STATEMENT OF USAT POLICIES AND DISCLOSURES

Effective Date: December 1, 2025

This Statement of USAT Policies and Disclosures (“Statement”) provides information about USAT, a payment stablecoin issued by Anchorage Digital Bank, N.A. (“ADB”). This Statement does not constitute, and should not be construed as, a contract, agreement, offer,promise, or other commitment by ADB, or as a representation or warranty regarding the future availability, value, or performance of USAT. Nothing in this Statement creates or confers any rights, obligations, or remedies, express or implied.

USAT ISSUANCE AND REDEMPTION POLICY

Clients. ADB issues USAT only to, and redeems USAT only from, persons who are Clients of ADB. A Client is any person or organization that maintains a customer account relationship with Anchorage Digital Bank, N.A., in good standing and documented in a written account agreement. The terms of that relationship are governed by an account agreement between ADB and the Client. ADB issues USAT to, and redeems USAT from, Clients on a one-to-one basis to the U.S. dollar (i.e., one USAT to USD $1.00), net of any fees disclosed in the USAT Fee Schedule. To initiate an issuance or redemption, a Client must have sufficient U.S. dollars or USAT, as applicable, in its account with ADB. A transaction is complete when ADB has processed and settled the corresponding transfer of USAT or U.S. dollars. ADB uses commercially reasonable efforts to process and settle valid issuance and redemption transactions in a timely manner, but may delay, restrict, or refuse a request when necessary, including to comply with law, manage risk, or ensure operational integrity.

Non-Clients. ADB does not issue USAT to, and does not redeem USAT from, persons who are not Clients of ADB. Persons who are not Clients may acquire or dispose of USAT only through transactions that are not issuance or redemption transactions between ADB and a Client. ADB does not guarantee the availability, pricing, or liquidity of USAT in secondary markets. Acquiring, holding, or using USAT does not create a customer account relationship with ADB or confer any rights, obligations, status, or privileges as a Client.

USAT Reserve Management Policy

The U.S. dollars received by ADB in exchange for USAT through issuance transactions are held in the form of cash and investments in assets that are low-risk and highly liquid. Together, these assets comprise the USAT Reserve. ADB manages the USAT Reserve so that aggregate value of all assets in the USAT Reserve meets or exceeds the U.S. dollar value of all USAT outstanding and in circulation. ADB uses the assets in the USAT Reserve to fund redemption transactions.

The USAT Reserve is held in one or more accounts titled in the name of the USAT Reserve Trust, an express trust under the law of the State of South Dakota for which ADB is the appointed trustee. The assets in the USAT Reserve are segregated from ADB’s general assets and are managed solely for the purposes of the USAT Reserve Trust. ADB does not lend, pledge, or rehypothecate the assets in the USAT Reserve, except in limited circumstances permitted by applicable law, such as to facilitate lawful redemption transactions. These structural protections are intended to ensure that the assets in the USAT Reserve remain legally separate from ADB’s property and are not subject to claims of ADB’s creditors or any person other than lawful holders of USAT.

The USAT Reserve may be maintained in one or more accounts at third-party depository institutions or custodians engaged by ADB as trustee of the USAT Reserve Trust.

ADB is prohibited by law from paying any form of interest or yield (whether in cash,tokens, or other consideration) to holders of USAT solely in connection with the holding,use, or retention of USAT. Consistent with applicable law and prevailing market practice for stablecoin issuers, ADB retains any interest, income, or other earnings generated from the assets in the USAT Reserve as compensation for issuing and redeeming USAT and for managing and administering the USAT Reserve.

Disclosures

No U.S. Government Affiliation. USAT is not issued, sponsored, endorsed, or approved by the United States government or any of its agencies or instrumentalities. USAT is not guaranteed or backed by the full faith and credit of the United States government and does not constitute legal tender.¹² The United States government does not require any person to accept USAT as payment for debts, taxes, or other obligations.

No Government Insurance. USAT is not subject to protection or insurance by the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA),or the Securities Investor Protection Corporation (SIPC) or to analogous protections in jurisdictions outside the United States.

Not an Investment Product. USAT designed to be used as a means of payment or settlement. ADB does not pay holders of USAT any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of USAT. Possession or ownership of USAT: does not entitle the holder to receive interest, profits, dividends, or other returns from ADB, its affiliates, or service providers; does not represent any investment, equity, or ownership interest in ADB, its affiliates, or service providers; does not confer any governance, voting, or similar rights with respect to ADB, its affiliates, or service providers; and does not provide any financial benefit or exposure based on the financial performance of ADB, its affiliates, or service providers.

