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Digital Assets Policy

PayServices Bank’s policy on cryptocurrencies, tokens, stablecoins, and other digital instruments — what we support, how we hold assets, how compliance applies, and what is not permitted.

Last updated: May 5, 2026
This document is provided in English only. The English version governs in all cases.

1. Overview

PayServices Bank is a state-chartered banking corporation organized under the laws of Idaho. It is not federally insured — deposits at PayServices Bank are not covered by any federal deposit insurance program.

This policy governs how PayServices Bank treats digital assets — including cryptocurrencies, tokens, stablecoins, and other instruments recorded on distributed ledgers — in connection with accounts maintained on the ITAM platform. It states what we support today, how we hold assets, what compliance obligations apply, and what we do not permit. It will be updated as the law develops.

Digital assets are not bank deposits and carry no guarantee of value. Nothing in this policy, and nothing in the operation of any digital asset feature on ITAM, constitutes a guarantee, warranty, or assurance of the value of any digital asset. The value of digital assets can be volatile and can decline to zero.

2. Definitions

The following terms are used throughout this policy. Where a term also has a definition in federal statute or other binding authority, that definition governs in the event of any conflict.

Digital asset

Any digital representation of value that is recorded on a cryptographically secured distributed ledger. The term encompasses virtual currency, payment stablecoins, digital securities, utility tokens, and non-fungible tokens. A digital asset is intangible personal property; it is not legal tender and is not a bank deposit.

Virtual currency

A digital asset that functions as a medium of exchange, unit of account, or store of value but is not recognized as legal tender by any government. Virtual currency is treated as property for U.S. federal income tax purposes. The most common examples are Bitcoin and Ether.

Payment stablecoin

A digital asset used or designed to be used as a means of payment or settlement, the issuer of which is obligated to redeem it for a fixed amount of monetary value and maintains, or creates the reasonable expectation of maintaining, a stable value relative to a reference asset. A payment stablecoin is distinct from a bank deposit and, once the applicable federal stablecoin framework takes effect, is expressly excluded from the definition of a security or commodity under federal law.

Digital security

A digital asset that constitutes a security under federal or state securities law — for example, a tokenized equity interest, tokenized bond, or other instrument that meets the investment contract test under applicable law. Digital securities are subject to federal and state securities regulation.

Utility token

A digital asset whose predominant purpose is consumptive rather than investment — that is, it is designed to be exchanged for access to services, software, content, or goods. A utility token that is genuinely consumptive and was not marketed as a financial investment may fall outside federal securities regulation, depending on the specific facts.

Non-fungible token (NFT)

A unique digital token recorded on a distributed ledger that is not interchangeable with other tokens of the same type on a one-for-one basis. NFTs may represent ownership of digital or physical assets. Their regulatory classification depends on how they were created, offered, and used.

Controllable electronic record

A digital record that can be subjected to exclusive control: the person in control has the power to derive substantially all the benefit from the record, the exclusive power to prevent others from deriving that benefit, and the exclusive power to transfer control to another person. This concept, now codified in Uniform Commercial Code Article 12 as adopted in multiple states, is the mechanism by which ownership and security interests in digital assets are established and transferred. Control of a digital asset is determined by possession of the private key or equivalent cryptographic credential associated with it.

Private key

The unique cryptographic element associated with the algorithm necessary to authorize a transaction involving a digital asset. Whoever controls the private key controls the associated digital asset. Loss or compromise of a private key is generally irreversible and results in permanent loss of control over the asset.

3. Supported activities

The following activities are within the scope of what PayServices Bank currently supports or is actively developing. Each activity is subject to our risk management framework, the compliance obligations described in Section 6, and applicable consumer protection requirements.

