Risk policy

1. Purpose and Scope

Cambeon Global is the trading name of Cambeon Global S.A., a cryptocurrency brokerage incorporated in the Republic of Panama under registration No. 155791256, with its registered office at Calle 50, Plaza 2000, Floor 17, Panama City, Republic of Panama (“Cambeon”, “we”, “us”, or “our”).

This Risk Policy describes the principal risks associated with digital assets and with the products and services we offer. It is provided so that you can understand the nature of those risks before deciding whether to engage with us.

This Policy applies to prospective and existing clients and to the representatives, beneficial owners, and authorized users of institutional clients. It refers to our activities generally, which may include the pooling of client contributions and their allocation, in client-selected product series, to digital assets and DeFi protocols and on-chain liquidity strategies, and an over-the-counter desk for the exchange of Fiat ⇄ USDT.

This Policy cannot disclose every risk. It is not a substitute for the terms of any separate agreement between you and Cambeon, and where such an agreement applies, its risk provisions govern.

2. No Advice and Suitability

Nothing in this Policy or on our Website is investment, legal, tax, accounting, or other professional advice, and nothing is a recommendation to enter into any transaction or strategy or an offer or solicitation to buy or sell any asset or instrument.

You are solely responsible for deciding whether any product, transaction, or strategy is appropriate for you in light of your own objectives, financial circumstances, experience, and risk tolerance. You should obtain independent professional advice where you consider it necessary. You should not participate in any activity described here unless you understand its nature and the extent of your exposure to risk.

3. Capital at Risk and No Guaranteed Returns

Digital assets and related activities involve a high degree of risk. The value of digital assets can fall as well as rise, and you may lose some or all of the value of your assets. You should not commit funds that you cannot afford to lose.

Past performance is not a reliable indicator of future results. No return, yield, or outcome is guaranteed, and any illustration, projection, or hypothetical scenario is provided for information only and may not be achieved. Accordingly, we do not present any specific figure, target, or range of return, and we do not rely on a track record of past performance. Returns are variable and depend on market conditions and the performance of the underlying strategy; you may receive back less than you contributed, up to the loss of your entire contribution.

4. Market Risk and Volatility

Digital-asset markets are highly volatile. Prices can move sharply and unpredictably over very short periods in response to market sentiment, macroeconomic conditions, regulatory developments, technological change, and other factors, many of which are outside our control. Market conditions can change faster than positions can be adjusted, and the price at which you enter or exit may differ materially from the price you expected.

5. Liquidity and Redemption Risk

Liquidity is the ability to buy or sell an asset without a significant effect on its price. In stressed or illiquid conditions, it may be difficult or impossible to execute a transaction at a reasonable price, or at all, and you may be unable to exit a position when you wish to.

Our DeFi allocations are organized in product series, each with an applicable period (a lock-up) during which the allocation is committed and illiquid and you have no right to redeem it, in whole or in part, before the end of that period. The specific lock-up, notice, and redemption terms of each series are set out in your client agreement and the client portal. Early redemption is not a right: we may permit, defer, or decline it depending on the series and the liquidity of the underlying positions, and, where we permit it, you bear the cost of unwinding the position early and the return for the accrual period in progress does not vest. We may also suspend, delay, or restrict redemptions in stressed conditions or where required by law.

6. Counterparty, Credit, and Settlement Risk

Transactions may expose you to the risk that a counterparty, custodian, exchange, liquidity provider, or other third party fails to meet its obligations, becomes insolvent, or defaults. In that event, you may not recover assets or value owed to you, and you may rank alongside other unsecured creditors.

Settlement risk arises where one side of a transaction performs before the other. Because a digital-asset transaction may combine an on-chain leg and a fiat leg that settle through different systems and at different times, there is a risk that value is delivered on one side and not returned on the other. For the over-the-counter (“OTC”) service we act as intermediary and arrange execution and settlement with or through third parties, such as liquidity providers, exchanges, and payment providers, and do not act as the principal counterparty to your transaction. For DeFi allocations we rely on third-party custodians, exchanges, wallets, and protocols that we select. We select these third parties with reasonable care but do not guarantee their performance, and, except to the extent caused by our fault, you bear the risk of their failure, insolvency, default, error, or security breach.

7. Custody and Wallet Risk

The security of digital assets depends on the safekeeping of private keys and on the custody arrangements applied to them. Loss, theft, or compromise of a private key, or a failure by a custodian, can result in the permanent and irreversible loss of assets. Assets held in online (“hot”) environments face different risks from those held in offline (“cold”) storage.

