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RISK DISCLOSURE & NO-ADVICE NOTICE

Version
1.1
Effective Date
28.10.2026
Last Updated
28.10.2026
IMPORTANT NOTICE – PLEASE READ CAREFULLY

This Risk Disclosure & No-Advice Notice is an Associated Document of the Platform's Terms of Use and must be read in conjunction with the Privacy Policy, the Terms of Use, and all other Associated Documents, each of which is incorporated by reference. Defined terms used herein have the meanings ascribed to them in the Terms of Use unless otherwise stated. By accessing or continuing to use the Platform, you acknowledge that you have read and understood this Risk Disclosure & No-Advice Notice. If you do not agree to this Risk Disclosure & No-Advice Notice, you must cease using the Platform.

1. INTRODUCTION AND SCOPE

1.1.This Risk Disclosure & No-Advice Notice ("Notice") is issued by Better Tomorrow Group LTD, a company duly incorporated and registered under the laws of the British Virgin Islands ("BVI") (hereinafter referred to as the "Company", "we", "us", or "our"), in connection with the operation of the online platform available at obmify.com and any associated mobile applications (collectively, the "Platform").

1.2. The Platform operates as an aggregator and information service that publishes, lists, and displays third-party cryptocurrency exchange service providers ("Listed Exchangers" or "Third-Party Providers"). The Platform does not directly conduct, intermediate, or facilitate the exchange, transfer, custody, or any other transaction involving virtual assets (crypto-assets) with Users. The Company does not act as a virtual asset service provider ("VASP"), crypto asset service provider ("CASP"), crypto-asset exchange, wallet provider, custodian, broker, dealer, investment adviser, or financial intermediary of any kind.

1.3. By accessing or using the Platform, you ("User", "you") acknowledge that you have read, understood, and accepted the terms of this Notice. This Notice forms an integral part of the Platform's Terms of Use and should be read in conjunction therewith.

1.4. This Notice does not constitute an exhaustive statement of all risks associated with crypto-assets. Users must conduct their own independent research and assessment of risks before engaging in any transaction with any Listed Exchanger.

2. NATURE OF THE PLATFORM AND ITS SERVICES

2.1. The Platform aggregates publicly available and voluntarily submitted information about crypto-asset exchange services offered by independent Third-Party Providers. The Platform enables users to compare exchange rates, review user-generated ratings and feedback, and access links directing them to the websites and services of Listed Exchangers.

2.2. The Company does not:

  • (a) execute, process, or settle any exchange, purchase, sale, or transfer of crypto-assets or fiat currencies;
  • (b) hold, control, or have custody of any User's funds, crypto-assets, private keys, or wallets;
  • (c) collect or transmit payments or crypto-assets between Users and Listed Exchangers;
  • (d) act as a party to any transaction between Users and Listed Exchangers;
  • (e) provide investment, financial, tax, or legal advice;
  • (f) issue, offer for sale, or admit to trading any crypto-assets;
  • (g) offer financial services relating to the issuance, offer, or sale of virtual assets within the meaning of Section 2(1) of the Virtual Assets Service Providers Act, 2022 (BVI); or
  • (h) provide services that would require authorisation as a crypto-asset service provider ("CASP") under Regulation (EU) 2023/1114 (Markets in Crypto-Assets Regulation — "MiCA").

2.3. The listing or display of any Third-Party Provider on the Platform does not constitute an endorsement, recommendation, certification, warranty, or guarantee by the Company regarding the reliability, legality, licensing status, solvency, or quality of services of such Third-Party Provider.

3. NO-ADVICE DISCLAIMER

3.1. Nothing on the Platform — including, without limitation, exchange rates, user reviews, rankings, comparison data, blog articles, market commentary, or any other information or content — constitutes or should be construed as financial advice, investment advice, trading advice, or any recommendation to buy, sell, hold, exchange, or otherwise deal in any crypto-asset, virtual asset, digital token, cryptocurrency, fiat currency, or any other financial instrument.