  • Digital assets as the subject of barter transactions. The PayServices Network supports barter — asset-for-asset exchange — as described in Terms of Service, Section 8. A digital asset that can be described, valued, and transferred may constitute one side of a barter transaction where both Members have agreed on the asset, quantity, and attributed value. All barter transactions involving digital assets are subject to the same compliance framework as monetary transactions, including SAR evaluation, sanctions screening, and the Travel Rule. The valuation, tax, and reporting consequences described in Terms of Service Section 8 apply.
  • Fiat transactions connected to digital asset activity. Members may use their ITAM accounts to receive fiat proceeds from digital asset sales, fund digital asset purchases on external platforms, and conduct other fiat-side transactions connected to digital asset activity. PayServices Bank does not itself operate a digital asset exchange, spot trading desk, or conversion service. The fiat leg of any such transaction is governed by these Terms and the full compliance framework.
  • Digital asset custody. PayServices Bank provides custodial services for digital assets. Custody is governed by the principles in Section 4. Where a custody arrangement is made, its specific terms — including which party holds the private key and under what conditions — are set out in a custody addendum to these Terms.
  • Reserve deposits for fiat-collateralized stablecoins. PayServices Bank holds fiat deposits serving as 1:1 reserves backing fiat-collateralized stablecoins. Reserve deposits are held in fully liquid, unencumbered form. They may not be lent, pledged, invested in anything other than high-quality liquid assets, or otherwise used for any purpose that would impair the ability to redeem the stablecoin on demand.
  • Payment stablecoin activities. PayServices Bank engages in activities relating to payment stablecoins consistent with applicable law. The federal stablecoin framework governing permitted payment stablecoin issuers, enacted in July 2025, is described in Section 5.

4. Custody principles

When PayServices Bank holds digital assets on behalf of a Member, it does so as custodian, not as owner. The following principles govern all custodial arrangements and inform the development of our custody services:

Segregation

Digital assets held in custody are kept separate from PayServices Bank’s own assets at all times. Accounting records and internal controls are designed to ensure that each custody account’s assets are identifiable, separated, and cannot be commingled with the Bank’s proprietary holdings or with the assets of other customers.

Full reserve

At all times, PayServices Bank maintains unencumbered assets in an amount not less than 100% of the digital assets held in custody. Custodied digital assets do not form part of the Bank’s lending base and may not be used to fund any Bank liability.

No rehypothecation

Unless expressly agreed otherwise in writing by the Member and permitted by applicable law, the Bank does not lend, pledge, repo, or otherwise encumber customer digital assets for any purpose. A Member’s digital assets are held exclusively for that Member’s benefit.

Private key management

Control of a digital asset is exercised through the private key associated with it. Each custody arrangement specifies, at the time of onboarding, which party holds the private key and under what conditions it may be used. The Bank maintains dual-control and segregation-of-duties procedures over private key material. Loss or compromise of a private key is potentially irreversible; the Bank maintains operational and cybersecurity controls designed to prevent this outcome, but cannot guarantee against it.

Technology risk disclosure

Digital asset custody involves risks that differ materially from traditional asset custody. These include smart contract vulnerability, blockchain network failure or reorganization, validator error, protocol-level changes or forks, private key compromise, and regulatory changes affecting the underlying network. The Bank identifies, measures, monitors, and maintains controls over these risks as part of its written risk management program, but cannot warrant against all possible outcomes.

Not insured; no guarantee of value

Digital assets held in custody are not bank deposits and are not subject to any deposit insurance scheme. PayServices Bank is not federally insured. The Bank’s custody obligation is limited to safekeeping the asset as received — it carries no obligation to preserve, maintain, or restore the market value of the asset, and it makes no representation about the future value of any digital asset.

5. Stablecoins

Not all instruments called “stablecoins” are the same, and they are not all treated the same under PayServices Bank’s policy or under applicable law.

Fiat-collateralized stablecoins

A fiat-collateralized stablecoin is backed by fiat currency or high-quality liquid assets held in reserve on a 1:1 basis, redeemable by the holder for a fixed amount of monetary value. This is the only category of stablecoin for which PayServices Bank currently holds reserve deposits. The reserve must be fully liquid and unencumbered at all times; see Section 3.

