Summary of our Transfer Services Policy

1. INTRODUCTION

   1. Uphold Digital Assets Europe, Unipessoal, Lda. (“Uphold”, “we”, “us”, or “our”) is licensed as a crypto-asset service provider and supervised by the Bank of Portugal and the Portuguese Securities Exchange Commission (CMVM). Supervisory authorities contacts: for the Bank of Portugal - Rua do Comércio, 148, 1100-150 Lisboa (registered address and correspondence); [email protected]; +351 213 130 000 ; for CMVM - R. Laura Alves 4, 1050-124 Lisboa, Portugal (registered address and correspondence); [email protected]; +351 21 317 7000. 
      
      
   2. We support both inbound transfers of crypto-assets from external wallets into your Uphold wallet (deposits) and transfers from your Uphold wallet to external wallets (withdrawals). These transfer services are a core feature, enabling you to deposit and withdraw crypto-assets to and from our platform, and are essential for operating our exchange and related services, such as staking. All transfers are carried out in line with EU and Portuguese regulations, including Regulation (EU) 2023/1113 (“Travel Rule Regulation”) and Regulation (EU) 2023/1114 (“MiCA Regulation”), to ensure safety, transparency, and compliance. 

2. INBOUND AND OUTBOUND TRANSFER ORDERS AND TRANSACTION PREVIEW

   1. Inbound Transfer Orders (Crypto-asset Deposits)
      1. For each inbound transfer (deposit), you will receive our specific crypto-asset address that should be used to transfer crypto-assets to your account at Uphold.  
         
         
      2. You will only be able to deposit a selected set of crypto-assets over the supported networks. Not all DLT networks that we support for outbound transfers are available for inbound transfers. All the set of crypto-assets and DLT networks supported by us are listed and continuously updated on our website. Only the networks and crypto assets published there are available for inbound transfers. Uphold reserves the right to change the list of supported crypto-assets at its sole discretion.
         
         
      3. Some inbound transfers may be irretrievable and lost if you do not choose a correct DLT network or if the crypto-asset or network is unsupported. We advise you to be very cautious when choosing a correct DLT network.
         
         
      4. We accept inbound transfers from the following sources
         
         1. External self-custody wallets;
         2. External custodial wallets.
            
            
      5. We will only credit your account once the deposit has passed our required compliance checks (e.g. AML/CTF, Travel Rule Regulation, sanctions) and has been considered final by our system. We only consider a transfer as final after a sufficient number of blocks has been added to the blockchain, following the one where a transaction has been included. These may take up some time, depending on both network confirmation and the outcome of our compliance reviews. Information on required block confirmations is provided on our website. 
         
         
   2. Outbound Transfer Orders (Crypto-asset Withdrawals)
      1. You can initiate an outbound crypto-asset transfer only from your own Uphold account, following a successful verification and authentication process into the platform. Crypto-assets from your account can be transferred to other accounts on our platform as well as to other external self-hosted or custodial wallets. 
         
         
      2. To begin a transfer, you must specify the type of crypto-asset that has to be withdrawn, the supported network, the destination wallet address or account, and the amount to be transferred.
      3. You will be able to review and possibly modify these details in the transaction preview section. It is important to review the transaction preview section carefully – you will not be able to change, modify, edit and/or cancel the confirmed transfer order. You can cancel, terminate or revoke a transfer order before confirming it in the transaction preview interface. Once confirmed, the transfer is deemed authorized and will be executed by Uphold.
         
         
      4. All crypto-asset withdrawals will be subject to our automatic compliance and fraud screenings, in compliance with relevant laws, including, but not limited to, AML/CFT regulations and Travel Rule Regulation. In case the authentication fails or raises security concerns, the transfer will not be accepted for processing and may trigger an enhanced review process as per our policies.
         
         
      5. Your outbound transfer is executed by us once we broadcast it to the relevant DLT network and the transaction has been included in a block on that network. Uphold does not exercise any control over the blockchain networks that it supports, and it will not be responsible for failures of the transfers attributable to the blockchain network, once that a transfer has been signed on-chain and relayed to the network. 
         
