Terms & Conditions

GlobalBlock Europe, UAB

 

Terms and Conditions of Business

 

Version: v0.1 (May 2022)

Contact details:

info@globalblock.co.uk

+44 203 307 3780

Lvovo 25, 6th floor, LT-09320 Vilnius, Lithuania 

Trading hours: 9am-6pm (CET) Monday – Friday (excluding State holidays).

In this document, we, us or our refers to GlobalBlock Europe, UAB, a company registered under the laws of the Republic of Lithuania with company number 306045642 with its registered office at Lvovo g. 25-104, Vilnius, Lithuania (GlobalBlock).

This agreement (the Agreement) is for customers who have a registered office or place of residence in the locations set out Jurisdictions | Globalblock.

The websites and the services offered by GlobalBlock are NOT addressed to persons who have registered office or place of residence in any country that is not listed Jurisdictions | Globalblock.

This document contains the terms and conditions (the Terms) upon which customers use our Brokering Services and Custody Services with respect to Cryptocurrencies. By using the Services, you are agreeing to accept and comply with these Terms. The Terms are entered into, and create a contract between, you and GlobalBlock. You should read the Terms carefully and, in their entirety, before you use the Services. The Terms may be updated and amended by us at any time, and the updated version shall be sent to you as soon as practical. Any updated version of these Terms shall automatically repeal and replace the previous version.

To agree to these Terms, you must be at least 18 years of age and have the full capacity to accept these Terms and enter into transactions involving the sale or purchase of Cryptocurrencies.

Important Notice:

GlobalBlock Europe, UAB is registered in accordance with the applicable laws of the Republic of Lithuania as virtual currency depository wallet operator and virtual currency exchange operator. GlobalBloack Europe, UAB is not a licensed financial services provider and is not supervised by the Bank of Lithuania.

The trading of Cryptocurrencies involves a high degree of risk. The Services are suitable only for persons who (a) have the ability to bear the total loss of all amounts invested in Cryptocurrencies; (b) fully understand and accept the risk factors involved in participating in the Cryptocurrency markets (including, but not limited to, the risk factors described in clause 10 (Risk Factors) of these Terms); and (c) have a very high-risk tolerance for loss.

The Services provided by GlobalBlock pursuant to these Terms are execution-only broking services and custody services with respect to Cryptocurrencies. GlobalBlock cannot, and will not, provide you with any advice as to the suitability or risk-profile of any transaction which you request GlobalBlock to execute as part of the Services and does not provide investment, tax or legal advice or make any recommendations about the suitability of any investments or products for any particular investor. You should seek your own independent financial, legal, regulatory, tax or other advice before making an investment. Any decision to proceed or not to proceed with a given transaction rests solely with you the Client. In the event that you choose not to seek advice from a relevant adviser, you should consider whether the investment or product is suitable for you.

See clause 3 (Regulatory Status) below for further details on regulatory status.

Contents

 

1.    Defined words and expressions in these Terms

2.    Commencement.

3.    Regulatory status.

4.    Our Services.

5.    Brokerage Services.

6.    Custody Services.

7.    Trade Providers.

8.    Our fees & charges.

9.    Foreign exchange.

10.  Risk factors.

11.    Client confirmations and obligations.

12.   Onboarding you as a client.

13.   Communications.

14.  Our responsibilities and liability to you.

15.   Termination of our relationship.

16.   Confidentiality and disclosure of information.

17.   Data protection.

18.   Intellectual property.

19.   Our relationship.

20.  Tax.

21.   Other important terms.

22.  Complaints.

23.  Changes to our terms & conditions of business.

24.  Governing law and jurisdiction for disputes.

In this document, we, us or our refers to GlobalBlock Limited, a company registered under the laws of England and Wales with company number 09450626 with its registered office at Argyle House, 3rd Floor, Northside, Joel Street, Northwood Hills, Middlesex, HA6 1NW and its operational office at 65 Curzon Street, London, W1J 8PE (GlobalBlock).

 

  1. Defined words and expressions in these Terms

 

The bold, capitalised words and expressions used in these Terms have the following meanings:

AML and CFT Policy

  • GlobalBlock’s Anti-Money Laundering and Counter Financing of Terrorism Policy. 

  • We implement the money laundering and terrorist financing pre-vention requirements in accordance with the applicable require-ments of the Republic of Lithuania and international law govern-ing this area. The objectives of the GlobalBlock’s AML and CFT Policy, its implementation procedures and measures are regu-lated in internal documents of the GlobalBlock. The AML and CFT Policy covers these areas: 

    • “know your client” (KYC) procedures;

    • client identification;

    • monitoring of financial transactions performed by clients;

    • detection and suspension of suspicious transactions;

    • storage of information on client transactions and maintenance of the register;

    • timely information and training of employees;

    • internal control.

  • Information related to implementation of the AML and CFT re-quirements is included in the Onboarding Documents.

 

Asset Manager

  • A Client whose business involves making, advising on or man-aging investments for its own clients (Underlying Clients), and which will use the Services for the purpose of buying and selling Cryptocurrencies on behalf of the Underlying Clients.

 

Brokering Service

  • as defined in clause 4.1(a).

 

Client

  • The person (whether a natural individual person or a corporate legal entity) that has been onboarded as a client of GlobalBlock in accordance with these Terms and who will receive the Ser-vices. References to you or your are references to the Client.

Cold Storage

  • the storage of Cryptocurrency in an offline digital wallet.

 

Connected Person

  • With respect to GlobalBlock, its employees, officers, directors, agents, consultants, shareholders, members or partners.

 

Controller, Processor, Data Subject, Personal Data, Personal Data Breach, processing and appropriate technical and organisational measures

  • As defined in the Data Protection Legislation.

 

Cryptocurrency

  • Any digital currency, token or unit for which GlobalBlock agrees to provide the Services from time to time in accordance with these Terms, and which, for the avoidance of doubt, includes Compatible Cryptocurrencies. Cryptocurrencies shall be interpreted accordingly.

 

Crypto Omnibus Account

  • An omnibus Cryptocurrency account/wallet in the name of GlobalBlock and which shall be secured via MPC. Crypto Omni-bus Accounts shall be interpreted accordingly.

 

Compatible Cryptocurrency

  • Bitcoin (BTC), Ethereum (ETH), Tether (USDT) and USDC, or any other Cryptocurrency as determined by GlobalBlock. Compati-ble Cryptocurrencies shall be interpreted accordingly.