The federal statutory framework for “payment stablecoins” — a defined category of fiat-collateralized stablecoin — is law. A payment stablecoin issued by a permitted issuer under that framework is expressly excluded from the definitions of “security” and “commodity” under federal law and is subject to the full BSA/AML compliance obligations applicable to financial institutions.

Algorithmic stablecoins

An algorithmic stablecoin maintains its peg through supply-adjustment mechanisms or through collateralization by other digital assets rather than by fiat or high-quality liquid asset reserves. PayServices Bank does not hold reserve deposits for algorithmic stablecoins and does not treat them as equivalent to fiat currency or to fiat-collateralized stablecoins for any purpose under this policy. Algorithmic stablecoins fall outside the federal payment stablecoin framework and their legal treatment is governed by general securities, commodities, and banking law on a case-by-case basis.

Yield-bearing stablecoins

A stablecoin that pays interest, yield, or any similar economic return to its holder solely in connection with holding or retaining the stablecoin is not a “payment stablecoin” under the applicable federal framework. PayServices Bank does not offer yield on stablecoin balances and does not currently support yield-bearing stablecoin products on the ITAM platform.

Before transacting in a stablecoin. If you are unsure whether a specific stablecoin is fiat-collateralized, algorithmic, or yield-bearing, consult the issuer’s published reserve attestations and redemption terms. PayServices Bank cannot verify the reserve composition or redemption terms of stablecoins it does not itself issue or hold reserves for.

6. Compliance obligations

Digital asset transactions are not exempt from any obligation under the Bank Secrecy Act or its implementing regulations. Every digital asset transaction on the ITAM platform is evaluated on the same basis as every other transaction.

Transaction-by-transaction evaluation

As described in our Customer Identification Program and Source of Funds disclosures, PayServices Bank evaluates each transaction on its specific facts. For digital asset transactions, the relevant facts include the nature of the asset, the counterparty and their jurisdiction, the blockchain network involved, associated wallet addresses and their history, the transaction amount, and the pattern of transactions on the account. A digital asset transaction that meets any of the three SAR triggers under applicable federal law will generate a mandatory SAR evaluation and, if applicable, a SAR filing. A high balance or large transaction size is not, by itself, a SAR trigger.

Sanctions

OFAC’s sanctions programs apply to digital asset transactions in the same manner as to fiat transactions. This includes the designation of specific wallet addresses as blocked property under various sanctions programs. A transaction involving a designated wallet address or a sanctions-listed counterparty is subject to blocking, rejection, and reporting obligations regardless of whether the asset is denominated in fiat or digital form. This applies to all digital assets without regard to the nature of the issuer, including instruments issued by foreign central banks or other governmental entities. The jurisdiction-specific sanctions analysis described in our Source of Funds disclosure and our Customer Identification Program applies fully to digital asset transactions.

Travel Rule

Financial institutions are required to transmit certain information about the originator and beneficiary of qualifying funds transfers. The applicable federal requirement has been interpreted to apply to transfers of convertible virtual currency above the applicable threshold. Where PayServices Bank facilitates a qualifying digital asset transfer, it transmits the required originator and beneficiary information to the extent technically feasible and as required by applicable law and regulatory guidance.

BSA program requirement

PayServices Bank’s written BSA/AML program covers digital asset transactions and digital asset custody activities on the same basis as all other activities. The program includes procedures for identifying, measuring, monitoring, and controlling the risks specific to digital assets, including the operational, cybersecurity, and financial crime risks described elsewhere in this policy.

Tax reporting

Virtual currency and other digital assets are treated as property for U.S. federal income tax purposes. Gains and losses on digital asset transactions are generally recognized as capital gains or losses or as ordinary income, depending on the circumstances and holding period. Where required by applicable law, PayServices Bank issues information returns and provides the corresponding Member statements. Members are responsible for the proper reporting of their own digital asset transactions. PayServices Bank is not a tax adviser and nothing in this policy constitutes tax advice.