         
      6. Uphold makes all necessary efforts to include all transfers in the first available block for immediate execution. Most transfers are validated by the relevant DLT network and included in the first available block after a single confirmation; however, this may not always be possible due to unpredictable network conditions, unusually high network fees, or because certain networks may require additional confirmations. Some transfers may take up to several hours before they can be executed and credited to the recipient account, in line with Uphold policy on maximum execution time.
         
         
      7. Accordingly, execution of your transfer by us does not constitute completion of the transfer on the network, as final completion depends on the necessary block confirmations being achieved and, where applicable, on acceptance by the recipient address, which are outside of our control. The number of block confirmations needed for the transfer of crypto-assets to be irreversible on the DLT, or sufficiently irreversible in case of probabilistic settlement, varies for each DLT network - check our website for further information on the number of block confirmations required by each network to finalise on-chain transfers.

3. TRANSFER FEES

   1. We charge fees on crypto-asset withdrawals to make sure your transfers are processed quickly and reliably under current network conditions. These fees reflect blockchain network fees (miner/validator fees), which can change depending on congestion and status of the networks, and we adjust them dynamically, so your transaction is confirmed promptly on-chain.
      
      
   2. The exact fee may depend on the DLT network used and, in some cases, the type of customer or transaction pattern (e.g. negotiated fees for institutional or high-volume clients).
      
      
   3. You will always see the applicable fees in advance during the transaction preview, and you must accept them before submitting your transfer.
      
      
   4. We also publish a full schedule of fees applied by us and any applicable limits on our website so you can clearly understand the costs associated with your withdrawals.

4. EXPECTED EXECUTION TIME, CUT-OFF AND VALUE DATE OF TRANSFERS

   1. Outbound Transfer Execution Time
      1. We calculate an expected execution time for outbound transfers, i.e. our      estimated time under normal conditions for a transaction to be accepted, broadcast to the relevant DLT network, and added to a block for execution. Expected execution times for all our supported DLT networks are displayed to our clients before acceptance of the transfer order. 
         
         
      2. While the expected execution time is an average time for standard conditions, delays may occur due to extended compliance checks, network congestion, fee spikes, or DLT network outages. You will be informed in the transfer preview that transfer execution by us may take longer than the displayed expected time. 
         
         
      3. We will always try our best to execute all transfers as soon as technically possible, possibly adjusting our fees for prompt addition to a block. We nevertheless will not allow a transfer to remain pending indefinitely. We set our maximum execution time for any transfer to 24 hours: all transfers that remain pending and could not be executed within 24 hours will be automatically cancelled by our systems. If this happens, you will receive a notification from us explaining that the transfer could not be carried out and giving you the reason and next steps.
         
         
      4. The execution of a transfer in virtue of its addition to a block does not imply that the transfer is final and irreversible on the blockchain. We do not control network-specific settlement finality times and will not take any responsibility for the successful finalisation of the transfer after this has been relayed to the network. 
   2. Outbound transfer cut-off and value date 
      1. We process outbound transfer orders on a near real-time, continuous basis (24/7, including weekends and holidays). 
         
         
      2. You may initiate a transfer at any time, and we will start processing it immediately upon receipt of the order.
         
         
      3. The value date of your outbound transfer is going to be the day when a transfer is executed and added to the block of your chosen DLT network.
   3. Crediting your account after an inbound transfer (deposit)
      1. Please be aware that we do not provide a maximum execution timeframe for crediting deposits of crypto-assets as this does not fully depend on us.
         
         
      2. We will only credit your account once the deposit has passed required compliance checks (e.g. AML/CTF, Travel Rule Regulation, sanctions) and has received sufficient block confirmations on the blockchain as required by us. The value date of your inbound transfer will be the day when both are completed. These may take up to several minutes. Information on required block confirmations is provided on our website.            
         