 

Custody Services

  • As defined in clause 4.1(b).

 

Data Protection Legislation

  • Lithuanian Data Protection Legislation and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of Personal Data (including, without limitation, the privacy of electronic communications); and the guidance and codes of practice issued by the relevant data protection or supervisory authority and applicable to a party.

 

Designated Broker

  • The individual person designated to you as a broker by Global-Block, or another person designated by GlobalBlock, if the first is unavailable.

 

DIIS

  • Deposit and investment insurance scheme of the Republic of Lithuania for the deposits held in banks and credit unions and liabilities of banks, brokerage firms, managements firms that have the right to provide investment services to investors.

 

Lithuanian Data Protection Legislation

  • the Financial Ombudsman Service of the United Kingdom.

 

Liveness Verification

  • An online verification used to detect a spoof attempt by deter-mining whether the source of the biometric data is a human be-ing or a fake representation.

 

LMFI

  • The Law on Markets in Financial Instruments (adopted on 18 January 2007, NoX-1024), as amended from time to time

 

Money Laundering Regulations

  • The Law on Prevention of Money Laundering and Terrorist Fi-nancing of the Republic of Lithuania, Order No. V-5 of the Direc-tor of the Financial Crime Investigation Service regarding the approval of instructions applicable to custodian virtual currency wallet operators and virtual currency exchange operators aimed at preventing money laundering and / or terrorist financing of 10 January 2020, other orders of the Director of the Financial Crime Investigation Service indicated therein as well as other relevant legislative acts applicable in regard to the prevention of money laundering and terrorist financing, as amended from time to time.

 

MPC or Multi Party Computation

  • An electronic procedure used to secure Cryptocurrencies in the Crypto Omnibus Account through a process of approvals from various selected parties.

 

Onboarding Documents

  • The documents and information you provide to GlobalBlock for the purposes of onboarding you as a Client with GlobalBlock, including, but not limited to, any information you provide in the online application form on the GlobalBlock website.

 

Privacy Policy

  • GlobalBlock’s privacy policy as then in force, an up-to-date copy of which may always be found on the GlobalBlock web-site.

 

Qredo

  • Qredo Limited, a private company incorporated in England & Wales (company number: 07834052) with registered address: Kemp House, 152-160 City Road, Islington, London, United Kingdom, EC1V 2NX.

 

Services

  • has the meaning given in clause 4.1.

 

Terms

  • The terms and conditions of business contained in this docu-ment which, together with the information contained in the Onboarding Documents, collectively govern the services pro-vided to the Client by GlobalBlock.

 

Third Party FX Services

  • has the meaning given in clause 9.2.

 

Third Party Provider

  • A service provider 

 

Trade Provider

  • A service provider that has been appointed by GlobalBlock to provide Trade Provider Services. More information about the Trade Providers we use is available on request.

 

Trade Provider Services

  • Services to assist and facilitate GlobalBlock provide the Services.

 

US Person

  • Any citizen of the United States of America or any person hold-ing a US passport regardless of residency or domicile; or any company having a registered office in the US or anyone who has an obligation to pay tax to the US tax authorities on their worldwide income.

2.   Commencement

   2.1.  These Terms shall commence on the date on which your GlobalBlock Designated Broker emails you that you have been successfully on-boarded as a Client and shall continue in force until terminated in accordance with clause 16 (Termination of our relationship).

3.   Regulatory status

3.1   Important Note: As at the date of these Terms, GlobalBlock is registered in accordance with the applicable laws of the Republic of Lithuania as virtual currency depository wallet operator and virtual currency exchange operator. GlobalBloack is not a licensed financial services provider, does not provide licensed services and is not supervised by the Bank of Lithuania. GlobalBlock is supervised by the Financial Crime Investigation Service in the context of the Money Laundering Regulations.

3.2.   It should be noted that in Lithuania, a digital currency does not have the status of legal tender and its creation does not have the same extensive regulatory protections and restrictions that apply in relation to Fiat Currencies such as EUR, GBP and USD. In addition, any digital currency values held by intermediaries are not currently protected under the DI-IS.

3.3.    Cryptocurrencies traded by Globalblock are not currently “financial instruments” under the LMFI and any investment activity (such as the sale or purchase) relating to such Cryptocurrencies does not come within the regulated framework of the LMFI. Therefore, the standard requirements on a regulated investment firm, such as, but not limited to, reporting obligations, transparency obligations, and capital reserves, shall not apply to Globalblock. In addition, the protections and remedies available to a Client within a regulated framework will not be available in this case.

4.   Our Services

4.1.    Subject to the provisions of these Terms GlobalBlock shall provide you with the following services (the Services):

(a)    execution-only brokering services to assist you in the buying and selling of Cryptocurrencies (relying solely on the Client’s instructions) through one or more Trade Providers (as further detailed in clause 6) (the Brokerage Services); and/or

(b)    the custody of your Cryptocurrency in a Crypto Omnibus Account or in Cold Storage (as further detailed in clause 7) (the Custody Services).

 

4.2.    Registration with GlobalBlock. In order to use the Services, you will need to register for an account (an Account) by providing your name, an email address, phone number and creating a password. By using an Account you agree and represent that you will use the Ser-vices only for yourself, and not on behalf of any third party, unless you have obtained prior approval from GlobalBlock in accordance with clause 12.7. You are fully responsible for all activity that occurs under your Account. We may, in our sole discretion, refuse to open an Account for you, or limit the number of Accounts that you may hold or suspend or terminate any Account or the trading of specific Cryptocurrency in your account.

 

4.3.    In order to use the Services, once onboarded as a Client (please see clause 16), the Client shall send the respective wallet address for the Compatible Cryptocurrency to Global-Block. The address from which the Compatible Cryptocurrency is to be received shall be screened and analysed by a third-party anti-money laundering partner with respect to, but not limited to, any suspicious or unlawful activity. If the wallet address is accepted by GlobalBlock, the Client shall send the Compatible Cryptocurrency to the client staging wallet address (address to be provided by your Designated Broker) and, once received, it will be transferred to a Crypto Omnibus Account (if applicable) or into Cold Storage. If our third-party anti-money laundering partner identifies any issues with the wallet address provided or the originating address of any transfer, GlobalBlock will notify you the Client and will request that you do not transfer the Compatible Cryptocurrency to the client staging wallet address. In the event that you do transfer such Compatible Cryptocurrency to the client staging wallet address or a small test transfer of Compatible Cryptocurrency has been remitted to us, we will send the equivalent Compatible Cryptocurrency back to the Client on request. If the client consistently provides wallet addresses that fail to meet the required score to pass the coin check then GlobalBlock reserves the right to close the clients account. Neither the Crypto Omnibus Account or the Cold Storage is a deposit or in-vestment account which means that your Cryptocurrency will not be protected by the DIIS.