7. Unsupported activities

The following activities are not supported on the ITAM platform:

  • Privacy coins and mixing services. Digital assets specifically designed to obfuscate transaction history, counterparty identity, or wallet addresses, and services that mix or tumble digital assets to obscure their origin, present compliance risks that cannot be managed within our BSA framework. Transactions involving such assets or services will be declined or reversed.
  • Unregistered digital securities. Transactions in digital assets that constitute unregistered securities under applicable law, in the absence of an applicable exemption, are not supported.
  • Transactions with sanctioned parties. Transactions in any digital asset where a party to the transaction, the issuer of the asset, or a controlling person of the issuer is subject to applicable sanctions are not supported and will be blocked as required by law.
  • Algorithmic stablecoins as reserve assets. Algorithmic stablecoins are not treated as reserve assets, monetary collateral, or fiat-equivalent for any purpose under this policy.
  • Staking, lending, or yield on custodied assets. PayServices Bank does not currently offer staking, lending, or yield-generating services in connection with custodied digital assets.
  • NFTs as payment instruments. Non-fungible tokens may be the subject of barter transactions under Terms of Service Section 8, but they are not treated as payment instruments, monetary instruments, or as substitutes for fiat currency.

8. Evolving law

Digital asset regulation is developing at an accelerating pace. As of the date of this policy, significant regulatory and legislative changes have taken place over the preceding eighteen months, and further changes — including implementing regulations for the first federal stablecoin framework, potential federal market structure legislation for non-stablecoin digital assets, and additional agency guidance on custody and tokenization — are expected.

This policy reflects the law and PayServices Bank’s practices as of May 5, 2026. It will be updated as material legal or operational changes occur. Material updates will be communicated to Members in-app and reflected in the “Last updated” date above. The version of this policy in effect at the time of any transaction governs that transaction for the purposes of these disclosures.

Members with questions about a specific digital asset, transaction type, or aspect of this policy that is not addressed here may contact us at the address below before transacting. We will make reasonable efforts to respond based on current law and our current practices, while noting that we do not provide legal, tax, or investment advice.

9. Contact us

PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States

info@payservices.com

Related policies: Terms of Service · Customer Identification Program · Source of Funds · Beneficial Ownership

1. Overview

PayServices Bank is a state-chartered banking corporation organized under the laws of Idaho. It is not federally insured — deposits at PayServices Bank are not covered by any federal deposit insurance program.

This policy governs how PayServices Bank treats digital assets — including cryptocurrencies, tokens, stablecoins, and other instruments recorded on distributed ledgers — in connection with accounts maintained on the ITAM platform. It states what we support today, how we hold assets, what compliance obligations apply, and what we do not permit. It will be updated as the law develops.

Digital assets are not bank deposits and carry no guarantee of value. Nothing in this policy, and nothing in the operation of any digital asset feature on ITAM, constitutes a guarantee, warranty, or assurance of the value of any digital asset. The value of digital assets can be volatile and can decline to zero.

2. Definitions

The following terms are used throughout this policy. Where a term also has a definition in federal statute or other binding authority, that definition governs in the event of any conflict.

Digital asset

Any digital representation of value that is recorded on a cryptographically secured distributed ledger. The term encompasses virtual currency, payment stablecoins, digital securities, utility tokens, and non-fungible tokens. A digital asset is intangible personal property; it is not legal tender and is not a bank deposit.

Virtual currency

A digital asset that functions as a medium of exchange, unit of account, or store of value but is not recognized as legal tender by any government. Virtual currency is treated as property for U.S. federal income tax purposes. The most common examples are Bitcoin and Ether.

Payment stablecoin

A digital asset used or designed to be used as a means of payment or settlement, the issuer of which is obligated to redeem it for a fixed amount of monetary value and maintains, or creates the reasonable expectation of maintaining, a stable value relative to a reference asset. A payment stablecoin is distinct from a bank deposit and, once the applicable federal stablecoin framework takes effect, is expressly excluded from the definition of a security or commodity under federal law.

