PaxFinance

Risk Warning

Pax Finance Limited Liability Partnership

BIN 260540020321

License of the National Bank of the Republic of Kazakhstan for dealer activity in the digital asset market - exchange operations with unbacked digital assets

No. 0126001O dated 30 June 2026

RISK WARNING

and terms of risk acceptance for operations with unbacked digital assets

Public version for clients

Version 1.0

APPROVED

by order of the Director of Pax Finance LLP

Beispekov Aslan Galimovich

No. 6 dated 10 July 2026

1. General provisions

All operations involving Pax Finance LLP, BIN 260540020321 (hereinafter the "Company"), and use of the services provided by the Company (hereinafter the "Service") are carried out by the User solely at their own risk. Digital assets and operations with them may result in significant financial losses.

The Company carries out the activity of an operator for the exchange of unbacked digital assets on the basis of the License for dealer activity in the digital asset market - exchange operations with unbacked digital assets No. 0126001O dated 30 June 2026, issued by the National Bank of the Republic of Kazakhstan, in accordance with the Law of the Republic of Kazakhstan No. 193-VII dated 6 February 2023 "On Digital Assets in the Republic of Kazakhstan", the Law of the Republic of Kazakhstan No. 191-IV dated 28 August 2009 "On Combating the Legalization (Laundering) of Proceeds of Crime, the Financing of Terrorism and the Financing of the Proliferation of Weapons of Mass Destruction" (hereinafter the "AML/CFT/CPF Law") and Resolution of the Board of the National Bank of the Republic of Kazakhstan No. 45 dated 29 April 2026 "On approval of the rules for carrying out the activities of operators for the exchange of unbacked digital assets" (hereinafter "Rules No. 45").

The Company does not guarantee the preservation of the value of digital assets and is not liable for losses incurred by the User as a result of fluctuations in the market value of digital assets or their own decisions to enter into transactions.

The User's use of the Service constitutes full and informed consent to this document and assumption of the risks set out below. A User who does not agree with any of the risks is not entitled to use the Service.

Reviewing this Risk Warning does not replace the User's completion of the questionnaire (test) to determine qualification, provided for by paragraphs 53-56 of Rules No. 45. Until sufficient qualification is confirmed based on the results of such a test, the User's operations are limited by the thresholds established by the Company's AML/KYC Policy.

This Risk Warning is an integral part of the Company's User Agreement and applies jointly with it and with the Company's Personal Data Processing and Protection Policy.

2. Principal risks

The User acknowledges, understands and accepts the following risks:

  • Risk of losses. Operations with digital assets involve a high level of risk; losses may arise within a short period of time and may amount to the total loss of the funds invested.
  • Market volatility. The value and liquidity of digital assets are subject to sharp and unpredictable changes.
  • Legal status of digital assets. Unbacked digital assets are not legal tender, are not backed by state guarantees, and are not covered by deposit insurance schemes or investor protection systems.
  • Regulatory risks. Changes in legislation at the international, regional and national levels may adversely affect the circulation, availability and value of digital assets, and may lead to account blocking, suspension of operations or loss of funds.
  • Irreversibility of transactions. Operations with digital assets recorded in a distributed ledger (blockchain) are irreversible. Losses caused by transactions made in error or by incorrectly specified details are not subject to reimbursement.
  • Risk of protocol changes. A hard fork, blockchain reorganization, change of the consensus protocol or other technical changes to the network may affect the availability, value or technical characteristics of a digital asset, including the loss of the ability to exchange it.
  • Recording of transactions. The date of execution of an operation with a digital asset is deemed to be the date of its recording in the distributed ledger (blockchain), which may differ from the date the operation was initiated by the User.
  • Liquidity loss risk. The value of digital assets depends on the willingness of market participants to exchange them for money. Cessation or restriction of demand may lead to the complete loss of the asset's value and the impossibility of selling it.
  • Limited acceptance. There is no guarantee that persons who currently accept digital assets in settlements will continue to do so in the future.
  • Operational and technological risks. The use of digital assets involves risks of fraud, cyberattacks, technical failures and errors of blockchain networks. Sending digital assets to an incorrect address or on an incorrect network results in their irrecoverable loss; the User is responsible for the correctness of the details (address, memo/tag, network).
  • Risk of insufficient coverage. During the period between the Company's receipt of the User's money or digital assets and the execution of the operation (including within the periods established by the Company's Payment Procedure), the money and digital assets are temporarily administered by the Company. The Company's assets and funds intended to cover its obligations to Users may prove insufficient to fully cover Users' losses, including in the event of the Company's insolvency.
  • Risk of loss of access. Loss or compromise of account access data (login, password, two-factor authentication codes, recovery keys) may lead to the irrecoverable loss of control over digital assets.
  • Third-party risk. The Company uses the services of third-party providers (banks, payment systems, identification providers, blockchain analytics) that are outside its control. Failures in their operation or cessation of their activities may affect the availability of the Service.
  • Risk of sanctions impact. The inclusion of the User, their counterparties or the wallets they use in sanctions lists (UN SC, OFAC, EU, authorized bodies of the Republic of Kazakhstan) may result in the suspension and freezing of operations and the transfer of information to authorized bodies.
  • Risk of suspension of operations for AML/CFT/CPF purposes. The Company reports a suspicious transaction to the authorized financial monitoring body no later than the business day following the day the relevant decision is made. The authorized body, within 24 (twenty-four) hours of receiving the report, is entitled to decide to suspend the operation for up to 3 (three) business days; where a decision of law enforcement bodies exists, the suspension of debit operations may be extended to 15 (fifteen) calendar days in the manner established by the AML/CFT/CPF Law.
  • Risk of interaction with mixers and anonymizers. Digital assets associated with anonymization services (mixers, tumblers) or other tools for concealing origin are not accepted by the Company; they may be returned, blocked or transferred to authorized bodies.
  • Risk of license revocation or suspension. The Company's License may be suspended, revoked or terminated by the National Bank of the Republic of Kazakhstan in the cases provided for by the Law of the Republic of Kazakhstan "On Digital Assets in the Republic of Kazakhstan", Rules No. 45 and other legislation of the Republic of Kazakhstan. In this case, the Company ceases to provide the Service and notifies Users within the period established by the legislation of the Republic of Kazakhstan.
  • Tax risk. The User is independently responsible for the fulfilment of tax obligations arising in connection with operations with digital assets, in accordance with the tax legislation of the Republic of Kazakhstan and the legislation of the country of their tax residence. The Company is not a tax advisor and does not provide recommendations on taxation matters.