In our case, the pooled contributions clients deliver, in particular the USDT delivered for our DeFi service, are received and held by Cambeon, through wallets we control and through third-party custodians, exchanges, wallets, or protocols that we select. Your contributions are pooled and commingled with those of other clients rather than held in individually segregated accounts or in a wallet in your name. We keep an internal ledger record of your entitlement, but this is record-keeping only: it does not place your assets in trust, make them bankruptcy-remote, or ring-fence them from our creditors. You do not have a proprietary claim to identifiable assets, and for any shortfall you may rank as an unsecured creditor of Cambeon. If Cambeon or a third party we rely on becomes insolvent, these assets may form part of the insolvent estate, and you could lose some or all of your contribution.

8. Digital Asset and Blockchain Risk

Digital assets depend on blockchain networks and other technologies that we do not control. On-chain transactions are generally irreversible once confirmed; a transaction sent to a wrong or incompatible address may be lost permanently. Networks can experience congestion, delays, rising transaction fees, reorganizations, or periods during which transactions cannot be confirmed. Protocol changes, forks, and airdrops can affect the existence, value, availability, or supported status of an asset. The regulatory and technical treatment of a given asset can change.

9. Smart Contract and Protocol Risk

Activities that rely on smart contracts are exposed to the risk of defects, bugs, or vulnerabilities in the underlying code, and to exploits, hacks, or unexpected behavior. Smart contracts generally execute automatically and may not be capable of being reversed, paused, or corrected once deployed. An audit of a smart contract does not guarantee that it is free of defects or safe to use.

10. Stablecoin Risk

Stablecoins, including those used in Fiat ⇄ USDT activity, are designed to maintain a stable value relative to a reference asset, but they may fail to do so. A stablecoin can trade below or above its reference value (“de-pegging”), temporarily or permanently, and its stability depends on the issuer, the adequacy and composition of its reserves, its redeemability, and its legal and regulatory treatment. We do not issue or control third-party stablecoins and cannot guarantee that any stablecoin will maintain its value or remain redeemable. The stablecoins we use are USDT (issued by Tether) and USDC (issued by Circle). We do not perform independent due diligence on their issuers or reserves and rely on their general market acceptance and liquidity, so you are exposed to the risk that either issuer fails to maintain the peg or encounters reserve, liquidity, or regulatory problems, freezes or blacklists addresses, or ceases redemptions.

11. DeFi and On-Chain Liquidity Risk

Decentralized finance (“DeFi”) and on-chain liquidity activities carry risks in addition to those described above.

Our DeFi service consists principally of providing liquidity to decentralized exchanges and liquidity pools, including through concentrated-liquidity positions in which liquidity is committed within a defined price range and may earn a share of the trading fees generated by the pool while the price remains within that range. Positions are actively managed: as prices move, a position may be closed, repositioned into a new range, or supplemented with additional capital, and the ranges, timing, and parameters are adjusted in response to market conditions. This activity is intended to generate trading fees, but it does not guarantee any result and can produce losses.

These activities are exposed to the risk of faulty or exploited protocol code, the risk that a price oracle provides inaccurate or manipulated data, the risk that a liquidity pool becomes depleted or imbalanced, and the risk of “impermanent loss”, where providing liquidity produces a worse outcome than simply holding the underlying assets. When the price moves outside a position’s range, the position stops earning fees and its composition shifts toward the weaker-performing asset, and repositioning or committing additional capital in a falling market can increase losses rather than recover them. Your net result also depends on network and transaction costs, the costs of repositioning, exchange-rate movements, and the fees retained on the service, all of which reduce returns and can increase losses.

Many DeFi protocols are experimental, are not operated by an identifiable responsible party, and offer no recourse if value is lost. The specific protocols, networks, pools, trading pairs, price ranges, and operating parameters we use change over time in response to market conditions and are not fixed by this Policy; the arrangements that apply to your allocation at any time are those set out in your client agreement and the client portal. Any yield, range, or performance figure we may reference from time to time is a variable reference that depends on market conditions, traded volume, and available liquidity, and is not a fixed rate or a guaranteed return.

12. OTC and Off-Exchange Transaction Risk

OTC transactions are executed bilaterally, off public exchange order books. They do not benefit from the protections, transparency, or central-counterparty arrangements that may apply on a regulated exchange, and you are exposed directly to the counterparty to the transaction.

Because prices for OTC transactions are agreed bilaterally rather than set by a public order book, the price you receive may differ from prices quoted elsewhere and may not represent the best available price. Quoted prices may move between the time a quote is given and the time a transaction is executed, and larger transactions may move the market against you or be subject to a wider spread or to slippage. We are remunerated on the OTC service through the spread included in the quote we present to you for each transaction, together with any fee set out in the client portal. The quote is presented at the time of the transaction and is valid for acceptance only for a short period; by accepting it, you accept the price, including the spread.

