ANCHORAGE DIGITAL BANK, N.A. COVERED STABLECOIN TERMS

Effective date: October 13, 2025

These Terms govern the characteristics, limitations, rights, and risks of payment stablecoins issued by Anchorage Digital Bank, N.A. (“ADB”). ADB may issue one or more series of payment stablecoins (each, a “Series”). These Terms apply to all Series issued by ADB (collectively, “Covered Stablecoins”). By acquiring or holding Covered Stablecoins, a holder acknowledges and accepts the characteristics, limitations, and risks set forth in these Terms. These Terms do not create any rights or obligations except as expressly provided herein.

ADB may amend these Terms at any time by posting updated Terms on the ADB site. Amendments become effective upon posting. Holders that continue to hold or use Covered Stablecoins after such posting are deemed to have accepted the amended Terms.

1. SCOPE AND APPLICABILITY

Clients. For customers of ADB (each, a “Client”), all issuance and redemption transactions, together with related support, constitute the “Covered Stablecoin Service.” The Covered Stablecoin Service is a “Service” under the Master Account Agreement governing the relationship between ADB and the Client. These Terms form part of, and are incorporated by reference into, the Master Account Agreement. In the event of a conflict between these Terms and the Master Account Agreement, the Master Account Agreement prevails.

Non-Clients. Persons who hold Covered Stablecoins but are not Clients (“Non-Clients”) are not customers of ADB. Non-Clients have no contractual relationship with ADB under these Terms and no enforceable rights against ADB in respect of Covered Stablecoins, except as may arise under applicable law. By acquiring or holding Covered Stablecoins, a Non-Client acknowledges the characteristics, limitations, and risks described in these Terms. These Terms do not create any contractual or other relationship between ADB and a Non-Client, and do not confer any rights or obligations, except as expressly provided herein.

2. COVERED STABLECOIN CHARACTERISTICS

Nature of Product. Covered Stablecoins are digital assets issued by ADB for use as a means of payment or settlement. Covered Stablecoins are not designed to appreciate in value, generate investment returns, or create profit. Each Covered Stablecoin is intended to maintain a stable, fixed value (the “Par Value”), subject to the risks, limitations, and conditions described in these Terms. Unless expressly stated otherwise, the Par Value of each Covered Stablecoin issued by ADB is one U.S. dollar (USD $1.00).

Series. ADB may issue one or more series of Covered Stablecoins (each, a “Series”). Different Series may have different names, designations, or identifiers, but all Series are issued solely by ADB and are subject to these Terms. The Series designation for a Covered Stablecoin may be identified by its ticker symbol, smart contract address, or other identifier as designated by ADB from time to time.

Legal Characteristics. Covered Stablecoins are not insured or guaranteed by the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Securities Investor Protection Corporation, or any other governmental or private insurance program. Covered Stablecoins are not legal tender and are not issued, guaranteed, or backed by any government.

Supported Blockchains. Covered Stablecoins are issued and maintained on blockchain networks selected by ADB (“Supported Blockchains”). ADB may issue Covered Stablecoins on multiple Supported Blockchains, and different Series may be issued on different Supported Blockchains. ADB may add, modify, or discontinue Supported Blockchains in its discretion.

3. RESERVE BACKING AND TRUST STRUCTURE

Covered Stablecoin Reserve. All Covered Stablecoins issued by ADB are backed by assets (the “Covered Stablecoin Reserve”) with an aggregate market value, as of the end of each business day, at least equal to the aggregate number of outstanding Covered Stablecoins. ADB publishes information regarding the composition of the Covered Stablecoin Reserve as required by applicable U.S. federal law.

Reserve Trust. The Covered Stablecoin Reserve is held in a South Dakota express trust (the “Covered Stablecoin Reserve Trust”). ADB, in its capacity as trustee of the Covered Stablecoin Reserve Trust, has fiduciary obligations to invest and manage the Covered Stablecoin Reserve prudently and in accordance with applicable South Dakota trust law, applicable federal banking law, and other applicable law. ADB's fiduciary duties include, but are not limited to, maintaining adequate reserves to satisfy redemption obligations. All income, gains, or other returns realized on the Covered Stablecoin Reserve beyond the amounts necessary to maintain reserves sufficient to back outstanding Covered Stablecoins on at least a one-to-one basis constitute fiduciary compensation to ADB for administering the Covered Stablecoin Reserve Trust.

