Effective Date: 2026-04-20 Last Updated: 2026-08-05
1. Purpose of this statement
This General Risk Disclosure Statement explains the principal risks associated with opening, maintaining, and using an account with Vitallium Corp. through its custodial crypto wallet application and related services (the “App” or the “Service”).
It is intended to help users understand the material risks associated with holding digital assets, including fiat-backed stablecoins, through a custodial omnibus wallet structure. It should be read together with the Terms of Service, the Privacy Policy, and any other product disclosures made available to users.
By creating an account or using the App, a user acknowledges that they have read and understood this Statement.
This Statement does not describe all risks of entering into Swap Transactions. Before entering into any Swap Transaction, the Customer must also read and accept the separate Swap Risk Disclosure, the Master Swap Agreement, the applicable Product Confirmation and the Collateral Terms.
Digital assets held in the Platform wallet before they are posted as collateral may be subject to the risks described in this Statement. Once Digital Assets are posted as collateral for a Swap Transaction, they are no longer held as wallet custody assets for the Customer and are treated in accordance with the Master Swap Agreement and Collateral Terms, including the title transfer arrangements described there.
2. Nature of the service
The Service is a custodial crypto wallet service. This means that Vitallium Corp, directly or through one or more custodians, controls the wallet environment, the relevant private keys or equivalent access credentials, and the operational systems used to safeguard supported digital assets.
Users are not using a self-custody wallet and do not directly control the private keys associated with the custody environment. A user’s rights with respect to assets reflected in their account arise from their contractual relationship with the Company, the Company’s internal books and records, and applicable law, and not solely from possession or control of cryptographic credentials.
3. Important general warning
Digital assets are risky. They may be volatile, technologically complex, operationally fragile, and subject to limited legal or regulatory protection. These risks may be higher where the provider is not regulated within a specific supervisory framework.
Users should not use the Service unless they are capable of understanding, bearing, and financially absorbing the risk of losing some or all of the digital assets held through their account.
4. No bank status, no licensed financial supervision
On the basis currently provided, provision of the Service by us including custodial wallet activities do not require a specific license, as opposed to other countries where they do. Nevertheless, our operations involve some degree of inspection and reporting by certain authorities, which we meet. Unless the Company expressly states otherwise in writing, the Service is not being offered by a bank, a deposit-taking institution, a securities intermediary, or another prudentially supervised financial institution.
5. Digital assets and stablecoins are not legal tender in Panama
Digital assets, including fiat-backed stablecoins, are not legal tender in Panama. A stablecoin’s reference to the U.S. dollar or another fiat currency does not make that token legal tender, sovereign currency, bank money, or a government-backed payment instrument.
Accordingly, no merchant, creditor, counterparty, or public authority is required to accept any crypto-asset or stablecoin merely because a user holds it through the Service.
6. Not a deposit, no deposit insurance, no public guarantee
Digital assets and stablecoins held through the Service are not deposits. They are not savings accounts, checking accounts, insured cash balances, or protected customer funds in the same sense as funds held at a regulated bank.
Unless the Company expressly states otherwise in writing, assets held through the Service are not protected by deposit insurance, investor compensation schemes, or similar public guarantee arrangements. No governmental authority, central bank, or public fund guarantees the value, redemption, convertibility, or return of any crypto-asset or stablecoin held through the Service.
7. Custodial risk: users rely on the company and its providers
Because this is a custodial service, users rely on the Company, and potentially on one or more custodians or providers engaged by the Company, to maintain secure wallet infrastructure, control and protect the relevant private keys or equivalent credentials, maintain accurate internal books and records, reconcile omnibus balances correctly, process deposits and withdrawals correctly, and detect and respond to fraud, cyber incidents, and operational failures.
Although the Company selects carefully its custodians and providers and implements commercially reasonable measures to prevent and detect failures in those functions, if any of these functions fail, whether because of human error, governance weakness, fraud, cyberattack, internal misconduct, service interruption, recordkeeping failure, or provider failure, a user may lose access to assets temporarily or permanently.
If a user relies solely on a passkey and loses access to the relevant device, account access may be unavailable until the user completes an available backup recovery method and any required verification checks.
