Terms of Use and Services Policy

1. Introduction

Welcome to JTSA Global LLC (“JTSA,” “we,” “us,” or “our”), a global family office specializing in institutional lending against digital assets. This Terms of Use and Services Policy (“Terms”) governs your access to and use of our lending services (“Services”). By engaging with our Services, you (“Client,” “you,” or “your”) agree to be bound by these Terms, as well as any applicable laws and regulations.

These Terms are effective as of April 16, 2025, and apply exclusively to institutional clients, defined as companies (e.g., corporations, partnerships, or other legal entities). JTSA Global LLC does not offer Services to retail clients or individuals. If you do not agree to these Terms, you may not use our Services.

‍2. Scope

JTSA Global LLC provides institutional lending services, including loans collateralized by digital assets (e.g., cryptocurrencies, tokens, or other blockchain-based assets). Our Services are designed for companies seeking financing against their digital asset holdings. The scope of our Services includes:

  • Loan Origination: Providing loans to eligible institutional clients, secured by digital assets as collateral.
  • Collateral Management: Evaluating and managing digital assets pledged as collateral, subject to our internal risk assessment and valuation processes.
  • Loan Servicing: Administering loan agreements, including interest payments, collateral adjustments, and repayment schedules.

Exclusions: Our Services do not include money transmission, digital asset exchange, custody services, securities trading, investment advice, or any retail-facing activities.

3. Eligibility

To use our Services, you must meet the following eligibility criteria:

  • Institutional Status: You must be a legally recognized company (e.g., corporation, limited liability company, partnership, or other legal entity) operating in a jurisdiction where our Services are permitted. Individuals, retail clients, or non-incorporated entities are not eligible.
  • Compliance with Laws: You must comply with all applicable laws, including anti-money laundering (AML), counter-terrorist financing (CFT), and sanctions regulations in your jurisdiction and those of JTSA Global LLC’s operations (e.g., U.S., Switzerland, UK, France).
  • Due Diligence: You must provide all requested information for our Know Your Customer (KYC) and AML/CFT due diligence processes, including but not limited to business registration documents, beneficial ownership details, and source of funds.
  • Digital Assets: The digital assets pledged as collateral must be legally owned by you, free of liens or encumbrances, and not classified as securities or financial instruments unless explicitly agreed upon and compliant with applicable regulations.

JTSA Global LLC reserves the right to reject any Client application or terminate Services if eligibility criteria are not met or if continued engagement poses legal, regulatory, or operational risks.

4. Client Responsibilities

As a Client, you agree to:

  • Provide Accurate Information: Submit complete, accurate, and up-to-date information during onboarding and throughout the term of our Services, including for KYC/AML/CFT compliance.
  • Comply with Laws: Ensure your use of our Services complies with all applicable laws, including those enforced by FinCEN, FINRA, FINMA, FCA, SEC, TRACFIN, and other relevant authorities.
  • Maintain Collateral: Ensure digital assets pledged as collateral remain valid, accessible, and sufficient to meet loan requirements. You are responsible for any decline in collateral value that may trigger margin calls or liquidation.
  • Notify Changes: Promptly inform JTSA Global LLC of any material changes to your business, legal status, or collateral, including regulatory investigations or insolvency proceedings.
  • Pay Fees and Interest: Fulfill all financial obligations under loan agreements, including interest payments, fees, and principal repayment, in accordance with agreed terms.

5. JTSA Global LLC’s Rights and Responsibilities

JTSA Global LLC will:

  • Provide Services: Deliver lending services in accordance with these Terms and applicable loan agreements, subject to regulatory compliance and risk management policies.
  • Conduct Due Diligence: Perform KYC/AML/CFT checks and ongoing monitoring to ensure compliance with regulations from FinCEN, FINRA, FINMA, FCA, SEC, TRACFIN, and other authorities.
  • Manage Collateral: Monitor and manage digital assets pledged as collateral, with the right to issue margin calls or liquidate collateral in accordance with loan agreements if collateral value falls below required thresholds.
  • Reserve Rights: Refuse, suspend, or terminate Services at our sole discretion, including for suspected non-compliance, regulatory changes, or operational risks.

JTSA Global LLC is not responsible for losses arising from market volatility, technical failures beyond our control, or Client non-compliance.

6. Regulatory Compliance

JTSA Global LLC operates in compliance with regulations from the following authorities, as outlined in our Regulatory Policy:

  • FinCEN (U.S.): We maintain AML/CFT programs and monitor transactions to comply with the Bank Secrecy Act, without engaging in money transmission requiring MSB registration.
  • FINRA (U.S.): Our lending activities do not involve broker-dealer functions, and we ensure digital assets are not securities to avoid FINRA registration.
  • FINMA (Switzerland): We do not accept public deposits or deal in securities, exempting us from banking or securities dealer licenses under Swiss law.
  • FCA (UK): Our Services exclude cryptoasset exchange or custody, and we use non-security tokens to avoid FCA registration under the Money Laundering Regulations.
  • SEC (U.S.): We confirm digital assets are not securities (per the Howey Test) to remain outside SEC jurisdiction for broker-dealer or investment adviser registration.
  • TRACFIN (France): We implement AML/CFT measures and report suspicious transactions, without engaging in digital asset services requiring AMF registration.