3. Acceptance of risks

By using the Service, the User confirms that they: fully understand and acknowledge the specified risks; independently make decisions to carry out operations with digital assets; possess knowledge and experience sufficient to assess the nature of these risks; assume responsibility for possible losses, including the risk of the complete and irrecoverable loss of the invested funds; will not bring claims against the Company for compensation of losses arising from the circumstances specified in this document, except in cases of wilful misconduct, gross negligence or fraud on the part of the Company.

Nothing in this document limits or may be construed as limiting the mandatory rights of the User as a consumer established by the legislation of the Republic of Kazakhstan, including the Law of the Republic of Kazakhstan "On Protection of Consumer Rights". If a particular provision of this document establishes less favourable terms for the User than the mandatory provisions of the legislation of the Republic of Kazakhstan, the provisions of the legislation of the Republic of Kazakhstan shall apply.

The User releases the National Bank of the Republic of Kazakhstan, its officials and employees from any claims related to the Company's activities carried out on the basis of the License issued to it. The User retains the right to bring reasoned claims directly against the Company in the manner established by the User Agreement and the legislation of the Republic of Kazakhstan.

4. Recommendations to the User

  • invest in operations with digital assets only those funds whose loss the User can bear without harm to their financial position;
  • verify the terms and details of each operation (wallet address, memo/tag, blockchain network) before confirming;
  • do not disclose account data (login, password, two-factor authentication codes, recovery keys) to third parties;
  • use secure devices and communication networks;
  • contact the Company only through the official channels indicated on the Company's website and verify the authenticity of web resources;
  • where necessary, seek advice from independent financial, tax and legal advisors.

5. Final provisions

This Risk Warning enters into force from the date of its approval by order of the Company's director.

The current version is posted on the Company's official website https://paxfinance.kz.

The Company is entitled to make changes to this Warning within the framework of the applicable legislation of the Republic of Kazakhstan and the terms of the License; information on changes is published on the Company's website. Continued use of the Service after the new version enters into force constitutes the User's agreement to the changes.

6. Details and contact information of the Company

Full name

Pax Finance Limited Liability Partnership

Short name

Pax Finance LLP

BIN

260540020321

Director

Beispekov Aslan Galimovich

Basis of activity

License No. 0126001O dated 30 June 2026, issued by the National Bank of the Republic of Kazakhstan

Registered address

010000, Republic of Kazakhstan, Astana, Nura district, Kabanbay Batyr Avenue, 47/2, non-residential premises 2

Website

https://paxfinance.kz

Phone

+7 777 992 1113

Email

info@paxfinance.kz

Effective date: 20.07.2026 Version: 1.0