Changes in Law or Policy. Changes in law, regulation, policy, supervisory guidance,enforcement priorities, court decisions, or governmental directives, whether in the United States or in other jurisdictions, may adversely affect the issuance, redemption, transfer, or use of USAT. Such changes may require ADB to modify, delay, restrict, suspend, or cease some or all services related to USAT to remain in compliance with applicable law or supervisory expectations. These developments may also affect third parties that accept USAT as payment, provide custody or related services, or facilitate liquidity for USAT.

Supported Blockchains. USAT exists only on blockchain networks that ADB designates as supported for USAT (each, a “Supported Blockchain”). Supported Blockchains are not owned, controlled, or operated by ADB. ADB may, at its discretion, add, change, or withdraw Supported Blockchains at any time.

Immutability, Finality, and Security of USAT Transactions. Transactions recorded on Supported Blockchains are immutable. Once a USAT transaction is confirmed on a Supported Blockchain, it cannot be reversed, canceled, or otherwise altered by ADB or by any other party. This immutability means that transactions involving USAT are final when confirmed by the Supported Blockchain’s consensus mechanism, and USAT transferred in erroneous, unauthorized, or fraudulent transactions, or to an incorrect or unintended address, may be permanently lost and unrecoverable. Holders of USAT who use wallets not custodied by ADB are responsible for safeguarding the private keys, seed phrases, passwords, and other credentials that control access to those wallets and for verifying the accuracy of all transaction details, including recipient addresses and amounts, before initiating a transfer. Holders of USAT who use wallets custodied by ADB are responsible for safeguarding the passwords and other credentials that control access to those wallets and for verifying the accuracy of all transaction details, including recipient addresses and amounts, before initiating a transfer. The loss or compromise of wallet credentials, or any error in entering transaction information, may result in an irreversible loss of USAT. ADB is not responsible or liable for losses arising from accidental, erroneous, unauthorized, orfraudulent USAT transactions, or from the loss, theft, or compromise of wallet credentials for wallets not controlled by ADB.

Timing of Transactions. When USAT is used in secondary-market transactions, the time at which a transaction is confirmed and recorded on a Supported Blockchain may differ from the time it is initiated by the user. Each Supported Blockchain determines transaction ordering and confirmation through its own consensus mechanism, validator operations,and network conditions. Factors such as network congestion, transaction volume, and the amount of gas or network fees attached to a transaction may affect the speed or sequence of confirmation. ADB does not control the timing, ordering, or finality of transactions recorded on Supported Blockchains and does not guarantee that any transaction will be confirmed or finalized at a specific time or within a particular timeframe.

Transaction, “Gas,” and Similar Network Fees. Transfers of USAT on Supported Blockchains require the payment of transaction, “gas,” or similar network fees to validators, miners, or other participants responsible for confirming and recording transactions on the relevant blockchain. These fees are determined by the underlying network protocol and fluctuate based on network activity, congestion, and other technical factors. ADB does not set, receive, or control gas or network fees. Failure to provide sufficient gas or network fees may result in a transaction being delayed, unconfirmed, or rejected by the network. ADB does not guarantee the execution, timing, or cost of any transaction on a Supported Blockchain and is not responsible or liable for any losses or delays arising from insufficient or fluctuating gas or network fees.

Secondary-Market Pricing. Clients and non-Clients may buy, sell, and transfer USAT in transactions that are not issuance or redemption transactions between ADB and a Client.These transactions, which are commonly referred to as secondary-market transactions,may occur directly between parties, such as through DeFi, through intermediated platforms, or through other arrangements that are not owned, controlled, or operated by ADB. The price of USAT in these transactions is determined solely by supply and demand among market participants and may differ, including materially, from the one-to-one value at which USAT is issued or redeemed by ADB. ADB does not control, support, or guarantee pricing in secondary markets.

Disruption to Operations Supporting USAT. Operational, technical, or other events affecting ADB or its critical service providers may impair or delay functions that support USAT, including issuance and redemption, safeguarding and management of the USAT Reserve, and related records and systems. These events may result from internal failures or from external circumstances beyond ADB’s control, such as power outages, cyber incidents, communications failures, natural disasters, acts of war or terrorism, pandemics, civil unrest, or governmental or regulatory actions. During such events, transfers of USAT that occur solely on Supported Blockchains may continue if those networks remain operational. However, ADB may be unable to provide issuance, redemption, or other services related to USAT, or may do so only with delay or reduced capacity until normal operations are restored. ADB does not operate Supported Blockchains and does not guarantee their performance, availability, or continuity. In addition, USAT is 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.

