Risk Disclosure
Feb 4, 2026
support@mainframe.finance
Dammstrasse 16 6300 Zug Switzerland
IMPORTANT NOTICE
This document forms part of the Annexes to the Mainframe Terms and Conditions and should be read together with the Terms and the Privacy Policy.
Capitalised terms used in this document have the meanings given to them in the Terms unless otherwise defined herein.
In the event of any inconsistency between this document and the Terms, the Terms shall prevail, except where the Privacy Policy governs the processing of Personal Data.
This document describes material risks associated with:
- Digital Assets;
- Third-Party Providers;
- fiat and payment structures;
- blockchain, smart contract and DeFi systems;
- AML, sanctions and regulatory controls;
- data processing and cross-border disclosure; and
- use of the Mainframe Platform.
This document is not exhaustive. Additional risks may exist or arise in the future.
Mainframe Finance AG operates as a non-discretionary technology, compliance and operational intermediary. Mainframe is not licensed or prudentially supervised by FINMA as a bank, securities firm, asset manager, DLT trading facility, trading venue, payment institution, collective investment scheme or financial market infrastructure.
Mainframe operates as a financial intermediary under the Swiss Anti-Money Laundering Act and is a member of VQF, a self-regulatory organisation recognised by FINMA for AMLA purposes. Such AMLA supervision does not constitute prudential supervision, licensing or authorisation by FINMA.
Mainframe does not:
- provide investment, legal, tax or financial advice;
- provide custody services;
- operate a trading venue, exchange, matching engine or DLT trading facility;
- execute transactions as principal;
- act as broker, dealer, asset manager, fiduciary or discretionary intermediary;
- guarantee execution, settlement, liquidity, custody, redemption or access to assets;
- guarantee the solvency, performance or security of any Third-Party Provider.
All decisions are made by the Client independently and at the Client’s own risk.
DIGITAL ASSET AND DLT RISKS
Digital Assets typically operate on distributed ledger technologies, including blockchain networks, smart contracts and other decentralised infrastructure.
Mainframe does not operate, maintain, validate, control or guarantee any blockchain, distributed ledger, smart contract or Digital Asset protocol.
Key risks include:
- irreversible transactions;
- incorrect wallet addresses or transaction parameters;
- protocol failure, bugs or vulnerabilities;
- forks, upgrades, airdrops or network changes;
- congestion, delays or failed confirmations;
- cyberattacks, exploits or validator failures;
- loss of access due to wallet, key, infrastructure or Third-Party Provider issues;
- partial or total loss of Digital Assets.
CAUTION: Blockchain transactions may be irreversible. Mainframe cannot reverse, cancel or modify blockchain transactions once submitted to the relevant network or Third-Party Provider.
PLATFORM ROLE AND STRUCTURE RISKS
2.1. No execution and no best execution
Mainframe does not execute trades, operate a trading venue or provide best execution.
Mainframe may transmit, route or facilitate Client Instructions to Third-Party Providers on a non-discretionary basis. Execution, pricing, acceptance, rejection, settlement and completion of any transaction are performed by Third-Party Providers.
Mainframe does not guarantee:
- best available price;
- execution speed;
- liquidity;
- settlement;
- transaction acceptance;
- routing quality;
- outcome of any Instruction.
CAUTION: Transactions may be delayed, rejected, partially executed, executed at an unfavourable price or not executed at all.
2.2. Routing and commercial conflict risk
Routing of Instructions may depend on:
- technical availability;
- Third-Party Provider integration;
- liquidity access;
- compliance requirements;
- operational constraints;
- commercial arrangements;
- rebates, commissions, spreads or other benefits received by Mainframe.
Mainframe may receive and retain fees, rebates, commissions, spreads or other financial or non-financial benefits from Third-Party Providers. Such arrangements may create conflicts of interest in relation to provider availability, routing, presentation or sequencing.
Mainframe does not undertake any obligation to achieve best execution or optimise routing for the Client.
THIRD-PARTY PROVIDER RISKS
The Platform depends on independent Third-Party Providers, including:
- centralised exchanges;
- decentralised exchanges;
- OTC counterparties;
- banks and payment institutions;
- fiat on/off-ramp providers;
- wallet and custody infrastructure providers;
- blockchain analytics providers;
- KYC, KYB and AML providers;
- cloud, hosting and infrastructure providers.