On the OTC service we act as intermediary: we arrange execution and settlement with or through third parties, and we are not the principal counterparty to your transaction. Those third parties, which include liquidity providers, exchanges, and the payment gateways and processors we use to receive and send fiat across the different jurisdictions we serve, are independent companies that are not part of Cambeon and that carry their own risks, including failure, error, insolvency, fraud, security breach, outages, holds, delays, reversals or chargebacks, regulatory action, and the withdrawal or suspension of their services or of your access to them. Except to the extent caused by our fault, you bear the risk arising from any such provider, and a failure or action by a payment gateway or other provider can delay, prevent, or reverse the settlement of your transaction.

13. Structured and Managed Exposure Risk

Our DeFi service is organized in product series that you select; you choose which series to allocate to, and we then allocate the pooled contributions to decentralized-finance protocols in accordance with that series, deciding the specific protocols, timing, and any rebalancing. We do not manage your assets on a discretionary or bespoke basis and do not act as your fiduciary or adviser. Your exposure depends on strategies, positions, and instruments whose value can decline. This activity does not eliminate market, liquidity, counterparty, smart-contract, or operational risk, and our process, limits, and diligence reduce but do not remove the possibility of loss, up to and including the total loss of your contribution. The specific series, their terms, and the protocols used are set out in your client agreement and the client portal.

14. Operational and Technology Risk

Our activities depend on systems, software, networks, and processes that may fail, be interrupted, or contain errors. Hardware or software faults, connectivity problems, maintenance, capacity limits, and human error can delay, prevent, or affect the execution of transactions or access to services. Access provided through the internet or third-party platforms is subject to risks of interruption, delay, and failure that are outside our control.

15. Cybersecurity and Theft Risk

Digital assets and the systems that support them are targets for cyberattacks, including hacking, phishing, malware, social engineering, and the theft or compromise of credentials or private keys. A successful attack can result in the loss of assets or data. You are responsible for keeping any credentials confidential and for taking reasonable steps to protect the devices and accounts you use. We apply technical and organizational safeguards to the Website and our systems, including encrypted connections, security headers, and restricted access, but these cannot eliminate the risk of cyberattack, and we do not guarantee that our systems or those of our providers will always remain secure. We do not claim any specific security certification.

16. Third-Party and Service-Provider Risk

We rely on third parties, which may include custodians, exchanges, liquidity providers, banks, payment processors, technology providers, and blockchain networks. A failure, error, insolvency, security incident, or change of terms affecting any of them can affect our services and your assets, and we may not control or be able to prevent such events. The main categories we depend on are custodians, exchanges, liquidity providers, banks and payment providers, technology and infrastructure providers (including our hosting provider), identity-verification and screening providers, and public blockchain networks and DeFi protocols. Some functions may be concentrated in a single provider, and the specific providers we use may change.

17. Fiat, Foreign Exchange, and Payment-Rail Risk

Transactions that involve fiat currency depend on banks, payment systems, and the payment gateways and processors we use to serve clients across different jurisdictions, all of which are outside our control and that may impose delays, holds, limits, rejections, or freezes, and that may withdraw access to their services. Where a transaction involves converting between currencies, movements in exchange rates can affect the value you receive, and conversion may occur at a rate or time that differs from the one you expected. Fiat payments are made and received only through supported payment methods and only to and from accounts in your own name that we have verified; a payment may be delayed, held, rejected, reversed, or charged back by a bank or payment provider, and you bear the resulting risk except to the extent caused by our fault. The supported currencies, payment methods, and any conversion terms are set out in your client agreement and the client portal.

18. Cross-Border and Settlement-Timing Risk

Our activities and those of our counterparties and providers may span multiple countries, time zones, and market and banking hours. Differences in operating hours, cut-off times, holidays, and settlement cycles can delay the confirmation of transactions or the movement of value, and cross-border activity may be subject to additional legal, regulatory, and operational requirements. Settlement of an OTC transaction is subject to payment-system and network confirmation and to third-party timing, and on-chain transfers are irreversible once made. For DeFi allocations, returns accrue over monthly cycles and amounts are settled for withdrawal over the operational periods set out in your client agreement and the client portal. A business day is a day on which banks are open in Panama.