Digital security

A digital asset that constitutes a security under federal or state securities law — for example, a tokenized equity interest, tokenized bond, or other instrument that meets the investment contract test under applicable law. Digital securities are subject to federal and state securities regulation.

Utility token

A digital asset whose predominant purpose is consumptive rather than investment — that is, it is designed to be exchanged for access to services, software, content, or goods. A utility token that is genuinely consumptive and was not marketed as a financial investment may fall outside federal securities regulation, depending on the specific facts.

Non-fungible token (NFT)

A unique digital token recorded on a distributed ledger that is not interchangeable with other tokens of the same type on a one-for-one basis. NFTs may represent ownership of digital or physical assets. Their regulatory classification depends on how they were created, offered, and used.

Controllable electronic record

A digital record that can be subjected to exclusive control: the person in control has the power to derive substantially all the benefit from the record, the exclusive power to prevent others from deriving that benefit, and the exclusive power to transfer control to another person. This concept, now codified in Uniform Commercial Code Article 12 as adopted in multiple states, is the mechanism by which ownership and security interests in digital assets are established and transferred. Control of a digital asset is determined by possession of the private key or equivalent cryptographic credential associated with it.

Private key

The unique cryptographic element associated with the algorithm necessary to authorize a transaction involving a digital asset. Whoever controls the private key controls the associated digital asset. Loss or compromise of a private key is generally irreversible and results in permanent loss of control over the asset.

3. Supported activities

The following activities are within the scope of what PayServices Bank currently supports or is actively developing. Each activity is subject to our risk management framework, the compliance obligations described in Section 6, and applicable consumer protection requirements.

  • Digital assets as the subject of barter transactions. The PayServices Network supports barter — asset-for-asset exchange — as described in Terms of Service, Section 8. A digital asset that can be described, valued, and transferred may constitute one side of a barter transaction where both Members have agreed on the asset, quantity, and attributed value. All barter transactions involving digital assets are subject to the same compliance framework as monetary transactions, including SAR evaluation, sanctions screening, and the Travel Rule. The valuation, tax, and reporting consequences described in Terms of Service Section 8 apply.
  • Fiat transactions connected to digital asset activity. Members may use their ITAM accounts to receive fiat proceeds from digital asset sales, fund digital asset purchases on external platforms, and conduct other fiat-side transactions connected to digital asset activity. PayServices Bank does not itself operate a digital asset exchange, spot trading desk, or conversion service. The fiat leg of any such transaction is governed by these Terms and the full compliance framework.
  • Digital asset custody. PayServices Bank provides custodial services for digital assets. Custody is governed by the principles in Section 4. Where a custody arrangement is made, its specific terms — including which party holds the private key and under what conditions — are set out in a custody addendum to these Terms.
  • Reserve deposits for fiat-collateralized stablecoins. PayServices Bank holds fiat deposits serving as 1:1 reserves backing fiat-collateralized stablecoins. Reserve deposits are held in fully liquid, unencumbered form. They may not be lent, pledged, invested in anything other than high-quality liquid assets, or otherwise used for any purpose that would impair the ability to redeem the stablecoin on demand.
  • Payment stablecoin activities. PayServices Bank engages in activities relating to payment stablecoins consistent with applicable law. The federal stablecoin framework governing permitted payment stablecoin issuers, enacted in July 2025, is described in Section 5.

4. Custody principles

When PayServices Bank holds digital assets on behalf of a Member, it does so as custodian, not as owner. The following principles govern all custodial arrangements and inform the development of our custody services:

Segregation

Digital assets held in custody are kept separate from PayServices Bank’s own assets at all times. Accounting records and internal controls are designed to ensure that each custody account’s assets are identifiable, separated, and cannot be commingled with the Bank’s proprietary holdings or with the assets of other customers.

Full reserve

At all times, PayServices Bank maintains unencumbered assets in an amount not less than 100% of the digital assets held in custody. Custodied digital assets do not form part of the Bank’s lending base and may not be used to fund any Bank liability.