4.4.    If a transfer to load Cryptocurrency into your client staging wallet address is not successful, you authorise GlobalBlock, in its sole discretion, to cancel any instructions or trades.

 

4.5.    Return of Cryptocurrency: You may request the return of all or part of any Cryptocurrency held in your Crypto Omnibus Account or Cold Storage at any time by instructing your Designated Broker. Unless agreed otherwise, your Cryptocurrency will be transferred to the wallet address you have registered with us which the Cryptocurrency was originally remit-ted to us within 1 Working Day. If this Agreement is terminated, we will return any Crypto-currency held in your Crypto Omnibus Account or Cold Storage and attempt to transfer the Cryptocurrency to the wallet address you have registered. We reserve the right to require you to re-complete the procedures outlined in clause 5 before transferring the Cryptocurrency to you. We will have no liability or responsibility for ensuring that the wallet address you provide is accurate and complete.

4.6.    Ending Support of a Cryptocurrency: GlobalBlock may in its sole discretion terminate support for any Cryptocurrency. GlobalBlock will provide you no less than 10 days’ notice (unless a shorter period is required by applicable law or a regulatory authority) via email to the email address associated with your GlobalBlock account to announce the end of such support. GlobalBlock reserves the right to return such Cryptocurrencies to the wallet ad-dress you have registered with us which the Cryptocurrency was originally remitted to us from following expiry of such 10 day period.

 

5.   Onboarding you as a client

5.1.   The onboarding process

 

In order to complete the onboarding process with GlobalBlock, you will need to:

 

(a)    Online form: Complete the application form as provided by GlobalBlock, on behalf of the individual or company that is being onboarded. Requirement to provide information on ultimate beneficiary owners, directors and shareholders who hold 25 % or more in respect to Company is applicable to the clients. 

 

(b)    KYC & AML documents for individual or company ultimate beneficiary owners, directors, shareholders: Provide documentation or information we require in accordance with our AML and CFT Policy and otherwise to satisfy our anti-money laundering, ‘know your customer’ (KYC) and other internal compliance requirements (together referred to as the KYC Documentation);

 

(c)    Liveness verification: agree to provide a Liveness Verification online; 

(d)    Additional documents: Provide any documentation we may request in addition to the in-formation provided in the online application form. For company this includes, but is not limited to:

- Certificate of Incorporation, Articles of Association;

- Extract from Commercial Register;

- Latest annual accounts;

- Proof of operational address, etc. 

 

You may also, as part of the onboarding process and/or during your relationship with us be required to update information provided to us during the onboarding and/or submit additional information about yourself or your business, provide relevant records, and arrange for meetings with GlobalBlock staff so that GlobalBlock may check that you are not sanctioned or in any way related with the sanctioned individuals (private individuals and/or company), among other things, establish the source of your wealth and source of funds for any transactions carried out in the course of your use of the Services.

5.2.    When transferring Cryptocurrency to us which has a value of EUR 15,000.00 (fifteen thou-sand euro) or higher, the Client shall be required to provide further documentation, as determined by GlobalBlock, evidencing the source of funds.

 

IMPORTANT NOTE: By providing us with any of the documentation referred to above in clause 5.1, you:

(a)    authorise us to forward such documentation on a Trade Provider on your behalf in order to facilitate the process of onboarding you as their client and for the ongoing provision of the services to you;

(b)    confirm that the information is true, accurate and complete, and you are not the subject of international sanctions. You have not withheld any information that may influence Global-Block’s evaluation of you for the purposes of your onboarding and use of the Services;

(c)    undertake to promptly notify in writing and provide GlobalBlock with information regarding any changes in circumstances that may cause any such information provided to become false, inaccurate or incomplete and also undertake to provide any other additional documents, records and information as may be required by GlobalBlock and/or applicable law.

 

Please see our Privacy Policy for further details on how we process and safeguard your personal information.

 

5.3.    By submitting the online application form, and ticking the relevant consent tick box, you consent to us carrying out such credit and identity checks as we consider necessary with our third-party KYC service providers and to us holding copies of identification documen-tation and sharing their details with our third-party KYC service providers in accordance with our Privacy Policy.

 

5.4.    Your Designated Broker will confirm to you by email or phone once you have been successfully onboarded as a Client with GlobalBlock. If we have any further questions on your application or require additional documentation we will contact you promptly by email or phone.

 

When your Designated Broker contacts you to confirm that you have been successfully onboarded as a Client, they will inform you of their contact details (telephone number and email address) and that your account is live.


5.5.    Each Client can only be onboarded once and can only open one account. You are fully responsible for all activity that occurs under your Account.

 

Important Note: We are not obliged to accept you as a Client and may refuse your application for any reason without providing the reason for the decision. We may also impose restrictions as a condition of agreeing to provide Services to you and may suspend or terminate any accounts and / or suspend or terminate the provision of the Services at any time if you do not provide information asked by GlobalBlock, or we think that there is are risk regarding implementation of AML and CFT Policy and/or legal regulation requirements also requirements regarding implementation of international sanctions. Also we can act as it is described above if we suspect unlawful activity, or we think that activity is suspicious or are not in line with our risk mitigation processes.

6.   Brokerage Services

6.1.    GlobalBlock shall provide you with the Brokerage Services. The process of buying and selling Cryptocurrencies as part of the Brokerage Service (including the process for placing and confirming orders, notification and approval of charges, cut-off times, settlement timescales, record-keeping procedures and other logistical matters) will vary depending on the Trade Provider used for the transaction and will be subject to the terms of their service agreement(s) applicable to that transaction.


6.2.    An “execution-only” service means that we will not advise you (whether in general terms or specifically) on the merits, risks or suitability or otherwise of any Cryptocurrency trading transaction that you are contemplating, nor the suitability or risk-profile of such transactions or prevailing or future market trends.

 

Important Notice: Any decision to proceed or not to proceed with a given transaction rests solely with you.

