all of your agents, 

representatives and affiliates to agree, not to seek recourse or recompense against any funds, assets 

or properties owned by a Borrower outside of the Borrower’s Account at any time. 

LENDING CRYPTO ASSETS VIA P2P CRYPTO LOANS IS VERY HIGH RISK AND ARE NOT 

INSURED IN ANY WAY BY FTX TRADING, ANY GOVERNMENTAL AGENCY, OR ANY THIRD 

PARTY. AS A LENDER, YOU MAY SUSTAIN A TOTAL LOSS OF YOUR LENT CRYPTO ASSETS 

IF THE BORROWER DEFAULTS ON A P2P CRYPTO LOAN AND SEIZURE AND/OR 

LIQUIDATION OF THE BORROWER’S ACCOUNT FAIL TO REPAY SUFFICIENT CRYPTO 

ASSETS TO COVER THE BORROWER’S DEBT TO YOU OR OTHER LENDERS. 

Borrowing

To become a P2P Crypto Loan borrower (“Borrower”), you must have first deposited crypto assets 

with FTX Japan into your Account as collateral. As a borrower, you can select “Enable Peer to Peer 

borrowing” on the P2P Crypto Loans website to enable borrowing of crypto assets from other FTX 

Japan users. The amount of crypto assets that you are entitled to borrow from time to time is 

determined based on a number of factors, including the amount of crypto assets made available by 

lenders for borrowing, the amount of crypto assets available in your Account as collateral, crypto 

asset market liquidity and volatility conditions, national, regional and global economic conditions, 

legal and regulatory requirements, as well as other factors that FTX Trading may consider from time 

to time. 

All borrowed crypto assets using the P2P Crypto Loans website are non-recourse with respect to 

any assets held by the Borrower in the Borrower’s Account. In other words, in the event of default, 

neither FTX Trading, any Lenders, nor any of their affiliates, agents or representatives may seek 

recourse or recompense against any funds, assets or properties owned by a Borrower outside of the 

Borrower’s Account. In the event of default of a Borrower’s P2P Crypto Loan, the sole recourse of 

any Lender is the seizure and/or liquidation of assets held in the Borrower’s Account.

Case 1:22-cv-23753-KMM Document 153-3 Entered on FLSD Docket 04/14/2023 Page 58 of

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You agree to pay (a) any interest charges that may accrue on your P2P Crypto Loan, which you may 

view on the P2P Crypto Loans website, and (b) any platform charges or fees that FTX Trading may 

provide from time to time, which will be viewable on the P2P Crypto Loans website as well.

You are not required to borrow any crypto assets at any time. By enabling P2P Crypto Loan 

borrowing, you agree to do so at your own risk. You acknowledge and agree that any crypto assets 

borrowed from a Lender via a P2P Crypto Loan may be used for any purposes on the FTX Japan 

trading platform, including for trading, collateral and withdrawals, provided however, that you agree 

that FTX Trading may instruct FTX Japan to limit withdrawals of crypto assets borrowed under P2P 

Crypto Loans in the event that there is insufficient assets in your Account.

BORROWING P2P CRYPTO LOANS ON FTX TRADING IS VERY HIGH RISK. AS A BORROWER, 

YOU MAY SUSTAIN A TOTAL LOSS OF CRYPTO ASSETS IN YOUR ACCOUNT. THE HIGH 

VOLATILITY AND SUBSTANTIAL RISK OF ILLIQUIDITY IN THE MARKETS MEANS THAT YOU 

MAY NOT BE ABLE TO LIQUIDATE YOUR ACCOUNT ASSETS IN TIME, OR AT ALL. IF THE 

VALUE OF THE ASSETS HELD IN YOUR ACCOUNT FALLS BELOW THE MINIMUM BALANCE 

REQUIREMENT OR FTX TRADING DETERMINES IN ITS SOLE DISCRETION THAT YOUR 

ACCOUNT APPEARS TO BE IN DANGER OF DEFAULTING ON A P2P CRYPTO LOAN, FTX

TRADING OR THE APPLICABLE LENDER(S) MAY, DIRECTLY OR INDIRECTLY, SEIZE AND 

LIQUIDATE ANY OR ALL OF YOUR POSITIONS AND ASSETS IN YOUR ACCOUNT TO REPAY 

YOUR BORROWED CRYPTO ASSETS. 