19. Legal, Regulatory, and Tax Risk

The legal and regulatory treatment of digital assets and related activities is evolving and differs between jurisdictions. Changes in law, regulation, policy, or their interpretation, including new restrictions, licensing requirements, or prohibitions, can affect the availability, value, or legality of our products and of particular assets, and can require us to change, suspend, or discontinue a service, in some cases without notice.

You are responsible for your own tax position. The tax treatment of digital assets and of any gains, income, or transactions can be complex and can change, and it depends on your individual circumstances and jurisdiction. You should obtain independent tax advice. We do not provide tax advice and do not generally provide tax reporting on your behalf; you are responsible for determining, paying, and reporting any taxes arising from your use of our services in your jurisdiction, and we may withhold or deduct amounts where required by applicable law.

20. Anti-Money-Laundering, Sanctions, and Compliance Risk

We are subject to legal and regulatory obligations relating to anti-money-laundering, counter-terrorist-financing, and sanctions, which require us to verify identity and source of funds, screen against sanctions and watchlists, monitor transactions, and report suspicious activity to competent authorities. To meet those obligations we may be required to request information, delay or decline a transaction, freeze or restrict assets or access, or terminate a relationship, and in some cases we may be prohibited from telling you why. As a company incorporated in Panama, we apply customer due diligence and ongoing monitoring and comply with the anti-money-laundering, counter-terrorist-financing, and sanctions obligations that apply to us, including reporting to the competent authorities where required.

21. Restricted Jurisdictions and Eligibility

Our products and services are not available to persons in every jurisdiction, and eligibility may be subject to conditions. If you are located in, or are a resident or national of, a restricted jurisdiction, you may not be permitted to use our services. Restricted jurisdictions currently include the United States, Canada, Cuba, Iran, North Korea, Myanmar, Yemen, Syria, Sudan, Russia, and Belarus, together with the Crimea, Donetsk, Luhansk, Zaporizhzhia, and Kherson regions, and any other jurisdiction subject to comprehensive international sanctions or in which providing the relevant service would not be permitted. This list may be updated at any time, and access from certain jurisdictions may also be technically restricted.

22. Conflicts of Interest

We, our affiliates, and the parties we work with may have interests that differ from, or conflict with, yours, including where we act in more than one capacity in relation to a transaction. In particular, we are remunerated through the spread on the OTC service and through the performance-based fee we retain on the DeFi service, we may pay a share of our revenue to introducing brokers, and we may deal in the same protocols, counterparties, or assets for our own account or for other clients. On the OTC service we act as intermediary and not as the principal counterparty to your transaction. We maintain arrangements to identify, manage, and where necessary disclose conflicts of interest; we may act despite a conflict where we can manage it with reasonable confidence that your interests are protected, and otherwise we disclose it or decline to act.

23. Force Majeure and Abnormal Market Conditions

Events outside our reasonable control, including market disruption, extreme volatility, failures of exchanges, networks, banks, or infrastructure, cyberattacks, changes in law, and other force-majeure events, can prevent, delay, or affect the execution of transactions and access to services. In abnormal market conditions, prices, liquidity, and the ability to execute can deteriorate rapidly, and transactions or withdrawals may be suspended or restricted.

24. Fees, Charges, and Taxes

The costs applicable to our services, including fees, charges, spreads, and network or transaction costs, affect your net result and can reduce returns or increase losses. You are responsible for any taxes and duties arising from your activity. We are remunerated on the OTC service through the spread included in each quote, and on the DeFi service through a variable, performance-based fee that is reflected in your net return and is not separately itemized; you also bear network and transaction costs and any third-party custodian, exchange, and protocol costs. The specific fees, spreads, and the basis of our remuneration are set out in your client agreement and the client portal, and we may deduct amounts owed to us from your account, assets, transactions, or returns.

25. Changes to This Policy

We may update this Risk Policy from time to time. Any updated version becomes effective when published on the Website. Your continued engagement with us after an update means you acknowledge the revised Policy.

26. Client Acknowledgement

By engaging with us, you acknowledge that you have read and understood this Risk Policy; that you understand digital assets and the products and services described here carry a high degree of risk, including the risk of losing some or all of the value of your assets; that no return or outcome is guaranteed; and that you are responsible for your own decisions and for obtaining any professional advice you consider necessary. You confirm that you are willing and able to bear the risks and any resulting losses. When you register as a client, you are required to confirm that you have read and agree to this Policy and our other policies; you cannot complete registration without doing so, and by completing registration you represent that you have read, understood, and accepted them.

27. Contact

For questions about this Risk Policy, you may contact us at legal@cambeon.com or at Calle 50, Plaza 2000, Floor 17, Panama City, Republic of Panama.