 

6.3.    When using the Brokerage Services, you may request to make a trade at any time 9am – 6pm CET (Business Hours) on any day Monday to Friday on which banks are open in England (a Business Day) by contacting your Designated Broker by telephone or email using the contact details you were provided with on confirmation of your acceptance as a Client.


6.4.    You should verify all trade information prior to submitting instructions to us. We will have no liability or responsibility for ensuring that the information you provide is accurate and complete. Once you have given us instructions to carry out a trade, you cannot withdraw your instruction unless the trade is not due to occur until a date in the future agreed with your Designated Broker.


6.5.    If we receive instructions from you to purchase or sell Cryptocurrency outside of Business Hours and/or on day that is not a Business Day, we may treat those instructions as if they were received by us on the following Business Day. Your trade will normally be settled no later than one Business Day after we receive your instructions but this may vary depending on which Trade Provider is used – please ask your Designated Broker for further detail in relation to each trade.  


6.6.    If you believe that a trade using your Cryptocurrency has been incorrectly carried out (an Incorrect Trade) you must contact us as soon as possible, and in any case no later than 24 hours after the Incorrect Trade occurred. If such Incorrect Trade occurred as a re-sult of our of our action or error, we will refund you the amount of that trade without undue delay and restore your Cryptocurrency balance to the state in which it would have been had the Incorrect Trade not taken place. We will always use our reasonable endeavours to provide the Brokerage Services on a ‘best execution’ basis, to ensure that the transaction process is efficient and transparent and to fulfil all trade instructions. However, due to the nature of market, this may not always be possible. If this is the case, we will notify you and seek your approval to re-attempt the purchase at the then current exchange rate for the transaction. You acknowledge that the purchase rate may not be the same as the selling rate at any given time. You agree to accept the relevant rate when you authorise a transaction. We do not guarantee that you will be able to buy and / or sell your Cryptocurrency at any particular price or time.


6.7.    GlobalBlock securely stores Cryptocurrency private keys, in a combination of MPC (multi-party computation) wallet and online and offline storage. Our security protocols may delay the initiation or crediting of a trade.

6.8.    GlobalBlock reserves the right to refuse to accept, suspend or cancel any trade order from you at any time in our absolute discretion without the need to give you an explanation, including that we may apply minimum trading amounts in relation to certain Cryptocurrencies and, if you provide us with instructions to make any trade that does not meet such trading minimums, we may inform you that we will not make such trade. GlobalBlock may return Cryptocurrency to the Client at any time without the need to provide any reason. You acknowledge that our decision to take certain actions, including limiting access to, sus-pending, or closing your account, may be based on confidential criteria that are essential for the purposes of our risk management and security protocols. You agree that Global-Block is under no obligation to disclose the details of its risk management and security procedures to you.


6.9.    If we refuse to complete a transaction and / or suspend or restrict your account, and / or terminate your use of the Brokerage Services, we will (unless it would be unlawful for us to do so) provide you with notice of our actions. In the event that we refuse to complete a trade and / or suspend your account we will lift the suspension or complete the transaction as soon as reasonably practicable once the reasons for refusal and / or suspension no longer exist. However, we are under no obligation to reinstate a trade at the same price or on the same terms as the suspended, reversed or cancelled trade or to inform you of the reason for our refusal to compel a trade or our suspension of your account.


6.10.    All transactions will be carried out in English.

 

7.   Custody Services

7.1.    GlobalBlock shall manage the storage and security of Compatible Cryptocurrencies through a Crypto Omnibus Account. The Client acknowledges and accepts that a Crypto Omnibus Account shall be in the name of GlobalBlock, and not in the name of the Client. All Cryptocurrencies held for you by us are assets held by GlobalBlock for your benefit on a custodial basis. Among other things, this means:


(a)    Title to Cryptocurrency shall at all times remain with you and shall not transfer to Global-Block. As the owner of Cryptocurrency, you shall bear all risk of loss of such Cryptocurrency. GlobalBlock shall not have any liability for fluctuations in the value of Cryptocurrency held for you.


(b)    None of the Cryptocurrencies held for you are the property of, or shall or may be loaned to, GlobalBlock; GlobalBlock does not represent or treat the Cryptocurrency as belonging to GlobalBlock. GlobalBlock may not grant a security interest in the Cryptocurrency held for you. Except as required by a facially valid court order, or except as provided herein, GlobalBlock will not sell, transfer, loan, hypothecate, or otherwise alienate Cryptocurrency held for you unless instructed by you or compelled by a court of competent jurisdiction to do so.

 

7.2.    The Client acknowledges that their Compatible Cryptocurrency stored in a Crypto Omnibus Account shall not be segregated from the Cryptocurrency of other clients of GlobalBlock. GlobalBlock may use shared blockchain addresses, controlled by GlobalBlock, to hold Cryptocurrencies held on behalf of Client’s and/or held on behalf of GlobalBlock and GlobalBlock shall not have any obligation to use different blockchain addresses to store Cryptocurrencies owned by you and Cryptocurrencies owned by other clients or by GlobalBlock.


7.3.    A Crypto Omnibus Account shall be secured by utilising an MPC facility provided by Qredo. Qredo provides software and security technology that enables MPC security over crypto assets, and are lead developers of the Qredo protocol.

Important Notice: The Client acknowledges and accepts that they will not be able to make a direct contractual claim against Qredo or any person who is a signatory with respect to any failure in, or loss suffered in relation to the use of, the relevant MPC facility.

 

7.4.    Clients may only use Crypto Omnibus Accounts for Compatible Cryptocurrencies. If you do not wish to use, or are unable to use, a Crypto Omnibus Account, you will either need to take delivery of any Cryptocurrency yourself, or, notify GlobalBlock that the Cryptocurrency should be stored in Cold Storage by GlobalBlock. You acknowledge that you will pay any fees payable in relation to the use of such Cold Storage.


7.5.    The Client acknowledges and accepts that, as the Cryptocurrency will not be segregated from the Cryptocurrency of other clients of GlobalBlock, should GlobalBlock become subject to insolvency proceedings, it is unclear how the Cryptocurrency (which are held by them at that time, either in a Crypto Omnibus Account or in Cold Storage) would be treated and what rights the Client would have to the ownership of the Cryptocurrencies.

 

Important Notice: The Client acknowledges that GlobalBlock has no responsibility or duty to take or enter into an insurance policy in its own name or capacity and will not be liable to the Client in relation to any loss suffered as a result of not taking out such insurance policy. The Client shall not be able to make a direct contractual claim against Qredo with respect to any such insurance policy.