Case 1:22-cv-23753-KMM Document 153-3 Entered on FLSD Docket 04/14/2023 Page 59 of

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別紙 15

サービスに関する別紙

日本のユーザーにのみ適用される規約

以下の規約は、本約款等の一部を構成し、FTX Earn を利用しているか又は FTX トレーディングが

提供する P2P 貸借暗号資産取引(以下「P2P 貸借暗号資産取引」といいます。)をご利用可能な

日本国に居住するお客様に適用されます。

FTX トレーディングは、P2P 貸借暗号資産の貸出人及び借受人のマッチングのための P2P 貸借暗

号資産取引プラットフォームを FTX Japan 株式会社(暗号資産交換事業者(登録番号関東財務局

長第 00002 号)、第一種金融商品取引業登録業者)(以下「当社」といいます。)のユーザー向

けに提供し、運営します。P2P 貸借暗号資産取引は当社ウェブサイトを通じて、また、モバイル

アプリの FTX Earn プログラムを通じて利用可能です。

(当社ウェブサイト又は FTX Earn プログラムのいずれかを通じて)P2P 貸借暗号資産取引におけ

る借受け又は貸出しを可能とし及び合意することで、お客様は以下の事項を了承し、同意します。

x お客様は当社により認定・認証されたユーザーです。

x P2P 貸借暗号資産取引は当社が提供するのではなく、P2P 貸借暗号資産取引に係るサービ

スは全て FTX トレーディングが単独で提供しています。

x お客様は、ご利用規約及び FTX のプライバシーポリシー(それぞれ随時なされる修正を含

みます。)を精読及び理解し、並びにこれらに同意しました。

x お客様は、当社がアンチマネーロンダリング法上必要な場合に又は適用ある金融規制その

他の法律に従ってお客様から収集する情報を FTX トレーディングに共有することを認めま

す。

x FTX Earnプログラムに参加されているお客様の場合、お客様の暗号資産は、各暗号資産に

応じて変更する可能性があり、1 時間単位で変動する報酬と引き換えに第三者借受人に貸

し出されます。

x お客様は、FTX トレーディングが当社に対して本貸出人及び本借受人それぞれとの間で資

産の借受け及び貸出しを行い、お客様に代わり P2P 貸借暗号資産取引を完了するために必

要な全ての措置を講じるよう指図することを認めます。

x お客様は、ご本人の勘定でのみ P2P 貸借暗号資産取引に参加し、他人の勘定で参加しませ

ん。

x お客様は、P2P 貸借暗号資産を違法行為、不法行為、その他本約款等に定める制限された

目的のために利用しません。 

x FTX トレーディングが P2P 貸借暗号資産の借受人又は貸出人となることはありません。

当社のユーザーのみが、借受人又は貸出人のいずれかとして P2P 貸借暗号資産取引に参加する資

格を有します。

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貸出し

お客様が P2P 貸借暗号資産取引の貸出人(以下「本貸出人」といいます。)となるには、まず資

産をお客様が当社に開設した口座(以下「お客様口座」といいます。)に預託する必要がありま

す。お客様は本貸出人として、P2P 貸借暗号資産取引ウェブサイトで「貸出し」を選択するか又

はモバイルアプリの FTX Earn プログラムに参加し、貸出しを希望する暗号資産の数量、最低貸借

料率及び暗号資産の種類を指定することで、お客様の暗号資産を貸し出す資格を得ます。お客様

の貸出しオファーは FTX トレーディングの P2P 貸借暗号資産取引注文板に提出され、自動的に借

受人(もしいれば)とのマッチングが行われます。

借受け額、資金調達率及び予想資金調達率は実績データのみに基づいており、保証されておらず、

1 時間ごとに頻繁に変更されます。お客様の暗号資産を貸し出すことができるか、お客様が貸し出

すことのできる借受人がいるか、暗号資産の借受けの需要があるか、又は表示された貸借料率が

正確であるかは、保証されません。FTX トレーディングは、単独の裁量において本貸出人及び本

借受人の注文及びマッチングを決定する権利を留保します。お客様はさらに FTX トレーディング

が随時定めるプラットフォーム手数料を支払うことに同意します。

お客様はいかなる時も資産を貸し出す必要はありません。お客様の資産の貸出しをストップする

には、(a) 何時でも P2P 貸借暗号資産取引ウェブサイトにアクセスして「STOP LENDING」をク

リックするか、又は(b) モバイルアプリ上で FTX Earn プログラムに参加しているお客様の場合、

「プロフィール」の「無効にする」をクリックし、「資産で利益を得られます」をクリックしま

す。

P2P 貸借暗号資産取引ウェブサイトを利用した貸し付けた暗号資産は全て責任財産限定型消費貸

借です。お客様は、本借受人の P2P 貸借暗号資産取引で債務不履行となった場合にお客様が遡及

できるのは本借受人の口座において保有されている資産の差押え及び/又は決済のみであること

に同意します。お客様は何時でも本借受人の口座外に本借受人が所有する資金、資産若しくは財

産からの償還又はこれらによる補償を求めないことに同意し、お客様の全ての代理人、代表者及

び関連会社に同意させます。

P2P 貸借暗号資産取引を通じた暗号資産の貸出しは、極めて高いリスクを伴い、FTX トレーディ

ング、政府機関又は第三者によって何ら保証されていません。本借受人が P2P 貸借暗号資産取引

で債務不履行となり、かつ本借受人の口座の差押え及び/又は決済ではお客様又は他の本貸出人

に対する本借受人の負債の補填に十分な暗号資産の返済ができない場合、お客様は本貸出人とし