3.2. The Platform does not provide legal, tax, regulatory, or accounting advice. Each User is solely responsible for determining and understanding the legal, tax, and regulatory implications of any transaction they undertake with any Listed Exchanger, including, but not limited to, obligations under the laws of their country of residence, domicile, or citizenship.

3.3. The information displayed on the Platform is provided on a general, non-personalised basis. The Platform does not assess, evaluate, or take into account any User's personal financial circumstances, risk tolerance, investment objectives, experience, or knowledge. Users should seek independent professional advice from qualified advisers before engaging in any crypto-asset related transaction.

3.4. Unlike regulated financial services entities, the Platform does not perform suitability or appropriateness assessments of crypto-asset products for Users, nor is it required to do so.

3.5. All content on the Platform is provided for informational purposes only. While the Company endeavours to ensure the accuracy and timeliness of the information published, no representation or warranty, express or implied, is made as to the accuracy, completeness, reliability, suitability, or availability of any information, data, exchange rates, or content on the Platform.

4. GENERAL RISKS OF CRYPTO-ASSETS

USERS SHOULD BE AWARE THAT CRYPTO-ASSETS ARE SUBJECT TO SIGNIFICANT AND INHERENT RISKS. THE RISKS DESCRIBED IN THIS SECTION 4 ARE NOT EXHAUSTIVE. USERS SHOULD CAREFULLY CONSIDER WHETHER ENGAGING WITH CRYPTO-ASSETS IS APPROPRIATE FOR THEM.

4.1. Risk of Total Loss of Invested Capital

Crypto-assets are highly speculative. You may lose all the money you invest. The European Supervisory Authorities (EBA, ESMA, and EIOPA — the "ESAs") have warned consumers that many crypto-assets are highly risky and speculative, and that consumers face the very real possibility of losing all their invested money if they buy these assets.

4.2. Extreme Price Volatility

Many crypto-assets are subject to sudden and extreme price movements. Prices can fall and rise quickly over short periods, including overnight. The value of crypto-assets relies largely on consumer demand, and there may be no backing assets or other tangible value. This extreme volatility means that many crypto-assets may be unsuitable as a store of value or as a means of exchange or payment.

4.3. Absence of Consumer Protection

The majority of crypto-assets and the selling of products or services in relation to crypto-assets have historically been unregulated or fall outside the scope of traditional consumer and investor protection frameworks. While the EU's MiCA Regulation introduces protections, MiCA's safeguards are less extensive than those for traditional investment products:

  • (a) No Investor Compensation Scheme: Crypto-assets are not covered by an investor compensation scheme of the type required for traditional investment services under MiFID II (Directive 2014/65/EU). If a crypto-asset service provider is unable to return your crypto-assets, there is no "safety net".
  • (b) No Periodic Reporting Obligation: Crypto-asset service providers have no obligation to report to clients, on a periodical basis, the crypto-assets they hold on clients' behalf and their updated or current value.
  • (c) Transitional Arrangements: Most EU Member States have opted to allow existing national crypto-asset service providers to operate without a MiCA licence during a transitional period of up to 18 months.
4.4. Fraud, Scams, and Malicious Activities

Numerous fake crypto-assets and scams exist whose sole purpose is to deprive individuals of their money using techniques such as phishing. Users should be alert to the risks of misleading advertisements, including via social media and influencers, and should be particularly wary of promised fast or high returns, especially those that look too good to be true.

4.5. Market Manipulation and Lack of Price Transparency

How crypto-asset prices are determined and how transactions are executed at exchanges is often not transparent. The holding of certain crypto-assets is highly concentrated, which may impact prices or liquidity. Users may therefore not receive a fair price or treatment when buying or selling crypto-assets or may be unable to sell their crypto-assets as quickly as they wish. Cases of market manipulation have been reported on multiple occasions.

4.6. Hacks, Operational Risks, and Security Issues

Distributed ledger technology underpinning crypto-assets bears specific risks. Several issuers and service providers for crypto-assets, including crypto exchanges and wallet providers, have experienced cyber-attacks and severe operational problems. Many consumers have lost their crypto-assets or suffered losses due to such hacks and disruptions or because they have lost the private keys providing access to their assets.