Mainframe does not control Third-Party Providers and does not guarantee their:
- solvency;
- regulatory status;
- security;
- availability;
- systems;
- compliance;
- operational performance;
- contractual performance.
Third-Party Providers operate under their own terms, policies and legal frameworks.
CAUTION: Failure, insolvency, cyberattack, regulatory action, misconduct or operational disruption affecting a Third-Party Provider may result in delayed access, restricted access, loss of assets, failed transactions or total loss.
FIAT FUNDS AND PAYMENT STRUCTURE RISKS
Fiat funds may be held with third-party banking or payment providers in accounts opened in the name of Mainframe and internally attributed to Clients.
Such accounts:
- are not personal bank accounts of the Client;
- may be pooled, omnibus or hybrid accounts;
- may not create a direct claim of the Client against the banking or payment provider;
- may not benefit from deposit protection;
- may not be bankruptcy-remote;
- may be subject to freezing, blocking, regulatory intervention or provider restrictions.
Clients may have rights only as determined by the applicable contractual, account and provider structure, the Terms and mandatory applicable law. No bank account, deposit, fiduciary deposit, trust, escrow or similar relationship with Mainframe is created.
There is no guarantee that fiat funds are legally segregated, protected from insolvency or preferentially treated in the insolvency of Mainframe or any Third-Party Provider.
CAUTION: In the event of insolvency, regulatory action, freezing order, banking provider failure or Mainframe insolvency, fiat funds may be delayed, restricted, frozen or lost.
CUSTODY, WALLET AND CLIENT ASSET RISKS
Mainframe does not act as legal custodian of Digital Assets and does not acquire beneficial ownership of Client Assets.
Digital Assets are held, recorded or operated through Third-Party Provider infrastructure, including wallet infrastructure providers, exchanges or other service providers.
Mainframe may have limited technical permissions within Third-Party Provider workflows, but such permissions do not constitute custody, discretionary control, beneficial ownership or an independent power to dispose of Client Assets.
Client Assets may be held on a segregated, omnibus or hybrid basis depending on the relevant provider, service or transaction type.
Depending on the relevant legal, account, omnibus, segregation and provider structure, Client Assets may not be bankruptcy-remote from Mainframe or Third-Party Providers.
CAUTION: Access to Client Assets may be restricted, delayed or permanently unavailable due to provider failure, technical issues, compliance controls, insolvency, cyberattack or regulatory intervention.
MARKET AND FINANCIAL RISKS
6.1. Market Risk
Digital Assets are highly volatile and speculative. Prices may change rapidly and unpredictably.
Clients may lose all or part of the value of their Digital Assets.
6.2. Liquidity Risk
Digital Asset markets may be fragmented, thinly traded or illiquid.
Clients may be unable to buy, sell, redeem, exchange or transfer Digital Assets at the desired time, price or volume.
Liquidity may deteriorate rapidly during market stress.
6.3. Counterparty Risk
Clients are exposed to Third-Party Providers and counterparties, including exchanges, OTC desks, liquidity providers, banks, payment providers, smart contracts and DeFi protocols.
Such counterparties may default, become insolvent, fail to settle, restrict withdrawals, suffer cyberattacks or cease operations.
In decentralised environments, there may be no identifiable counterparty.
6.4. Market Conduct Risk
Digital Asset markets may be subject to:
- fraud;
- manipulation;
- wash trading;
- front-running;
- insider dealing;
- spoofing;
- artificial liquidity;
- abusive or disorderly market practices.
Such risks may be higher than in traditional regulated financial markets.
Mainframe does not control or monitor market conduct of Third-Party Providers or other market participants.
6.5. Continuous Trading Risk
Digital Asset markets often operate 24/7. Price movements may occur at any time, including outside normal business hours.
STABLECOIN RISKS
Stablecoins may present specific risks in addition to general Digital Asset risks.