7.6.    All Cryptocurrency stored in a Crypto Omnibus Account shall be secured via MPC. GlobalBlock shall use reasonable efforts to check that Qredo has an insurance policy in place to cover losses on a Crypto Omnibus Account caused by certain types of criminal activity in connection to the MPC security facility provided by them. However, GlobalBlock gives no guarantee to the Client that Qredo shall have, or continue to have, any such insurance policy, nor makes any representation or warranty that such insurance policy is ro-bust or sufficient or will cover any losses suffered by the Client.

 

Important Notice: The Client acknowledges that GlobalBlock has no responsibility or duty to take or enter into an insurance policy in its own name or capacity and will not be liable to the Client in relation to any loss suffered as a result of not taking out such insurance policy. The Client shall not be able to make a direct contractual claim against Qredo with respect to any such insurance policy.

7.7.    GlobalBlock shall have the right to return any Cryptocurrency to the Client at any time without providing any reason. GlobalBlock may suspend the Crypto Omnibus Account should it determine (in its sole discretion) that the Client is involved in any suspicious or unlawful activity.

 

8.   Trade Providers

8.1.    GlobalBlock will buy and sell Cryptocurrencies through its approved Trade Providers. De-pending on the nature of the Services required by a Client, it may be necessary for GlobalBlock to engage multiple Trade Providers. For more information about the Trade Providers we use please ask your Designated Broker.


8.2.    Important Notice: GlobalBlock shall not be responsible for any damage or loss you may suffer as a result of the actions or omissions (i.e. any failure to act) of a Trade Provider that GlobalBlock is unable to recover from such Trade Provider under its relevant agreement (including but not limited to, a failure or delay in the execution or settlement of trades). Further information on the extent to which GlobalBlock shall be liable to you is provided in clause 14.

 

 

9.   Our fees & charges

9.1.    You agree to be responsible for the payment of, and you shall pay, all fees and charges (the Fee) to GlobalBlock in accordance with the provisions set-out in Schedule 2 (Fees). 

10.   Foreign exchange

10.1.    Currency restrictions may apply when buying or selling Cryptocurrencies using the Ser-vices. For example, it may only be possible to buy certain Cryptocurrencies using certain Fiat Currencies. Your Designated Broker can provide further information on any applicable currency restrictions in place in relation to a proposed trade.


10.2.    A Trade Provider may be able to perform additional FX conversion services for you in conjunction with a trade (a Third Party FX Service). Any such Third Party FX Services will be subject to the terms of their applicable service agreement(s) and GlobalBlock shall not be liable to Client for any loss arising from Client’s procurement of such services from a Third Arty FX Service Trade Provider.

 

11.   Risk factors

 

Important Notice: By using the Services, you acknowledge and accept the significant risks which are associated with participating in the Cryptocurrency markets, and you understand and accept that GlobalBlock will not held responsible for any losses relating to such risks, which include, but are not limited to, the following:

11.1.    Highly volatile asset class: Cryptocurrencies are a volatile and relatively immature asset class which are subject to a very high degree of volatility, and any investment in them which you may make is exposed to a high level of risk of partial or total loss.


11.2.    Regulatory risk & change of laws: The current low level of regulation applicable to Cryptocurrencies means that activities in this asset class are subject to higher risks than more heavily regulated asset classes. In addition, regulatory authorities in most major jurisdictions are in the process of assessing how to regulate Cryptocurrencies and it is very likely that the global legal and regulatory landscape in this area will change considerably in the near future, which could have significant implications for Cryptocurrency prices and liquidity.


11.3.    Fraud risk: This asset class is subject to a high degree of risk of fraud (including through malicious hacking and data breaches).


11.4.    Technical risks: We do not own or control the underlying software protocols which govern the operation of Cryptocurrencies. Generally, the underlying protocols are ‘open source’ and anyone can use, copy, modify, and distribute them. We assume no responsibility for the operation of the underlying protocols and we are not able to guarantee the functionality or security of network operations. You acknowledge and accept the risk that underlying software protocols relating to any Cryptocurrency, you provide to use or we purchase or sell on your behalf may change.

In particular, as a result of the innovative nature of the technology underpinning Cryptocurrency assets, they carry a high degree of technical/IT-related risk which may result in significant losses. There is also a risk of loss of value of Cryptocurrency assets relating directly to the cryptographic nature of the assets, for example risks associated with ‘soft’ or ‘hard’ forks in the blockchains underlying a particular Cryptocurrency. It is your responsibility to make yourself aware of upcoming operating changes and you must carefully consider publicly available information and information that may be provided by GlobalBlock in determining whether to continue to transact in the affected Cryptocurrency. GlobalBlock will use its best efforts to provide you notice of its response to any material operating change; however, such changes are outside of GlobalBlock’s control and may occur without notice to GlobalBlock. GlobalBlock’s response to any material operating change is subject to its sole discretion and includes deciding not to support any new digital currency, fork, or other actions. You acknowledge and accept the risks of operating changes to Cryptocurrency protocols and agree that GlobalBlock is not responsible for such operating changes and not liable for any loss of value you may experience as a result of such changes in operating rules.

 

11.5.    Liquidity risk: Certain Cryptocurrencies may lack liquidity meaning that they cannot be sold ad hoc or sold only at a reduced price, particularly in adverse market conditions.


11.6.    Execution-only trading risk: As GlobalBlock provides an execution-only brokerage ser-vice, and does not provide any tailored or general trading advice to Clients on their pro-posed Cryptocurrency transactions, GlobalBlock is not responsible for Clients’ investment decisions and Client is responsible for the risk of incurring losses resulting from any deci-sions it makes.


11.7.    Counterparty risk: Significant loss may result if a counterparty to a transaction is partially or completely unable to honour its obligations in respect of the transaction.


11.8.    Tax risk: Changes of the law might lead to an unexpected value decrease of your Crypto-currency investments or an unexpected tax liability.