4.7. Product Complexity

Some products providing exposure to crypto-assets are very complex, sometimes with features that can increase the magnitude of losses in case of adverse price movements. These products, given their complexity, are not suitable for many consumers.

4.8. Technology Risks

Crypto-assets are prone to novel risks due to their underlying technology. These include, but are not limited to, risks associated with distributed ledger technology, smart contract vulnerabilities, protocol changes (forks), consensus mechanism failures, interoperability issues, and the potential obsolescence of specific blockchain networks.

4.9. Regulatory Risk

The legal and regulatory status of crypto-assets varies significantly across jurisdictions and is subject to rapid and unpredictable change. Actions by governmental authorities, including the introduction of new legislation, the amendment of existing laws, or the enforcement of prohibitions, may adversely affect the use, transfer, exchange, and value of crypto-assets.

4.10. Liquidity Risk

Crypto-asset markets may have limited liquidity, particularly for lesser-known tokens or during periods of market stress. Users may not be able to sell or exchange their crypto-assets at a desired price or at all.

4.11. Irreversibility of Transactions

Transactions involving crypto-assets may be irreversible. Once a transaction has been broadcast to and confirmed by the relevant blockchain network, it generally cannot be undone or reversed. Errors in wallet addresses, amounts, or network selection may result in permanent loss of funds.

5. SPECIFIC NOTICE FOR USERS IN THE EUROPEAN UNION AND EUROPEAN ECONOMIC AREA

5.1. This Section is of particular relevance to Users who are residents of or located in the European Union ("EU") or European Economic Area ("EEA"), or who intend to interact with Listed Exchangers that are established in the EU/EEA.

5.2. Joint ESAs Warning on Crypto-Assets (2022)

The European Supervisory Authorities (EBA, ESMA, and EIOPA) have issued a joint warning (ESA 2022 15) reminding consumers that:

  • Many crypto-assets are highly risky and speculative and are not suited for most retail consumers as an investment or as a means of payment or exchange.
  • Consumers should be aware of the lack of recourse or protection available to them, as crypto-assets and related products and services typically fall outside existing protection under current EU financial services rules.

The ESAs urge consumers to ask themselves the following questions before acquiring crypto-assets:

  • Can you afford to lose all the money you invest?
  • Are you ready to take on high risks to earn the advertised returns?
  • Do you understand the features of the crypto-asset or related products and services?
  • Are the firms/parties you are dealing with reputable?
  • Are the firms/parties you are dealing with blacklisted by the relevant national authorities?
  • Are you able to protect effectively the devices you use for buying, storing, or transferring crypto-assets, including your private keys?
5.3. ESMA Warning on Crypto-Assets (2025)

ESMA has issued a further warning (ESMA35-1872330276-1971) emphasising that:

  • Despite the application of MiCA (Regulation (EU) 2023/1114), the inherent risks of investing in crypto-assets remain.
  • Many crypto-assets are highly speculative and volatile, with prices subject to sudden and extreme fluctuations.
  • MiCA does not provide the same level of protection as those available for traditional investment products.
  • Clients should be very cautious when engaging with non-EU firms. Crypto-asset investments or related services offered by non-EU firms entail even lower safeguards, heightened risks of fraud and scams, and limited recourse (if any) in the event of disputes or claims against the provider.
  • Users are not protected by MiCA when crypto-asset services are provided by firms not authorised in the EU.
5.4. MiCA and Authorisation

Under MiCA, crypto-asset service providers operating in the EU must be duly authorised by the competent national authority of an EU Member State. The Company is not authorised, registered, or licensed as a CASP under MiCA and does not provide crypto-asset services within the meaning of MiCA. Users are strongly advised to verify independently that any Listed Exchanger with which they choose to transact holds the appropriate authorisation under MiCA or under the relevant national law of an EU Member State.

5.5. Stablecoin Regulatory Changes

Users should be aware that, following the full application of MiCA, certain stablecoins (including but not limited to USDT) were delisted or restricted on EU-regulated platforms due to non-compliance with MiCA's requirements for e-money tokens and asset-referenced tokens. Users should verify the regulatory status of stablecoins before engaging in transactions.