These include:
- de-pegging risk;
- issuer insolvency;
- reserve insufficiency;
- redemption suspension or refusal;
- bank or custodian failure affecting reserves;
- regulatory restrictions;
- freezing or blacklisting of addresses;
- sanctions-related blocking;
- smart contract or issuer-level intervention;
- loss of confidence in the stablecoin;
- lack of enforceable redemption rights.
A stablecoin may not maintain its intended value. The fact that a token is described as a “stablecoin” does not mean that it is risk-free, fully backed, redeemable or protected.
Mainframe does not issue stablecoins, guarantee stablecoin reserves, guarantee redemption or guarantee the solvency of any stablecoin issuer.
CAUTION: Stablecoins may lose their peg or become non-redeemable, resulting in partial or total loss.
DEFI AND SMART CONTRACT RISKS
Interactions with decentralised finance protocols and smart contracts may involve heightened risks, including:
- code bugs;
- exploits;
- oracle manipulation;
- governance attacks;
- liquidity pool imbalance;
- impermanent loss;
- MEV, front-running and transaction reordering;
- bridge failures;
- admin-key abuse;
- protocol shutdown;
- lack of legal recourse.
Mainframe does not audit, control or guarantee DeFi protocols, smart contracts, bridges or decentralised applications.
CAUTION: DeFi interactions may be irreversible and may result in total loss without any identifiable counterparty or practical remedy.
TECHNICAL, CYBER AND INFRASTRUCTURE RISKS
Use of the Platform and Digital Assets depends on external systems, including:
- blockchain networks;
- Third-Party Provider systems;
- internet infrastructure;
- cloud providers;
- APIs;
- wallet infrastructure;
- Client devices and credentials.
Risks include:
- outages;
- latency;
- failed API calls;
- incorrect data;
- system errors;
- malware;
- phishing;
- credential compromise;
- unauthorised access;
- cyberattacks;
- infrastructure failure.
Mainframe applies reasonable technical and organisational measures but does not guarantee uninterrupted, error-free or secure operation.
CAUTION: Cybersecurity or infrastructure failures may result in unauthorised access, failed transactions, loss of assets or loss of data.
AML, SANCTIONS AND REGULATORY CONTROL RISKS
Mainframe is subject to AML, sanctions and compliance obligations.
Mainframe and/or Third-Party Providers may:
- refuse onboarding;
- request additional information;
- delay, reject or block Instructions;
- restrict withdrawals;
- freeze or hold balances;
- restrict access to Client Assets;
- suspend or terminate Accounts;
- report activity to competent authorities;
- decline to disclose reasons where disclosure is prohibited or restricted.
Such actions may occur without prior notice where required or permitted by law, regulation, sanctions regimes, Third-Party Provider requirements or internal compliance policies.
Mainframe may be legally prohibited from informing the Client of certain reports, investigations, restrictions or suspicious activity assessments.
CAUTION: AML, sanctions or regulatory measures may result in delayed, restricted, frozen or unavailable access to assets, including for an extended or indefinite period, subject to applicable law, competent authority instructions and Third-Party Provider requirements.
LEGAL AND REGULATORY RISKS
Digital Assets, DeFi, stablecoins, exchanges, wallet infrastructure and payment services are subject to evolving laws and regulations.
Regulatory authorities may:
- restrict or prohibit certain assets or activities;
- impose licensing, reporting or compliance requirements;
- reclassify Digital Assets;
- restrict transfers, trading or redemption;
- require blocking, freezing or reporting;
- impose sanctions or enforcement actions.
Regulatory changes may affect:
- availability of the Platform;
- access to Third-Party Services;
- Client Assets;
- legality of transactions;
- tax treatment;
- reporting obligations.
Regulatory changes may apply with limited notice and may have adverse effects on existing holdings or transactions.
Certain exclusions or limitations of liability set out in the Terms may be subject to mandatory applicable law and may not be enforceable in all circumstances. This may affect the allocation of losses between the Client, Mainframe and Third-Party Providers.
Regulatory recharacterisation risk. Although Mainframe structures its activities as non-discretionary technology, compliance and operational intermediation, regulators, courts, banking partners or Third-Party Providers may assess the Platform structure, fiat account structure, technical permissions, operational integrations or interaction with Third-Party Providers differently.