Anti–Money Laundering, Counter–Terrorist Financing, Sanctions, and Financial Crime Laws. Persons who acquire, hold, or use USAT must not use it for any unlawful purpose or in violation of applicable anti–money laundering, counter–terrorist financing, sanctions, or other financial crime laws, including dealings with prohibited persons,jurisdictions, or activities. ADB may delay, restrict, block, or refuse issuance, redemption,or other services related to USAT and may freeze, block, seize, burn, or otherwise prevent the transfer or use of USAT associated with specified persons, accounts, or wallet addresses, including those of non-Clients where it identifies or reasonably suspects prohibited, unlawful, or high-risk activity. ADB may also be required or directed by courts,regulators, law-enforcement agencies, or other governmental authorities to freeze, block, seize, burn, or otherwise prevent the transfer or use of USAT associated with specified persons, accounts, or wallet addresses, including those of non-Clients. ADB may implement such actions without prior notice, including where required by law. As a result of such actions, certain USAT may become temporarily or permanently inaccessible or non-redeemable through ADB, and transactions involving ADB’s services may be delayed,declined, or canceled. To the fullest extent permitted by applicable law, ADB is not responsible or liable for losses, interruptions, or delays arising from actions taken in good-faith compliance with anti–money laundering, counter–terrorist financing, sanctions, or other financial crime laws, or with lawful governmental orders or directives.Blockchain Network and Protocol Risk. If a fork, change, or other condition affects a Supported Blockchain, ADB may take any actions it considers necessary or appropriate top reserve the integrity of USAT, maintain one-to-one reserve backing for outstanding USAT,or ensure compliance with applicable law. Such actions may include suspending, modifying, or ceasing issuance, redemption, or transfers of USAT on the affected blockchain, on either a temporary or permanent basis. ADB will determine, in its sole discretion, which fork, if any, of the affected blockchain will continue as a Supported Blockchain. Only tokens issued by ADB on a Supported Blockchain and expressly designated by ADB as USAT are USAT. Tokens recorded on any blockchain that is not, or is no longer, a Supported Blockchain, or that represent derivative, “wrapped,” or “bridged”versions of USAT, are not USAT and are not redeemable by ADB. ADB assumes no responsibility or liability for any losses, interruptions, or disruptions arising from forks, other protocol changes, or the existence or operation of tokens purporting to represent USAT.

Responsibility for Legal Compliance. Persons who acquire, hold, or use USAT do so on their own behalf and not as agents, representatives, or intermediaries of ADB. Each person is responsible for understanding and complying with all laws, regulations, and requirements that apply to them, including those arising from their jurisdiction, status, or activities. These may include licensing or registration requirements, or obligations under tax, securities, commodities, anti–money laundering, sanctions, consumer protection, and other legal or regulatory frameworks. ADB does not provide legal, tax, or regulatory advice and does not determine, monitor, or ensure any person’s compliance with applicable law.

Service Providers. ADB engages a range of service providers, which may include both affiliated and unaffiliated entities, to support the issuance, redemption, custody, management, and operation of USAT and related systems. These service providers may include technical and operational support providers, sub-custodians and asset managers responsible for the safekeeping or administration of the USAT Reserve, licensors of trademarks and other intellectual property, and entities that provide distribution,marketing, or other related services. All such service providers perform their respective roles under agreements with ADB. Although these service providers may support certain aspects of the USAT framework, ADB is the sole issuer of USAT and the only entity with obligations to redeem USAT in accordance with applicable law. None of these service providers issue, redeem, guarantee, or assume any responsibility or liability for USAT, and their operational support does not create or imply any obligations to USAT users with respect to USAT or any transactions, disputes or issues related there to.

USAT Trademark. “USAT” and the related logo (“USAT Trademarks”) are trademarks ofTether Operations, S.A. de C.V. (collectively with its affiliates, “Tether”) and are being used by ADB under license. The purchase, sale, holding, transfer, or other use of USAT does not create any rights or claims: (1) against ADB by any Client or other person who may have a trademark infringement claim against Tether with respect to the USAT Trademarks, or (2) against Tether by any Client or other person who may have rights or claims against ADB other than in connection with a trademark infringement claim related to the USAT Trademarks. The purchase, sale, transfer, holding, or other use of USAT does not confer upon any person any right, title, or interest, including any license rights in or to the USAT Trademarks. Any use of the USAT Trademarks without the express prior written consent of Tether is strictly prohibited. Tether is not the issuer of USAT and has no obligation to issue, redeem or guarantee USAT, or otherwise support USAT, or assume any responsibility or liability for USAT, including any transactions, disputes or issues related thereto, except trademark infringement claims with respect to the USAT Trademarks. USAT is separate and distinct from USDT, a U.S. dollar stablecoin issued by Tether International, S.A. de C.V. Tether is an intended third-party beneficiary with respect to this Section and has the right to enforce the terms of this Section directly against any person.