4. ISSUANCE OF COVERED STABLECOINS

Eligibility. ADB issues Covered Stablecoins exclusively to Clients. ADB does not issue Covered Stablecoins to Non-Clients. ADB may refuse, suspend, or limit any issuance request in its discretion, including for reasons such as incomplete verification, suspected fraud or illicit activity, risk management concerns, operational limitations, regulatory restrictions, unavailability of a particular Series, or violation of the Master Account Agreement or these Terms.

Issuance Value. Covered Stablecoins are issued at the Par Value for the applicable Series, as designated by ADB, net of any applicable fees disclosed in the Covered Stablecoin Fee Schedule.

Timing. ADB uses commercially reasonable efforts to process issuance requests promptly. Issuance may be delayed or suspended due to verification procedures, compliance requirements, operational or technical issues, or other factors outside ADB’s control.

5. TRANSFER AND USE OF COVERED STABLECOINS

Transfer of Rights. A transfer of Covered Stablecoins transfers all rights associated with those Covered Stablecoins to the recipient. The transferring holder relinquishes all rights upon completion of the transfer. The conditional right to redeem with ADB passes to the recipient only if, and when, the recipient becomes a Client under the Master Account Agreement.

Finality and Risk of Loss. Blockchain transactions are final once confirmed according to the consensus rules of the relevant network. Covered Stablecoins sent to an incorrect, invalid, inaccessible, or compromised address may be permanently lost. ADB has no ability or obligation to reverse, cancel, retrieve, or recover such transactions.

On-Chain Transfers. Covered Stablecoins may be transferred to other blockchain addresses. On-chain transfers may be delayed due to network congestion, technical issues, or other factors outside ADB’s control. Holders are solely responsible for gas or network fees required for on-chain transfers of Covered Stablecoins. Transactions submitted with insufficient fees may fail or be canceled. ADB does not advance or cover fees on behalf of holders unless expressly agreed in writing with a Client.

Transfer and Use Restrictions. Covered Stablecoins may not be transferred in violation of applicable law, including transfers: to or from persons or entities in prohibited jurisdictions; to or from persons or entities subject to economic sanctions; or in connection with unlawful activity or violations of securities or other applicable laws. ADB may freeze, block, seize, or otherwise restrict Covered Stablecoins where required by court orders, subpoenas, regulatory directives, or law enforcement requests, or where ADB determines that a transfer violates, or is likely to violate, applicable law or regulation. Such actions may apply to Covered Stablecoins held by Clients and Non-Clients alike and may result in permanent loss of access.

Third-Party Platforms. Holders may use Covered Stablecoins on third-party platforms, including exchanges, wallets, custodians, and decentralized finance protocols, at their sole risk. ADB does not operate, control, or endorse third-party platforms, and does not guarantee their security, functionality, or the value of Covered Stablecoins traded or held on such platforms. Par Value applies only to redemption by Clients directly with ADB. On third-party platforms, the value of Covered Stablecoins often fluctuates above or below Par Value due to market conditions or other factors beyond ADB’s control. Third-party platforms are subject to risks including hacking, software vulnerabilities, fraud, insolvency, operational failures, and liquidity shortfalls. ADB is not responsible for losses arising from the use of Covered Stablecoins on third-party platforms.

6. REDEMPTION OF COVERED STABLECOINS

This Section sets forth ADB’s procedures for timely redemption of outstanding Covered Stablecoins (the “Redemption Policy”) as required by the GENIUS Act, 12 U.S.C. § 5903(a)(1)(B)(i).

Eligibility. ADB redeems Covered Stablecoins exclusively from Clients. ADB does not redeem Covered Stablecoins from Non-Clients. ADB may refuse, suspend, or limit any redemption request in its discretion, including for reasons such as incomplete verification, suspected fraud or illicit activity, risk management concerns, operational limitations, liquidity management, regulatory restrictions, unavailability of a particular Series, or violation of the Master Account Agreement or these Terms.

Redemption Value. Covered Stablecoins presented for redemption by Clients are redeemed at the Par Value for the applicable Series, net of any applicable fees disclosed in the Covered Stablecoin Fee Schedule.

Timing. ADB uses commercially reasonable efforts to process redemption requests promptly. Redemption may be delayed or suspended due to verification procedures, compliance requirements, operational or technical issues, liquidity management, or other factors outside ADB’s control.