8. Omnibus custody and pooled-wallet risk
Customer assets may be held in pooled, omnibus, or shared wallet structures rather than in segregated on-chain addresses uniquely identifiable to each user. In that case, the blockchain may not identify a user individually, and a user’s entitlement will depend substantially on the Company’s internal records, reconciliation systems, and contractual arrangements.
If the Company’s books and records are inaccurate, delayed, corrupted, or incomplete, or if an operational failure affects the omnibus environment, a user’s ability to establish the amount or type of digital assets attributable to their account may be impaired.
In an insolvency, restructuring, seizure, dispute, or similar proceeding affecting the Company or a relevant service provider, the treatment of pooled customer assets may be uncertain and recovery may be delayed, reduced, or unavailable.
9. Third-party dependency risk
The Company may use one or more custodians, wallet-infrastructure providers, cloud providers, node providers, monitoring vendors, compliance-screening providers, or other third-party service providers in connection with the Service.
Although the Company selects carefully its custodians and third-party-providers and implements commercially reasonable measures to prevent and detect failures in those functions, failures, outages, insolvencies, security incidents, misconduct, legal restrictions, compliance failures, or control weaknesses affecting any custodian or other third-party provider may impair the Company’s ability to safeguard assets, maintain access to wallet infrastructure, or process transactions.
10. Insolvency and credit risk
If the Company or a custodian becomes insolvent, enters liquidation, restructuring, administration, or a similar proceeding, a user’s access to digital assets may be delayed, frozen, or impaired.
The legal treatment of digital assets in insolvency may be uncertain, particularly where assets are pooled or where multiple custodians or intermediaries are involved. Users are therefore exposed not only to the operational soundness of the Company, but also, where applicable, to the solvency and performance of the custodians and service providers involved in the custody chain.
11. Fiat-backed stablecoin-specific risk
The Service may support fiat-backed stablecoins, including stablecoins that are represented as referencing a fiat currency such as the U.S. dollar. Even where a stablecoin is described as fiat-backed or fully backed, it may still involve significant risk.
A fiat-backed stablecoin can lose its peg, trade below its intended reference value, become illiquid, or become unavailable for transfer or redemption. It should not be described to users as risk-free merely because it is intended to maintain a stable value. The Company does not issue or control pegging, trading, liquidity or any other feature related to any supported digital asset or stablecoin.
12. Reserve and backing risk
The value and resilience of a fiat-backed stablecoin depend heavily on the quality, liquidity, custody, segregation, and governance of the assets said to back it.
The risks may include insufficient or poorly managed reserves, reserve assets that become illiquid or impaired, concentration with reserve custodians or banking partners, delays in access to reserve assets, weak operational safeguards over reserves, and inaccurate, delayed, or incomplete information about backing.
13. Redemption-rights risk
A user’s ability to redeem a fiat-backed stablecoin may depend on the legal and operational terms imposed by the issuer or intermediaries. A user may have no direct legal relationship with the stablecoin issuer, reserve custodian, or reserve banking partner.
Redemption may be available only to selected counterparties, may be subject to fees or thresholds, may be delayed or suspended, or may not be available to the user directly at all.
14. Stablecoins are not cash and not bank money
A fiat-backed stablecoin is not the same thing as fiat currency held in a bank account. It is also not central bank money, legal tender, or a bank deposit.
Even if a stablecoin is designed to track a fiat currency, its practical value, liquidity, transferability, and redeemability depend on the issuer, the reserve arrangement, the applicable legal framework, and market confidence; which all of those are not controlled or influenced by the Company.
15. Freezing, blocking, blacklisting, and issuer-control risk
Some stablecoin arrangements may permit the issuer, administrator, or another privileged actor to freeze, block, blacklist, pause, burn, or otherwise affect transfers or balances. If such controls are exercised, a user’s stablecoins may become inaccessible, non-transferable, or impaired, and the Company may be unable to reverse or overcome that outcome.
This risk may arise from sanctions controls, anti-fraud interventions, legal orders, issuer discretion, governance actions, or technical incident response.
16. Market, liquidity, and de-pegging risk
Even where the Service does not offer trading or conversion features, the value and practical usability of supported digital assets can still deteriorate sharply. Stablecoins can de-pegging, lose liquidity, face market stress, or suffer confidence shocks.
Digital assets more generally may become difficult to transfer, support, or value accurately in stressed conditions.