No rehypothecation

Unless expressly agreed otherwise in writing by the Member and permitted by applicable law, the Bank does not lend, pledge, repo, or otherwise encumber customer digital assets for any purpose. A Member’s digital assets are held exclusively for that Member’s benefit.

Private key management

Control of a digital asset is exercised through the private key associated with it. Each custody arrangement specifies, at the time of onboarding, which party holds the private key and under what conditions it may be used. The Bank maintains dual-control and segregation-of-duties procedures over private key material. Loss or compromise of a private key is potentially irreversible; the Bank maintains operational and cybersecurity controls designed to prevent this outcome, but cannot guarantee against it.

Technology risk disclosure

Digital asset custody involves risks that differ materially from traditional asset custody. These include smart contract vulnerability, blockchain network failure or reorganization, validator error, protocol-level changes or forks, private key compromise, and regulatory changes affecting the underlying network. The Bank identifies, measures, monitors, and maintains controls over these risks as part of its written risk management program, but cannot warrant against all possible outcomes.

Not insured; no guarantee of value

Digital assets held in custody are not bank deposits and are not subject to any deposit insurance scheme. PayServices Bank is not federally insured. The Bank’s custody obligation is limited to safekeeping the asset as received — it carries no obligation to preserve, maintain, or restore the market value of the asset, and it makes no representation about the future value of any digital asset.

5. Stablecoins

Not all instruments called “stablecoins” are the same, and they are not all treated the same under PayServices Bank’s policy or under applicable law.

Fiat-collateralized stablecoins

A fiat-collateralized stablecoin is backed by fiat currency or high-quality liquid assets held in reserve on a 1:1 basis, redeemable by the holder for a fixed amount of monetary value. This is the only category of stablecoin for which PayServices Bank currently holds reserve deposits. The reserve must be fully liquid and unencumbered at all times; see Section 3.

The federal statutory framework for “payment stablecoins” — a defined category of fiat-collateralized stablecoin — is law. A payment stablecoin issued by a permitted issuer under that framework is expressly excluded from the definitions of “security” and “commodity” under federal law and is subject to the full BSA/AML compliance obligations applicable to financial institutions.

Algorithmic stablecoins

An algorithmic stablecoin maintains its peg through supply-adjustment mechanisms or through collateralization by other digital assets rather than by fiat or high-quality liquid asset reserves. PayServices Bank does not hold reserve deposits for algorithmic stablecoins and does not treat them as equivalent to fiat currency or to fiat-collateralized stablecoins for any purpose under this policy. Algorithmic stablecoins fall outside the federal payment stablecoin framework and their legal treatment is governed by general securities, commodities, and banking law on a case-by-case basis.

Yield-bearing stablecoins

A stablecoin that pays interest, yield, or any similar economic return to its holder solely in connection with holding or retaining the stablecoin is not a “payment stablecoin” under the applicable federal framework. PayServices Bank does not offer yield on stablecoin balances and does not currently support yield-bearing stablecoin products on the ITAM platform.

Before transacting in a stablecoin. If you are unsure whether a specific stablecoin is fiat-collateralized, algorithmic, or yield-bearing, consult the issuer’s published reserve attestations and redemption terms. PayServices Bank cannot verify the reserve composition or redemption terms of stablecoins it does not itself issue or hold reserves for.

6. Compliance obligations

Digital asset transactions are not exempt from any obligation under the Bank Secrecy Act or its implementing regulations. Every digital asset transaction on the ITAM platform is evaluated on the same basis as every other transaction.

Transaction-by-transaction evaluation

As described in our Customer Identification Program and Source of Funds disclosures, PayServices Bank evaluates each transaction on its specific facts. For digital asset transactions, the relevant facts include the nature of the asset, the counterparty and their jurisdiction, the blockchain network involved, associated wallet addresses and their history, the transaction amount, and the pattern of transactions on the account. A digital asset transaction that meets any of the three SAR triggers under applicable federal law will generate a mandatory SAR evaluation and, if applicable, a SAR filing. A high balance or large transaction size is not, by itself, a SAR trigger.