6. SPECIFIC NOTICE FOR USERS IN UKRAINE

6.1. This Section is of particular relevance to Users who are residents of or located in Ukraine, or who interact with Listed Exchangers operating in Ukraine.

6.2. Law of Ukraine "On Virtual Assets" (No. 2074-IX)

The Law of Ukraine "On Virtual Assets" No. 2074-IX dated 17 February 2022 (the "Ukrainian VA Law"), which has been adopted but has not yet entered into force, could establish a legal framework for the definition and legal status of virtual assets in Ukraine. Under the Ukrainian VA Law:

  • Virtual assets are defined as intangible benefits expressed as a dataset in electronic form that have certain value.
  • Virtual assets are recognised as objects of civil rights, and ownership rights to them are legally protectable.
  • Virtual assets cannot be used as an official means of payment in Ukraine.
  • Service providers involved in the circulation of virtual assets (e.g., exchanges, exchangers, wallet providers) are subject to regulatory requirements, including registration with the National Securities and Stock Market Commission ("NSSMC") and compliance with anti-money laundering and financial monitoring rules in accordance with FATF recommendations.
6.3. Status of the Platform in Ukraine

The Company is not registered with the NSSMC or any other Ukrainian regulatory authority as a virtual asset service provider. The Platform does not provide exchange services in Ukraine and does not collect or transmit funds or virtual assets. It merely aggregates and publishes publicly available information about third-party exchange services, some of which may operate in Ukraine.

6.4. Evolving Regulatory Landscape

Ukrainian legislation on virtual assets is rapidly developing. On 3 September 2025, the Verkhovna Rada adopted draft law No. 10225-d in first reading, proposing to rename the Ukrainian VA Law to "On Virtual Asset Markets" and to introduce significant amendments, including stricter licensing requirements for VASPs, updated definitions, and closer alignment with EU standards (MiCA). Users should independently monitor changes in Ukrainian legislation and ensure compliance with all applicable laws.

6.5. Tax Obligations in Ukraine

Users in Ukraine who derive income from transactions with virtual assets may be subject to taxation. Users are solely responsible for determining and fulfilling their tax obligations under the Tax Code of Ukraine and any implementing regulations.

7. SPECIFIC NOTICE FOR THE BVI REGULATORY FRAMEWORK
7.1. BVI Virtual Assets Service Providers Act, 2022

The Virtual Assets Service Providers Act, 2022 (No. 17 of 2022) ("BVI VASP Act") regulates the registration and supervision of VASPs operating in or from within the BVI. Under the BVI VASP Act:

  • "VASP" means a virtual asset service provider registered under the Act to conduct activities such as exchange between virtual assets and fiat currencies, exchange between forms of virtual assets, transfer of virtual assets, safekeeping or administration of virtual assets, or participation in financial services related to an issuer's offer or sale of a virtual asset (Section 2(1)).
  • Section 5(1) prohibits any person from carrying on in or from within the BVI the business of providing a virtual asset service without being registered by the Financial Services Commission ("FSC").
7.2. Exclusions Under Section 2(2) of the BVI VASP Act

The BVI VASP Act explicitly provides that certain activities do not qualify as VASP activities, including:

  • (a) providing ancillary infrastructure to allow another person to offer a service (e.g., cloud data storage providers);
  • (b) providing services as a software developer or provider of unhosted wallets whose function is only to develop or sell software or hardware;
  • (c) solely creating or selling a software application or virtual asset platform;
  • (d) providing ancillary services or products to a virtual asset network;
  • (e) solely engaging in the operation of a virtual asset network without engaging or facilitating VASP activities on behalf of customers.
7.3. Platform's Position Under BVI Law

The Company submits that the Platform operates as an information aggregation service that publishes information about Third-Party Providers and does not itself engage in or facilitate exchange, transfer, custody, or other virtual asset transactions on behalf of Users. The Company does not come with Users into custody, control, power, or possession of any money or virtual asset during the course of its business. Accordingly, the Company's position is that it falls within the scope of Section 2(2)(c) of the BVI VASP Act, which excludes persons who solely create or sell a software application or virtual asset platform from the definition of VASP. However, users should not interpret this as a guarantee of the Platform's regulatory status. The interpretation and application of the BVI VASP Act is subject to the authority of the BVI Financial Services Commission.