12.   Client confirmations and obligations

By signing the relevant Onboarding Documents and using the Services, you understand, agree and confirm to us that:

12.1.    You accept these Terms, and any updates made to these Terms in accordance with clause 24;


12.2.    You are at least 18 years of age and have the full capacity to accept these Terms and enter into transactions involving the sale or purchase of Cryptocurrencies;


12.3.    We will not provide you or anyone else with any investment advice in connection with the sale or purchase of Cryptocurrencies;


12.4.    You trade entirely at your own risk and we are not responsible for any loss you may suffer as a result of the sale or purchase of Cryptocurrencies through the Services provided by GlobalBlock;


12.5.    You have obtained (and will maintain and comply with terms of) any licences, consents, registrations, authorisations, recognitions, approvals and exemptions necessary for the transactions you will undertake through GlobalBlock;


12.6.    Any information you provide to us at any time will be true, accurate and not misleading, and when necessary you agree to update us as soon as you become aware of any important changes to such information;


12.7.    You will not act on behalf of or carry out transactions on behalf of a third party and all funds and/or Cryptocurrency assets provided for the purposes of the Services legally and beneficially belong to you except in the case where you are an Asset Manager. If, as an Asset Manager and following receipt of GlobalBlock’s consent, you grant permission to a third party to access or use the Services you acknowledge that granting permission to a third party to take specific actions on your behalf does not relieve you of any of your responsibilities under this Agreement. You are fully responsible for all acts or omissions of any third party with access to the Services and any action of such third party shall be considered to be an action authorised by you. Further, you acknowledge and agree that you will not hold GlobalBlock responsible for, and will indemnify GlobalBlock from, any liability arising out of or related to any act or omission of any third party with access to the Services;


12.8.    You are not using and will at no time use the Services for any transaction which is illegal or contrary to any law or regulation in force anywhere in the world at the time when the trans-action is entered into;


12.9.    You are not using and will at no time use the Services to perform criminal activity of any sort, including but not limited to money laundering or terrorist financing;


12.10.    You have the capability to take delivery of any Cryptocurrency you purchase through your use of the Services and will provide GlobalBlock with any such information GlobalBlock requires to effect such delivery immediately on request;


12.11.    Where you are onboarded as a Client with GlobalBlock jointly with more than one person, instructions from any of those persons will be deemed as coming from all. We will hold all joint Clients jointly and severally liable for all instructions and GlobalBlock shall not be liable to Client in relation to any dispute between such persons in relation to GlobalBlock’s actions taken to comply with such instructions;


12.12.    You have full authority to engage GlobalBlock and any Cryptocurrency deposited with or held by GlobalBlock is free from all liens, charges or other encumbrances;


12.13.    You are not a US Person or a national of any country listed in the United States Department of Treasury’s Office of Foreign Assets Control website at http://www.treas.gov/ofac; 

 

12.14.    You further warrant and represent to us that:


(a)    You have been duly granted all necessary authority by your Underlying Client to use the Services on its behalf.


(b)    Your use of the Services will not breach any legal, regulatory or other obligations (including contractual obligations) to which you may subject, including any duties or obligations owed to your Underlying Clients; and


(c)    You have obtained (and will maintain, and your use of the Services will be in full compliance with) any licences, consents, registrations, authorisations, permis-sions, recognitions, approvals and exemptions (whether regulatory or otherwise) which are required for the transactions you undertake through GlobalBlock.

 

12.15.    Indemnity: You agree to indemnify GlobalBlock and/or any of its Connected Persons against all losses, costs or liabilities (including reasonable legal fees and expenses) that it or they may incur as result of claims, actions, suits or proceedings brought against them by any person in connection with any breach of the warranties and representations in clauses 12.15(a) to 12.15(c) (inclusive) above.


12.16.    Important Notice: If at any time after we have on-boarded you as a Client, we become aware that any of the confirmations or undertakings in this clause 12 was or is untrue (wholly or partially), we reserve the right, without notice to you, to cease processing any transactions for you, and take such further action as we, in our absolute discretion, see fit or are required to take under any law or regulation to which we are subject.

 

13.   Communications

13.1.    No verbal statements by GlobalBlock, its Connected Persons, the Designated Broker or its brokers, employees or agents will be binding unless and until confirmed in writing (which shall include by email) by GlobalBlock.


13.2.    The Client agrees that GlobalBlock may contact them both on a non-real time basis (e.g. by sending the Client written documents or emails) and on a real-time basis (e.g. by telephoning the Client) and the Client consents to such communications and acknowledges that such communication would not be considered by the Client as being a breach of any of its rights under the Lithuanian Data Protection Legislation.

 

14.   Our responsibilities and liability to you

14.1.    Nothing in these Terms will limit or exclude GlobalBlock’s liability to you for fraud, fraudulent misrepresentation, or any other liability which cannot be limited or excluded by law.


14.2.    Neither GlobalBlock or any Connected Person will be responsible or liable in any respect for any of the below listed types of loss or damage you suffer in connection with the Services:


(a)    Loss of value of your Cryptocurrency assets (including, but not limited to, losses attributable to any of the risk factors listed in clause 10);


(b)    any loss of use of hardware, software or data and / or any data corruption or loss; data breaches or hacks; any losses or damages arising out of or relating to any inaccuracy, defect or omission of Cryptocurrency price data; any error or delay in the transmission of such data; and / or any interruption in any such data; loss or malfunction of Cryptocurrency wallets; and loss or malfunction of cryptographic keys;


(c)    Breaches of the Agreement or Delays in the execution of trades caused by matters outside of our reasonable control or due to the application of mandatory legal rules;


(d)    Loss arising as a result of the acts or omissions of Trade Providers or other third-parties engaged as part of the Services that GlobalBlock is unable to recover from such Trade Provider or third-party under the relevant agreement;


(e)    loss of profits, loss of anticipated savings and / or any actual or hypothetical trading losses. This means, by way of example only (and without limiting the scope of the preceding sentence or any other caps on liability under these Terms), that if you claim that we failed to custody your Cryptocurrency in accordance with these Terms and this resulted in a loss of such Cryptocurrency, your damages are limited to no more than the value of such Cryptocurrency, and that you may not re-cover for any "loss" of anticipated trading profits or savings as a result of such loss of the Cryptocurrency;


(f)    any loss of, or damage to, reputation or goodwill; any loss of business or opportunity, customers or contracts; any loss or waste of overheads, management or other staff time; or any other loss of revenue, whether direct or indirect;


(g)    any “indirect” or “consequential” loss as defined by the laws of England; and


(h)    any loss or damage whatsoever which does not arise directly as a result of our breach of these Terms (whether or not you are able to prove such loss or dam-age),


even if we are advised of or knew or should have known of the possibility of the same.