て貸し出した暗号資産を全て失う可能性があります。

借受け

P2P 貸借暗号資産の借受人(以下「本借受人」といいます。)になるには、まず暗号資産を担保

としてお客様口座において当社に預託する必要があります。お客様は借受人として P2P 貸借暗号

資産取引ウェブサイトで「P2P 借受けを有効とする」を選択することで当社の他のユーザーから

暗号資産を借り受けることができます。お客様が借り受けることのできる暗号資産の数量は、貸

出人が借受けに提供する暗号資産の数量、お客様口座で担保として利用可能な暗号資産の数量、

暗号資産市場の流動性及びボラティリティの状況、国、地域及び世界の経済状況、法律上及び規

制上の要件並びに FTX トレーディングが随時検討するその他の要因を含む多くの要因に基づいて

決定されます。

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P2P 貸借暗号資産取引ウェブサイトを利用して借り受けられた暗号資産全てについて、責任財産

は本借受人の口座において本借受人が保有する資産に限定されます。言い換えると、債務不履行

の場合、FTX トレーディング、本貸出人又はその関連会社、代理人若しくは代表者のいずれも本

借受人の口座外に本借受人が所有する資金、資産若しくは財産からの償還又はこれらによる補償

を求めることはできません。本借受人が P2P 貸借暗号資産取引で債務不履行となった場合、本貸

出人が遡及できるのは本借受人の口座において保有される資産の差押及び/又は決済のみです。

お客様は、(a) P2P 貸借暗号資産に付される利息(P2P 貸借暗号資産取引ウェブサイトで閲覧でき

ます。)、及び (b) FTX トレーディングが随時定めるプラットフォーム手数料(これも P2P 貸借

暗号資産取引ウェブサイトで閲覧可能です。)を支払うことに同意します。

お客様はいかなる時も暗号資産を借り受ける必要はありません。P2P 貸借暗号資産の借受けを可

能とすることで、お客様はご自身がリスクを負担して借受けを行うことに同意します。お客様は、

P2P 貸借暗号資産取引を通じて本貸出人から借り受けた暗号資産が当社の取引プラットフォーム

上で取引、担保及び引出を含むあらゆる目的で利用される可能性があることを了承し、同意しま

す。但し、お客様は、お客様口座に十分な資産がない場合は FTX トレーディングが P2P 貸借暗号

資産取引に基づき借り受けられた暗号資産の引出を制限するよう当社に指図する可能性があるこ

とに同意します。

FTX トレーディングでの P2P 貸借暗号資産の借受けは極めて高いリスクを伴います。お客様は借

受人として、お客様口座内の全ての暗号資産を失う可能性があります。マーケットにおける高い

ボラティリティ及び重大な非流動性リスクの存在は、お客様がお客様口座内の資産を期限内に決

済できないか又は決済が全くできなくなる可能性があることを意味します。お客様口座において

保有される資産の価額が最低必要残高を下回るか又は FTX トレーディングが単独の裁量でお客様

口座の P2P 貸借暗号資産について債務不履行となるおそれがあると判断する場合、FTX トレーデ

ィング又は関連する本貸出人は、お客様が借り受けた暗号資産の返済のためにお客様口座内のポ

ジション及び資産の全部又は一部を直接又は間接的に差し押え、決済する可能性があります。

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SCHEDULE 16

SERVICE SCHEDULE

TERMS APPLICABLE TO UK USERS ONLY

(Updated September 29, 2022)

Products and services related to a specified investment for the purposes of the UK Financial 

Services and Markets Act 2000 (Regulated Activities) Order 2001 may not be promoted or 

offered to residents of the United Kingdom, unless they fall within the certain exemptions from 

the UK financial promotions regime under article 12 (Overseas Recipients), article 19 

(Investment Professionals), article 48 (High Net Worth Individuals), article 49 (High Net Worth 

Companies, Unincorporated Associations), article 50 (Sophisticated Investors) and article 50A 

(Self-certified Sophisticated Investors) of the Financial Services and Markets Act 2000 

(Financial Promotion) Order 2005, or they have otherwise be lawfully communicated in 

accordance with the Financial Services and Markets Act 2000 and the Financial Services and 

Markets Act 2000 (Financial Promotion) Order 2005.

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