7. SERVICE PROVIDERS TO ADB

Engagement of Service Providers. ADB engages third-party and affiliated entities (“Service Providers”) to perform support functions for Covered Stablecoins pursuant to written agreements with ADB that define the scope of the support services, allocate responsibilities, and define compensation for services. 

Nature of Relationship. Except as expressly identified in ADB’s public disclosures, Service Providers are not agents or representatives of ADB with respect to any holder of Covered Stablecoins. Service Providers operate under ADB’s oversight but remain independent from ADB. They perform services within defined contractual scopes and have no authority to act for, bind, or represent ADB in any capacity. Materials or communications issued by a Service Provider are not binding on ADB unless expressly approved in writing by ADB.

ADB as Sole Issuer and Sole Obligor. ADB remains the sole issuer of, and the sole obligor for, every Series of Covered Stablecoins within the meaning of the GENIUS Act, 12 U.S.C. § 5901 et seq., even when ADB engages one or more Service Providers to perform operational or administrative functions. Rights of redemption exist only as provided in the written agreement governing the applicable Covered Stablecoin Trust, the Master Account Agreement, and applicable law. These rights do not confer upon any holder of Covered Stablecoins any additional right, title, interest, lien, or claim against any account, asset, or agreement maintained by a Service Provider in the administration of the Covered Stablecoin Reserve or any Covered Stablecoin Trust. Any other rights against ADB arise only to the extent expressly provided in the Master Account Agreement and applicable law.

Brand Partners. Certain Service Providers license or otherwise permit ADB to use a brand name, trademark, or other intellectual property in connection with a Series (each such Service Provider, a “Brand Partner”). Brand Partners are Service Providers for all purposes of these Terms. The issuance of a Covered Stablecoin under the brand name, trademark, or other intellectual property of a Brand Partner does not create any rights or claims against ADB by any customer or other person who may have rights against that Brand Partner, nor does it create any rights or claims against the Brand Partner by any customer or other person who may have rights against ADB, except as expressly provided in a written agreement or required by applicable law.

8. SUPPORTED BLOCKCHAINS AND OPERATIONAL CONTROLS

No Control of Blockchains. ADB does not operate, own, or control any Supported Blockchain. ADB is not responsible for the operation of any Supported Blockchain and does not guarantee its functionality, security, settlement finality, or availability.

ADB’s Support Decisions. ADB determines, in its sole discretion, which blockchains qualify as Supported Blockchains. ADB may add or remove Supported Blockchains at any time; suspend operations on a Supported Blockchain during forks, protocol upgrades, security incidents, or other events; determine whether to support a forked version; or require holders to migrate Covered Stablecoins to a different Supported Blockchain. Holders who fail to complete a required migration in accordance with ADB’s instructions may permanently lose access to Covered Stablecoins on the affected blockchain. ADB is not responsible for damages, losses, or costs resulting from a holder’s failure to migrate. ADB is also not responsible for bugs, vulnerabilities, or failures in the operation of any Supported Blockchain, whether arising from a fork, upgrade, consensus change, or other modification.

Smart Contract Risks. Covered Stablecoins are issued through smart contracts deployed on Supported Blockchains. Smart contracts may contain vulnerabilities, may be subject to attack, or may fail to function as intended. ADB does not guarantee the security or functionality of any smart contract and is not responsible for losses arising from smart contract risks, except as expressly provided under the Master Account Agreement.

Unauthorized Versions. Third parties may create alternative, “wrapped,” or “bridged” versions of Covered Stablecoins. Such versions are not issued, authorized, or supported by ADB, cannot be redeemed with ADB, and are entirely at the risk of holders. ADB assumes no responsibility for any losses associated with such unauthorized versions.

Unsupported or Incorrect Blockchains. Covered Stablecoins transferred to an address on an unsupported or incorrect blockchain may be permanently lost. ADB is not responsible for such losses.

Private Key Security. Holders are solely responsible for safeguarding private keys associated with wallets holding Covered Stablecoins. Loss or compromise of private keys may result in permanent loss of access. ADB cannot recover lost private keys, except with respect to Covered Stablecoins held in ADB custody under the Master Account Agreement.

Operational Risks. ADB’s operations, and the operation of Supported Blockchains, may be subject to interruptions, delays, or failures caused by technical issues, cyberattacks, force majeure events, or other factors outside ADB’s control.