CROSS-BORDER RISKS
Use of the Platform may involve multiple jurisdictions.
Clients may be subject to laws, regulations, taxes, sanctions, reporting obligations or restrictions in their own jurisdiction.
Mainframe does not provide legal, tax or regulatory advice and does not guarantee that use of the Platform is lawful in the Client’s jurisdiction.
Clients are solely responsible for ensuring that their use of the Platform and Third-Party Services is lawful.
DATA PROTECTION, PRIVACY AND INFORMATION DISCLOSURE RISKS
Use of the Platform requires the processing of Personal Data, including identity, KYC/KYB, AML, transaction, wallet, blockchain, technical and compliance data.
Personal Data may be shared with:
- Third-Party Providers;
- banks and payment institutions;
- exchanges and OTC counterparties;
- wallet and infrastructure providers;
- KYC/AML providers;
- blockchain analytics providers;
- regulators, authorities and law enforcement;
- cloud, hosting and IT providers.
Personal Data may be transferred outside Switzerland and the EEA, including to jurisdictions that may not provide equivalent data protection.
Blockchain data may be public, permanent, immutable and not capable of deletion or rectification.
Data subject rights may be restricted where required or permitted by AML, sanctions, regulatory, legal, security or evidentiary obligations.
Under Swiss FADP, data security breaches must be reported to the FDPIC where they are likely to result in a high risk to the personality or fundamental rights of affected persons.
Compliance monitoring, blockchain analytics, risk scoring and behavioural analysis may result in automated or semi-automated alerts, restrictions, enhanced due diligence measures, transaction delays, account suspension or refusal of service. Such measures do not necessarily constitute solely automated decision-making with legal or similarly significant effects. Where applicable law requires human review or additional safeguards, Mainframe will apply such safeguards.
Such measures may be based on data obtained from Third-Party Providers, blockchain analytics tools or internal systems and may be incomplete, inaccurate or subject to interpretation.
CAUTION: Use of the Platform involves data-sharing, regulatory-disclosure, cross-border-transfer and blockchain-transparency risks.
TAX RISKS
Digital Asset transactions may have tax consequences, including income tax, capital gains tax, wealth tax, VAT, withholding tax, reporting obligations or other duties depending on the Client’s jurisdiction.
Mainframe does not provide tax advice and does not determine the Client’s tax obligations.
Clients are solely responsible for obtaining independent tax advice and fulfilling applicable tax obligations.
NO ADVICE, NO SUITABILITY AND NO FIDUCIARY DUTY
Mainframe does not provide:
- investment advice;
- legal advice;
- tax advice;
- financial advice;
- suitability assessments;
- portfolio management;
- discretionary services;
- fiduciary services.
Mainframe does not assess whether any Digital Asset, Third-Party Provider, transaction or service is suitable, appropriate or advisable for the Client.
All decisions are made by the Client independently and at the Client’s own risk.
RETAIL CLIENT ACKNOWLEDGEMENT
If the Client is a retail client or consumer, the Client should carefully consider whether Digital Assets and the Platform are appropriate in light of the Client’s financial situation, knowledge, experience and risk tolerance.
Digital Assets may not be suitable for all clients.
Nothing in this document excludes or limits mandatory consumer rights that cannot be waived under applicable law.
FINAL RISK ACKNOWLEDGEMENT
By using the Platform, the Client acknowledges and accepts that:
- Digital Assets are high-risk and may result in total loss;
- Client Assets may be delayed, restricted, frozen or lost;
- fiat funds may not benefit from deposit protection;
- Depending on the relevant legal, account, omnibus, segregation and provider structure, Client Assets may not be bankruptcy-remote from Mainframe or Third-Party Providers;
- Third-Party Providers may fail, become insolvent or restrict access;
- transactions may be irreversible;
- Mainframe does not provide custody, execution, best execution, investment advice or fiduciary services;
- regulatory, AML or sanctions measures may restrict access without prior notice;
- data may be shared with Third-Party Providers and authorities;
- cross-border and blockchain data risks may apply.
FINAL CAUTION: Clients may lose all or part of their fiat funds, Digital Assets or other Client Assets. Access to assets may be delayed, restricted, frozen or permanently unavailable.