7.4. Anti-Money Laundering (AML) Considerations

The BVI maintains a comprehensive AML/CFT framework, including the Anti-Money Laundering Regulations (Revised Edition 2020), as amended and the Anti-Money Laundering and Terrorist Financing Code of Practice, as amended. The Company screens Listed Exchangers against applicable sanctions lists [at onboarding and periodically] and requires Listed Exchangers to maintain the AML/KYC procedures required by the law applicable to them. The Company does not verify the adequacy or effectiveness of such procedures. The Company's review is limited to publicly available information and does not constitute a comprehensive audit, legal due diligence, or regulatory compliance assessment. Some Listed Exchangers may operate in jurisdictions that do not impose licensing or registration requirements on crypto-asset exchange providers. The listing of an Exchanger on the Platform does not represent a warranty, certification, or endorsement by the Company of such Exchanger's regulatory compliance, solvency, or reliability. The Company does not perform customer due diligence on Users, as it does not enter into transactional relationships with Users.

7.5. BVI Data Protection

The Data Protection Act, 2021 (No. 3 of 2021) ("BVI DPA") regulates the processing of personal data by public and private bodies in the BVI. The Company processes any personal data of Users in accordance with the principles set forth in the BVI DPA, including the General Principle (Section 7), the Notice and Choice Principle (Section 8), the Security Principle (Section 10), and the Retention Principle (Section 11). For details on how the Company processes personal data, Users should refer to the Platform's Privacy Policy.

8. THIRD-PARTY RISKS

8.1. Independence of Listed Exchangers. Each Listed Exchanger is an independent entity with no corporate, partnership, or joint venture relationship with the Company, unless expressly stated otherwise. The Company has no control over and accepts no responsibility for the actions, omissions, errors, policies, terms of service, fees, exchange rates, or conduct of any Listed Exchanger.

8.2. No Guarantee of Service Quality. The Company does not guarantee the timeliness, completeness, accuracy, or reliability of any exchange rates, terms, conditions, or other information displayed on the Platform in respect of any Listed Exchanger. Exchange rates and conditions displayed on the Platform may differ from actual rates and conditions at the time a User initiates a transaction with a Listed Exchanger.

8.3. No Guarantee of Regulatory Status. While the Company endeavours to list only exchangers that meet certain basic AML standards, the Company does not guarantee that any Listed Exchanger:

  • (a) is duly licensed, registered, or authorised in any jurisdiction;
  • (b) complies with all applicable laws and regulations, including national or international AML laws and regulations, MiCA or any other national or international regulatory framework;
  • (c) is solvent or financially stable;
  • (d) will honour its obligations to Users.

8.4. User's Responsibility. Users are solely responsible for conducting their own due diligence on any Listed Exchanger before engaging in any transaction. Users should verify, at a minimum:

  • The regulatory/licensing status of the Listed Exchanger in the relevant jurisdiction;
  • The Listed Exchanger's compliance with AML/KYC requirements;
  • The Listed Exchanger's terms of service, privacy policy, and complaint handling procedures;
  • Whether the Listed Exchanger is authorised to provide crypto-asset services in the EU (for EU/EEA-based Users).
9. LIMITATION OF LIABILITY

9.1. To the maximum extent permitted under the laws of the British Virgin Islands, the Company, its parent undertakings, subsidiaries, affiliates, holding companies, directors, officers, shareholders, employees, agents, licensors, suppliers, and contractors (collectively, the "Company Parties") shall, under no circumstances whatsoever and under no theory of liability — whether in contract, tort (including negligence and gross negligence), equity, statute, strict liability, unjust enrichment, or otherwise — be liable to any User or any third party for any loss, damage, harm, cost, expense, or claim of any nature or description, whether direct or indirect, foreseen or unforeseen, arising out of or in connection with:

  • (a) your access to, use of, or inability to access or use the Platform, the Applications, or any Content at any time or for any reason;
  • (b) any transaction entered into with, or failure of any transaction with, any Listed Exchanger, including failed transfers, delayed settlements, or erroneous exchanges;
  • (c) any loss, theft, freezing, confiscation, or destruction of Crypto-Assets or fiat currency, howsoever arising;
  • (d) any fraud, scam, misrepresentation, insolvency, default, or other misconduct of any Listed Exchanger;
  • (e) any reliance upon exchange rate data, pricing information, Content, reviews, ratings, or any other information displayed on or through the Platform;
  • (f) any interruption, suspension, withdrawal, termination, or failure of the Platform or Applications for any reason;
  • (g) any unauthorised access to, interception, alteration, disclosure, or destruction of any data transmitted through or stored in connection with the Platform;
  • (h) any regulatory, enforcement, or supervisory action affecting Crypto-Assets, Listed Exchangers, or the Company in any jurisdiction;
  • (i) any action taken by the Company in the exercise of its rights under Section 13 (Sanctions and Prohibited Jurisdictions) or Section 14 (Anti-Money Laundering) of the Platform Terms of Use;
  • (j) any Force Majeure Event as defined in Section 20 of the Platform Terms of Use; or
  • (k) any other matter arising out of or in connection with the Platform Terms of Use, the Platform, or any Associated Document.

For this purpose, the Company contracts on its own behalf and as agent and trustee for each of the Company Parties, each of which shall to this extent be treated as a party to the Platform Terms of Use solely for the purpose of enforcing clause 17.3 of the Platform Terms of Use, and each of which may ratify this arrangement by relying on it in any proceedings; for the avoidance of doubt, the clause 17.3 of the Platform Terms of Use creates no obligation, duty, or liability of any Company Party towards the User or the Company.

For more details on the company's limitations of liability and other specific provisions, please refer to Section 17 of the Platform Terms of Use.

9.2. No Warranty. The Platform and all information, data, and content thereon are provided on an "as-is" and "as-available" basis without warranties of any kind, whether express, implied, statutory, or otherwise, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement, and freedom from error.

9.3. The limitations in this Section 9 apply to the fullest extent permitted by law and shall survive the termination or expiration of any User's use of the Platform.

10. USER ACKNOWLEDGEMENTS AND CONFIRMATIONS

BY ACCESSING OR USING THE PLATFORM, YOU ACKNOWLEDGE, REPRESENT, AND CONFIRM THAT:

10.1. You have read, understood, and accepted this Risk Disclosure & No-Advice Notice in its entirety.

10.2. You understand that crypto-assets are highly risky and speculative, and that you may lose all of the money you invest in crypto-assets.

10.3. You are of legal age in your jurisdiction of residence and have the legal capacity to use the Platform and to enter into transactions with Listed Exchangers.

10.4. You have made your own independent assessment of the risks of interacting with crypto-assets and with any Listed Exchanger, and you accept those risks.

10.5. You have not relied on any statement, representation, warranty, or guarantee made by or on behalf of the Company in deciding to interact with any Listed Exchanger.

10.6. You are solely responsible for compliance with all applicable laws and regulations in your jurisdiction, including but not limited to AML/KYC requirements, tax obligations, and any restrictions on the acquisition, holding, or transfer of crypto-assets.

10.7. You acknowledge that the Company is not a licensed, registered, or authorised financial services provider, investment adviser, VASP, CASP, or financial intermediary in the BVI, the EU, Ukraine, or any other jurisdiction (unless otherwise expressly disclosed).

10.8. You understand that the information on the Platform is for informational purposes only and does not constitute financial, legal, tax, or investment advice.

11. AMENDMENTS

11.1.The Company reserves the right according to the Platform Terms of Use to amend, update, or modify this Notice at any time, at its sole discretion, by publishing the revised version on the Platform.

11.2. Users are encouraged to review this Notice regularly. Continued use of the Platform after the publication of any amendments constitutes acceptance of the amended Notice.

12. CONTACT INFORMATION

For any questions or concerns regarding this Risk Disclosure & No-Advice Notice, please contact:

Emailcontact@bettertomorrowgroupltd.com
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