5. EXECUTION, REJECTION, RETURN, SUSPENSION OF TRANSFERS

   1. Execution: We only execute your transfer where:
      1. You confirm the transfer;
      2. All required Travel Rule Regulation information has been obtained, verified, and transmitted;
      3. Pre-execution sanctions and AML/CFT checks are cleared;
      4. No fraud or unauthorized access indicators are present;
      5. The transaction is technically valid and supported on the relevant DLT network.
   2. Rejection. We may reject your transfer to keep your account and assets safe, or to comply with legal and regulatory requirements. This can happen if:
      1. The required information is missing or can’t be verified;
      2. The transfer fails our sanctions, AML/CTF, Travel Rule Regulation, or fraud checks;
      3. Your account is restricted;
      4. The destination address or network is invalid or unsupported;
      5. We detect significant risks of fraud, unauthorized access, or unusual activity.
   3. Suspension. We may need to temporarily suspend transfers if we need to further verify its compliance with our AML/CTF, international sanctions or fraud prevention rules. Suspended transfers will be manually reviewed by our internal teams for further assessment before they can be approved for execution. Our review of suspended transfers may lead to a rejection of the transfer if any of the conditions listed in paragraph 5.2 above are verified. 
   4. Return. Your transfer can be returned if it cannot be credited to the intended recipient. This can happen if:
      1. The receiving wallet or service provider rejects the transfer after running its own checks;
      2. The recipient’s wallet doesn’t support the crypto-asset, address, or network you used;
      3. There is a technical issue outside of our control that prevents the transfer from being completed.
   5. If Uphold rejects, suspends or returns your transfer before it is added to the blockchain (as per Section 6 below), we will notify you via email, clarifying:
      1. The reasons for the action (unless we are obliged under applicable law to withhold such information in whole or in part, e.g. in order to comply with AML/CTF requirements);
      2. Next steps to rectify or resolve the issue (if applicable); and 
      3. Any applicable fees charged and potential reimbursement options, where available.

6. UNAUTHORIZED, INCORRECTLY INITIATED OR EXECUTED TRANSFERS, AND LIABILITY

   1. You must notify us as soon as possible if you believe a crypto-asset transfer was unauthorized or incorrectly executed. We strongly recommend you do so immediately, as soon as you are aware of the incorrect or unrecognised transfer, though we will review reports received at any later date as well.
   2. Upon receiving your report, we will promptly investigate whether the transfer was unauthorized or executed incorrectly due to an error, technical issue, or incident on our side. This may require you to promptly provide any information we reasonably request (for example, transaction details, device information, police report, etc.).
   3. If the transfer is found to be unauthorized or incorrectly executed with liability attributable to us, we will refund or compensate you without undue delay and no later than seven business days following our decision. Refunds may be provided either in crypto-assets or in fiat (at your discretion in EUR or USD).
   4. If we have reasonable grounds to suspect fraud, dishonesty, intent, or gross negligence on your part, we may refuse reimbursement and will inform you in writing of our decision, explain the reasons, and confirm that an investigation has been opened.  Every disputed transfer is carefully investigated, and we will make a final decision on any refund based on evidence and applicable law. 
   5. We are liable only for losses arising from unauthorized or incorrectly executed transfers as a result of an incident attributable to us or due to any other direct control.
   6. We are not liable for incidents outside of our control, i. e. which occurred independently of the provision of the relevant service, or independently of our operations, such as inherent blockchain/distributed ledger failures that we do not control.
   7. If losses arise because of fraud, dishonesty, intent, or serious negligence on your part (as defined by law), you may need to cover those losses. 
   8. In any event, our liability for the loss of crypto-assets is capped at their market value at the time the transfer occurred.

7. SECURITY MEASURES

   1. We operate robust ICT systems to ensure secure, reliable, and efficient transfer services.
   2. Transfers are only processed after you have been securely authenticated, in line with Strong Customer Authentication (SCA) and internal security controls such as two-factor authentication (2FA) and risk-based checks. If authentication fails or raises concerns, the transfer will be blocked and reviewed.
   3. Our security framework follows international standards and includes strict data protection, encryption, continuous monitoring, and independent penetration testing.
   4. Advanced AI systems are used to detect and prevent fraud, account takeovers, and suspicious transfers in real time.
   5. Security is further supported by 24/7 monitoring, disaster recovery arrangements, and dedicated ICT risk management policies.

8. ACTIVITY LOG AND RECORDKEEPING

   1. You can access your activity log at any time through Uphold’s app or web dashboard. You can also export or download the activity log.
   2. You can export or download the activity log, summarising all your inbound and outbound transfers into/from your Uphold account. 
   3. Access to your transaction history is provided free of charge.

For any additional help or support you may need, you are always welcome to contact our customer support via our Help Center, or via your Uphold app.