14.3.    Indemnity: You agree to indemnify GlobalBlock and/or any of its Connected Persons against all losses, costs or liabilities (including reasonable legal fees and expenses) that it or they may incur a result of claims, actions, suits or proceedings brought against them by any third party in connection with your breach and / or our enforcement of these Terms or your violation of any law, rule or regulation, or the rights of any third party. This means that that you will be required to compensate us in full (on a pound-for-pound basis) for any such losses.


14.4.    Liability Cap: Subject to clauses 14.1 to 14.2 (inclusive), GlobalBlock and any Connected Person’s total aggregate liability to you for any losses, costs, liabilities or expenses which you may suffer arising out of, or in connection with, any breach by us (or any Connected Person) of these Terms, shall be limited to a maximum aggregate amount equivalent to the total amount of Fees which GlobalBlock has received from you in the period from the commencement of these Terms to the date of the relevant breach by GlobalBlock or the relevant Connected Person.

 

15.   Termination of our relationship

 

15.1.    Either GlobalBlock or the Client may terminate the contract formed by these Terms at any time and for any reason by prior 14 days written notice to the other party, subject to the remaining provisions of this clause 15.


15.2.    Termination shall not affect any accrued rights, remedies, obligations and liabilities of the parties as at the date of Termination.


15.3.    We reserve the right to terminate the Agreement immediately at any time where there is a material breach of the Terms by you, where we are unable to contact you with regard to any matter or due to any other significant reasons (for example, we reasonably suspect that you behave fraudulently or otherwise criminally, provide to us incorrect information, put our reputation at risk, etc.). We also reserve the right to terminate the Agreement where it becomes unlawful for us to carry out the Services or we are obliged to do so by virtue of any legal or regulatory obligation.


15.4.    In the event of Termination, we will close out any trades not completed and inform you of any loss or liability incurred. You are responsible for the loss or liability we have incurred as a result of closing out such trades and you must pay such loss or liability incurred promptly on demand by GlobalBlock. We reserve the right to use any sums standing to the credit of any Custodian Account to settle all or part of the loss or liability.


15.5.    In the event of Termination, subject to clause 15.4, we will return your Cryptocurrency to you in accordance with clause 4.5.

 

16.   Confidentiality and disclosure of information

 

16.1.    Save as set out in clause 16.2 below and otherwise provided by these Terms and our Pri-vacy Policy, we will keep confidential and not disclose to third parties any personal infor-mation relating to you, including your name, address, email address and details any of the trades you have made with us (Personal Information) without your written consent. For the avoidance of doubt, this consent does not relate to our processing of your personal in-formation or your rights under and in accordance with data protection law and regulations. Please see clause 17 (Data Protection) below and our Privacy Policy for information about how we process your personal data, and the rights you have in respect of this.


16.2.    We reserve the right at all times to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, regulation, sanctions programs, legal process or governmental request. We may also disclose, in our absolute discretion and without fur-ther notice to you, any Personal Information to Trade Providers, other third-parties en-gaged in connection with the provision of the Services, law enforcement, taxation authori-ties, data protection authorities, government officials, and any other regulatory authorities when:


(a)    required or requested by law or regulatory authorities;
(b)    required by court order or other legal procedure; or
(c)    where disclosure is necessary to report suspected illegal activity.


16.3.    With respect to US persons, we may share your information with other financial institutions as authorized under Section 314(b) of the US Patriot Act, and with tax authorities, including the US Internal Revenue Service, pursuant to the Foreign Account Tax Compliance Act (FATCA), to the extent that this statute may be determined (by us in our discretion) to ap-ply.

 

17.   Data protection

 

17.1.    Both parties will comply with all applicable requirements of the Data Protection Legislation. This clause 17.1 is in addition to, and does not relieve, remove or replace, a party's obliga-tions or rights under the Data Protection Legislation.


17.2.    The parties acknowledge that for the purposes of the Data Protection Legislation Global-Block is the Controller.


17.3.    You acknowledge that we may process personal data in relation to you (if you are an indi-vidual), and personal data that you have provided (or in the future provide) to us in relation to your employees and other associates, or other individuals (if you are not an individual), in connection with these Terms, or the Services. We will process this personal data in ac-cordance with the Privacy Policy, which shall form part of these Terms. Accordingly, you represent and warrant that:


(a)    your disclosure to us of any personal data relating to individuals other than your-self was or will be made in accordance with all applicable data protection and data privacy laws, and those data are accurate, up to date and relevant when disclosed;


(b)    before providing any such personal data to us, you acknowledge that you have read and understood our Privacy Policy, a copy of which is available here: Privacy Policy, and, in the case of personal data relating to an individual other than your-self, have (or will at the time of disclosure have) provided the individual with a copy of, or directed the individual towards a webpage containing that Privacy Pol-icy (as amended from time to time); and


(c)    if from time to time we provide you with a replacement version of the Privacy Poli-cy, you will promptly read that notice and provide updated copies of the Privacy Policy to, or re-direct towards a webpage containing the updated Privacy Policy, any individual whose personal data you have provided to us.

 

18.   Intellectual property

 

The GlobalBlock Limited trademarks and logos are our property. They should not be copied, re-produced, modified, republished, uploaded, posted, transmitted, scraped, collected or distributed in any form or by any means, whether manual or automated.

 

19.   Our relationship

 

Nothing in these Terms is intended to, or will be deemed to, establish any partnership or joint ven-ture between GlobalBlock and the Client or any other person, nor constitute any person the agent of another person, nor authorise any person to make or enter into any commitments for or on be-half of any other person.

 

20.   Tax

 

It is your sole responsibility to determine whether, and to what extent, any taxes apply to any transactions that you request as part of the Services, and to withhold, collect, report and remit the correct amounts of taxes to the appropriate tax authorities.

 

21.   Security Interests

You must not create security over your Cryptocurrency unless you have sought our prior approval in writing.

22.   Other important terms

22.1.    Recording of telephone calls: Telephone calls between Clients and GlobalBlock may be recorded and retained for training purposes and/or as verification of instructions to trade by the Client. Such calls may be used in evidence in the event of a dispute.


22.2.    Unenforceability: If any provision or part-provision of these Terms is or becomes invalid, illegal or unenforceable under the laws of any relevant jurisdiction, that provision or part-provision will be deemed to be deleted from the Term, and that deletion will not affect the validity and enforceability of the rest of these Terms. Furthermore, the deleted provision or part-provision shall be replaced with wording necessary to achieved the necessary commercial result and the parties shall act in good faith to agree such wording.