Clients must comply with these and other applicable regulations. JTSA Global LLC may report suspicious transactions to relevant authorities (e.g., SARs to FinCEN, reports to TRACFIN) as required.

7. Risk Disclosures

Engaging in our Services involves risks, including but not limited to:

  • Market Volatility: Digital assets are highly volatile, and declines in collateral value may lead to margin calls or liquidation.
  • Regulatory Changes: Evolving regulations in the U.S., Switzerland, UK, France, or other jurisdictions may impact the availability or terms of our Services.
  • Operational Risks: Technical issues, cyber threats, or blockchain failures may affect digital assets or loan servicing.
  • Counterparty Risk: Client insolvency or non-compliance may result in loan default or termination of Services.

Clients are responsible for assessing these risks and obtaining independent legal, financial, or tax advice before using our Services.

8. Fees and Costs

Clients are responsible for all fees, interest, and costs associated with our Services, as specified in individual loan agreements. These may include:

  • Loan origination fees
  • Interest payments
  • Collateral management fees
  • Liquidation costs (if applicable)

JTSA Global LLC will provide a fee schedule prior to entering loan agreements. All payments must be made in the agreed currency and timeframe.

9. Confidentiality

JTSA Global LLC will protect Client information in accordance with applicable privacy laws, including GDPR (EU/UK), CCPA (California), and other data protection regulations. We may disclose information:

  • To comply with legal or regulatory obligations (e.g., KYC/AML/CFT reporting to FinCEN, TRACFIN).
  • To service providers (e.g., technology or compliance vendors) under strict confidentiality agreements.
  • In response to lawful requests from courts or regulators.

Clients agree to keep loan terms and related communications confidential, except as required by law.

10. Limitation of Liability

To the fullest extent permitted by law, JTSA Global LLC, its affiliates, directors, employees, or agents shall not be liable for any direct, indirect, incidental, or consequential damages arising from:

  • Use of or inability to use our Services.
  • Losses due to market volatility, regulatory changes, or technical failures.
  • Client errors, omissions, or non-compliance.

Our total liability shall not exceed the fees paid by the Client for the Services giving rise to the claim.

11. Indemnification

Clients agree to indemnify and hold harmless JTSA Global LLC, its affiliates, directors, employees, and agents from any claims, losses, or damages arising from:

  • Client’s breach of these Terms or loan agreements.
  • Client’s violation of applicable laws or regulations.
  • Misrepresentation of Client information or collateral.

12. Termination

JTSA Global LLC may terminate or suspend Services at any time, with or without notice, for reasons including:

  • Client non-compliance with these Terms or applicable laws.
  • Regulatory changes affecting our ability to provide Services.
  • Suspected fraud, money laundering, or other illicit activities.

Clients may terminate Services by repaying all outstanding loans and fees in accordance with loan agreements. Upon termination, Clients must transfer any collateral back to their control, subject to our release procedures.

13. Governing Law and Dispute Resolution

These Terms are governed by the laws of the State of Delaware, United States, without regard to conflict of law principles. Any disputes arising from these Terms or our Services shall be resolved through:

  • Negotiation: Parties will attempt to resolve disputes amicably within 30 days.
  • Arbitration: If unresolved, disputes shall be settled by binding arbitration in Delaware under the rules of the American Arbitration Association (AAA). The arbitration shall be conducted in English, and the arbitrator’s decision shall be final.
  • Jurisdiction: For matters not subject to arbitration, the parties submit to the exclusive jurisdiction of the courts of Delaware.

Clients operating in other jurisdictions (e.g., Switzerland, UK, France) must ensure compliance with local laws, which may supplement these Terms.

14. Amendments

JTSA Global LLC may amend these Terms at any time by providing notice to Clients via email or our website. Continued use of our Services after such notice constitutes acceptance of the amended Terms. Significant changes (e.g., affecting fees or eligibility) will be communicated at least 30 days in advance, where feasible.

15. Contact Information

For questions, support, or to report issues related to our Services, contact: JTSA Global LLC

Email: info@jtsaglobal.com

Address: 1712 Pioneer Ave #500 Cheyenne, WY. 82001

Phone: +1-254-255-9080

16. Miscellaneous

  • Entire Agreement: These Terms, together with any loan agreements, constitute the entire agreement between JTSA Global LLC and the Client, superseding all prior agreements.
  • Severability: If any provision of these Terms is found invalid or unenforceable, the remaining provisions shall remain in full force.
  • No Waiver: Failure to enforce any provision of these Terms does not constitute a waiver of that provision.
  • Assignment: Clients may not assign their rights or obligations under these Terms without our prior written consent. JTSA Global LLC may assign its rights to affiliates or successors.

17. Acknowledgment

By using our Services, you acknowledge that you have read, understood, and agree to be bound by these Terms. You represent that you are an authorized representative of an eligible institutional Client and that all information provided is accurate and complete.