17. Technology, network, and protocol risk
Digital assets depend on distributed ledger networks, wallet software, validators or miners, smart contracts, and third-party technical infrastructure. These systems may fail, fork, become congested, be exploited, or behave unexpectedly.
Risks include blockchain forks, consensus failure, smart-contract vulnerabilities, node outages, trapped assets, incompatible network changes, and failures in third-party infrastructure.
18. Cybersecurity, phishing, fraud, and account compromise
The crypto sector is exposed to elevated levels of phishing, impersonation, malware, social engineering, insider abuse, and account takeover.
If a user’s device, credentials, email account, phone number, or authentication methods are compromised, an attacker may gain access to the user’s account, issue instructions, or interfere with access. Users are responsible for protecting their own devices, passwords, authentication factors, and communications channels.
19. Transfers, delays, and irreversibility risk
Transfers of digital assets may be delayed, rejected, suspended, or become effectively irreversible once processed on the relevant network. Mistakes involving destination addresses, unsupported tokens, incompatible chains, wrong network selection, or technical misconfiguration may result in loss.
Even in a custodial model, the Company cannot guarantee that all transfer requests will be processed on the underlying network within any particular timeframe, or that every supported network will operate normally at all times.
20. Compliance controls, freezes, and service restrictions
The Company may delay, refuse, suspend, condition, or block deposits, withdrawals, account access, or specific transactions where it considers this necessary for security, sanctions compliance, AML/CFT compliance, fraud prevention, suspicious-activity review, legal process, court order compliance, regulatory requests, or operational integrity.
Accordingly, access to assets may be restricted for periods of time that are uncertain and may extend beyond a user’s expectations.
21. Information, transparency, and disclosure risk
Information relating to supported digital assets or stablecoins may be incomplete, delayed, inaccurate, inconsistent, unaudited, or misleading. This includes statements about reserves, attestations, governance, cybersecurity, liquidity, regulatory status, or redeemability.
A user should not assume that a stablecoin is safe, fully backed, liquid, or directly redeemable merely because it is marketed that way.
22. Legal, regulatory, and tax-change risk
The legal and regulatory treatment of digital assets and stablecoins is evolving rapidly in Panama and elsewhere. Changes in law, regulation, supervisory practice, sanctions rules, accounting treatment, or tax rules may require the Company to change the Service, restrict support for particular assets, or block access for particular users or jurisdictions.
Users are responsible for determining the tax, accounting, legal, and reporting consequences of holding or transferring digital assets through the Service.
23. No investment advice, no suitability assessment
The Service is a custodial crypto wallet service. It is not investment advice, legal advice, tax advice, a recommendation, a suitability assessment, or an endorsement of any crypto-asset or fiat-backed stablecoin.
The Company does not represent that any supported asset is appropriate for a user’s objectives, risk tolerance, or circumstances.
24. No guarantee of recoverability
The Company does not guarantee that lost, stolen, frozen, blacklisted, de-pegging, unsupported, misdirected, or inaccessible digital assets will be recoverable. Recovery may depend on third parties, issuers, custodians, blockchain governance processes, courts, or technical circumstances outside the Company’s control.
In many cases, recovery may be delayed, partial, or impossible. Unless stated otherwise expressly, the Company does not commit on behalf of the user, to take part in any recovery effort or guarantee any result.
25. User acknowledgment
By using the Service, each user acknowledges and agrees that:
- for Swap Transactions, the Customer must separately acknowledge the Swap Risk Disclosure;
- the Service is a custodial omnibus wallet service, and the user does not control the private keys used in the custody environment;
- the Company may use custodians and the user is exposed to risks arising throughout that custody chain;
- the user’s entitlement may depend materially on the Company’s and its providers’ internal books and records, rather than on a segregated on-chain wallet in the user’s name;
- digital assets and fiat-backed stablecoins are not legal tender in Panama;
- assets held through the Service are not bank deposits and are not protected by deposit insurance or public guarantee schemes;
- fiat-backed stablecoins may de-pegging, become illiquid, be frozen, or fail to provide the redemption rights the user expects;
- the Company is a Panamanian provider that is not licensed for this activity; and
- the user may lose some or all of their digital assets or access to them.
26. Contact
If you have questions about this General Risk Disclosure or the Service, please contact:
Vitallium Corp
50th Street, PH Plaza 2000, 17th Floor Panama City, Panama Province, Panama