22.3.    Enforcement of Our Rights: We may not always strictly enforce our rights under these Terms. If we do choose not to enforce our rights at any time, this is a temporary measure and we may enforce our rights strictly again at any time.


22.4.    Entire agreement: These Terms (including documents incorporated by reference herein) constitute the entire agreement between GlobalBlock and the Client with respect to the matters covered, and these Terms take precedence over all previous written, verbal or im-plied understandings between them with respect to those matters. By accepting these Terms you confirm that you are not relying upon any statements, representations, promises or undertakings that are not contained in these Terms.


22.5.    Survival: All provisions of these Terms which by their nature extend beyond the expiration or termination of these Terms, including, without limitation, the clauses relating to termination, account cancellation, debts owed to GlobalBlock, use of the Services, disputes, and general provisions will continue to be binding and operate after the termination or expiration of this Agreement.


22.6.    Force majeure: If we are unable to perform the Services due to a Force Majeure Event, our obligations to you in respect of the Services will cease for as long as we continue to be unable to provide the Services. For the purposes of this clause, a “Force Majeure Event” means any circumstance beyond our reasonable control, including but not limited to, any changes of laws or sanctions policies, delay or failure due to any act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other industrial dispute, fire, interruption in telecommunications or Internet services or network provid-er services, failure of equipment and/or software, data loss, theft or corruption, or other catastrophe or any other occurrence which is beyond our reasonable control.

 

23.   Complaints

23.1.    If you wish to make a complaint, you should advise your Designated Broker of the com-plaint immediately. In order to allow us to investigate your complaint promptly and effectively, you should provide your Designated Broker with full details of the circumstances giving rise to your complaint including, if applicable, details of the time and date of any relevant actual or purported request or trade. We reserve the right not to commence investigations until such details are provided. We will investigate the complaint promptly and fully and provide a written response to your complaint.


23.2.    For complaints or disputes arising out of or in connection with this Agreement or the pro-vision of the Services that cannot be resolved via the complaint process set out in clause 23.1 above, you submit to the non-exclusive jurisdiction of the courts of the Republic of Lithuania without prejudice to any mandatory rights available to consumers (being individuals not engaged in conduct related to their trade, business or profession) to commence proceedings against GlobalBlock.


23.3.    GlobalBlock and the provision of the Services are not covered by the DIIS.

24.   Changes to our terms & conditions of business

We may amend these Terms at any time by notifying you of the amended terms and conditions. Such notification can be made to you by email (to the email address that we hold for you from time to time) and your continued use of any of Services after the date of such notification means that you agree to and accept such amended terms and conditions.

25.   Governing law and jurisdiction for disputes

 

These Terms will be governed by and construed in accordance with the laws of the Republic of Lithuania and by accepting these Terms all parties agree to the exclusive jurisdiction of the Lithua-nian courts to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms.

Schedule 2: Fees

 

The Client shall pay GlobalBlock fees for the provision of a Crypto Omnibus Account and/or for GlobalBlock holding Cryptocurrency in Cold Storage for the Client as notified to the Client by the relevant Designated Broker prior to the commencement of provision of the relevant service (the Fee).

(1)    The Fee shall start to accrue two (2) Business Day’s after GlobalBlock receives the Client’s Cryptocurrency in the Crypto Omnibus Account and/or in Cold Storage. The Fee shall be calculated by GlobalBlock based on the value of the Cryptocurrency held in its Crypto Omnibus Account and/or Cold Storage on each Business Day of each calendar month.


(2)    The Client shall pay the Fee by the last Business Day of each calendar month. Global-Block shall send an invoice to the prior to the last Business Day of each calendar month Client setting out the Fee. The Fee shall be paid by the Client in the currency stated on the invoice.


(3)    GlobalBlock shall be entitled to charge the Client interest at a rate equal to two percent (2%) per annum above the then current base lending rate of HSBC Bank Plc at the date the invoice was issued on any validly issued invoices paid late.


(4)    The Client acknowledges and agrees that they shall be responsible for the payment of any charges, transfer fees, registrations fees, taxes, duties and other fiscal liabilities and all other liabilities and costs properly payable or incurred by GlobalBlock under this Agreement.


(5)    GlobalBlock shall be entitled to charge the Client for any expenses reasonably incurred by any individuals or firms which GlobalBlock engage in connection with the Services including, but not limited to, travelling expenses, hotel costs, subsistence and any associated expenses, and for the cost of services provided by third-parties and required by us for the performance of the Services, and for the cost of any materials. 


(6)    All amounts payable to GlobalBlock under these Terms are exclusive of VAT. Where any taxable supply is made under these Terms, GlobalBlock shall raise a valid VAT invoice, including any additional amounts in respect of VAT as are chargeable on the supply of the Services, when payment of the Fee is due.

Transaction Fee

1.    The Client shall pay GlobalBlock fees for the purchase, sale, or conversion of Cryptocurrencies (the “Transaction Fee”).

2.    Unless a transaction is a large notional transaction or is executed with the OTC team (in which case the fees shall be determined in accordance with section 4 of this Transaction Fee section), the Transaction Fee for transactions relating to any Cryptocurrency which at the time of the transaction is ranked in the top twenty cryptocurrencies by market capitalisation as determined by GlobalBlock (list available on request) shall be 1% (one per cent) of the value of the transaction. The Transaction Fee for transactions relating to any other Cryptocurrency shall be 2% (two per cent) of the value of the transaction. 

3.    The Transaction Fee for any withdrawal with a total value less than £5,000 (five thousand pounds sterling) shall include an additional fee of £25 (twenty five pounds sterling). GlobalBlock may waive this additional fee in the case of bulk transactions (e.g. where the transaction forms part of a Basket Trade). 

4.    The Transaction Fee for any large notional transaction or any transaction executed with the OTC team shall be calculated at the time of the order and determined by GlobalBlock on the basis of a number of factors, including market liquidity, the size of the transaction, and execution risk. 

5.    All Transaction Fees will be disclosed to the Client prior to the Client confirming that it wishes to complete the transaction. Transaction Fees for transactions completed through GlobalBlock’s website or mobile application will be deducted from the balance on the Client’s account or from the Client’s transaction proceeds upon completion of the transaction.  Transaction Fees for transactions completed using the GlobalBlock over the counter service will be agreed on a net basis.