Sanctions

OFAC’s sanctions programs apply to digital asset transactions in the same manner as to fiat transactions. This includes the designation of specific wallet addresses as blocked property under various sanctions programs. A transaction involving a designated wallet address or a sanctions-listed counterparty is subject to blocking, rejection, and reporting obligations regardless of whether the asset is denominated in fiat or digital form. This applies to all digital assets without regard to the nature of the issuer, including instruments issued by foreign central banks or other governmental entities. The jurisdiction-specific sanctions analysis described in our Source of Funds disclosure and our Customer Identification Program applies fully to digital asset transactions.

Travel Rule

Financial institutions are required to transmit certain information about the originator and beneficiary of qualifying funds transfers. The applicable federal requirement has been interpreted to apply to transfers of convertible virtual currency above the applicable threshold. Where PayServices Bank facilitates a qualifying digital asset transfer, it transmits the required originator and beneficiary information to the extent technically feasible and as required by applicable law and regulatory guidance.

BSA program requirement

PayServices Bank’s written BSA/AML program covers digital asset transactions and digital asset custody activities on the same basis as all other activities. The program includes procedures for identifying, measuring, monitoring, and controlling the risks specific to digital assets, including the operational, cybersecurity, and financial crime risks described elsewhere in this policy.

Tax reporting

Virtual currency and other digital assets are treated as property for U.S. federal income tax purposes. Gains and losses on digital asset transactions are generally recognized as capital gains or losses or as ordinary income, depending on the circumstances and holding period. Where required by applicable law, PayServices Bank issues information returns and provides the corresponding Member statements. Members are responsible for the proper reporting of their own digital asset transactions. PayServices Bank is not a tax adviser and nothing in this policy constitutes tax advice.

7. Unsupported activities

The following activities are not supported on the ITAM platform:

  • Privacy coins and mixing services. Digital assets specifically designed to obfuscate transaction history, counterparty identity, or wallet addresses, and services that mix or tumble digital assets to obscure their origin, present compliance risks that cannot be managed within our BSA framework. Transactions involving such assets or services will be declined or reversed.
  • Unregistered digital securities. Transactions in digital assets that constitute unregistered securities under applicable law, in the absence of an applicable exemption, are not supported.
  • Transactions with sanctioned parties. Transactions in any digital asset where a party to the transaction, the issuer of the asset, or a controlling person of the issuer is subject to applicable sanctions are not supported and will be blocked as required by law.
  • Algorithmic stablecoins as reserve assets. Algorithmic stablecoins are not treated as reserve assets, monetary collateral, or fiat-equivalent for any purpose under this policy.
  • Staking, lending, or yield on custodied assets. PayServices Bank does not currently offer staking, lending, or yield-generating services in connection with custodied digital assets.
  • NFTs as payment instruments. Non-fungible tokens may be the subject of barter transactions under Terms of Service Section 8, but they are not treated as payment instruments, monetary instruments, or as substitutes for fiat currency.

8. Evolving law

Digital asset regulation is developing at an accelerating pace. As of the date of this policy, significant regulatory and legislative changes have taken place over the preceding eighteen months, and further changes — including implementing regulations for the first federal stablecoin framework, potential federal market structure legislation for non-stablecoin digital assets, and additional agency guidance on custody and tokenization — are expected.

This policy reflects the law and PayServices Bank’s practices as of May 5, 2026. It will be updated as material legal or operational changes occur. Material updates will be communicated to Members in-app and reflected in the “Last updated” date above. The version of this policy in effect at the time of any transaction governs that transaction for the purposes of these disclosures.

Members with questions about a specific digital asset, transaction type, or aspect of this policy that is not addressed here may contact us at the address below before transacting. We will make reasonable efforts to respond based on current law and our current practices, while noting that we do not provide legal, tax, or investment advice.

9. Contact us

PayServices Bank — Compliance
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States

info@payservices.com

Related policies: Terms of Service · Customer Identification Program · Source of Funds · Beneficial Ownership