# Getting Started Mountain Protocol Documentation {% hint style="info" %} Mountain Protocol Limited, a Bermuda Limited company, is licensed by the Bermuda Monetary Authority (BMA) as a Digital Asset Business, under license #202302512 License can be verified in the official BMA website: {% endhint %} Welcome to Mountain Protocol! We believe in a world where access to the "risk-free rate" is available for everyone in an enterprise-grade and regulated product that is safe for developers to evolve the world finance stack. Mountain Protocol believes that yield-bearing stablecoins should provide the following: * Permissionless composability * Regulatory compliance * Enterprise-grade setup * Seamless User Experience Mountain Protocol has two products: the USDM token and the Mountain Protocol Platform. ## USDM token The USDM token is a rebasing ERC20 token, redeemable at a pegged 1:1 USD value by primary users. USDM is a fully backed stablecoin, backed by "USDM Reserves", which are held under custody with regulated financial institutions in bankruptcy-remote[^1] accounts, segregated from the Company's operating accounts, on behalf of, and for the benefit of, Users. USDM rebases daily, allowing users to receive rewards. These rewards are generated by the interest paid by the US Treasuries held in the [USDM Reserves](/legacy-docs/usdm-reserves). For full details related to rights conferred to USDM holders, [click here](/legacy-docs/product-structuring#rights-conferred-by-the-usdm-token). For more details on USDM, visit the page below. {% content-ref url="/pages/C5YATwEoLCUf8B4IHMLB" %} [USDM Token](/legacy-docs/usdm-token) {% endcontent-ref %} ## Mountain Protocol Platform The Mountain Protocol Platform allows Primary users (or Primary Customers, used interchangeably) to purchase or redeem USDM 1:1. Initially, purchases and redemptions will be enabled for USDC, with fiat payments coming next. Other stablecoins will be considered in the future, pending reliable and affordable off-ramping partners and sufficient market demand. {% content-ref url="/pages/yvXeapFv76OPYocTi1FE" %} [Mountain Protocol Platform](/legacy-docs/mountain-protocol-platform) {% endcontent-ref %} [^1]: “Bankruptcy remote” means, with respect to an asset, that the asset would be “excluded” from an insolvent entity’s “estate” in a receivership, insolvency, liquidation or similar proceeding (“insolvency”). # USDM Wind-Down Overview Following its acquisition agreement with Anchorage Digital ([Annnouncement](https://medium.com/@MountainUSDM/mountain-protocol-signs-definitive-agreement-to-be-acquired-by-anchorage-digital-716d8b35c30c)), Mountain Protocol will begin an orderly wind-down of the Mountain USD (USDM) stablecoin. This decision is based in part on the evolving U.S. regulatory landscape, including upcoming stablecoin legislation. The wind-down process has been designed to prioritize transparency, accessibility, and user protection. It includes redemption options for both Primary Customers as well as Secondary Customers. The wind-down process has been designed to prioritize transparency, accessibility, and user protection. It includes redemption options for both Primary Customers as well as Secondary Customers. As part of the wind down plan, minting has been disabled and primary customers will no longer be able to buy USDM. The USDM wind down will be split into 3 phases: * Phase 1 (May 12th to June 11): USDM Rewards will stay active for a 30-day period. During this period there are no changes to USDM, other than minting being disabled. * Phase 2 (June 12 to July 11): Reward rate is set to 0%. There are no other changes during this phase. * Phase 3 (August 22): USDM Reserves remaining will be deposited on a Uniswap pool against another stablecoin (stablecoin to be determined). This means that USDM stablecoins after the kick-off of Phase 3 will no longer be backed by US Treasury products held in USDM Reserves, redeemable at $1 by Mountain Protocol, and are instead backed by the correspondent stablecoin (USDC) and honored by the Uniswap protocol. For more information on the terms and conditions changes at Phase 3, visit the “[Terms and Conditions - Phase 3](/wind-down-legal/terms-and-conditions)”. ## Phase 3 specifics |


| **Phase 1 and 2** | **Phase 3** | | ---------------------- | ------------------------------------------------------------------------------- | ------------------------------------------------------------- | | Reserves holdings | USDM Reserves Ltd, an orphan SPV for the benefit of USDM holders | Uniswap pool on Ethereum with concentrated liquidity of wUSDM | | Reserve composition | Short term US Treasuries and equivalent assets, as per investment policy (link) | USDC | | Redeeming counterparty | Mountain Protocol Ltd redeems 1:1 on primary market | Uniswap pool allows users to swap | | Trust assumptions | Mountain Protocol operation, regulated under BMA | Collateral stablecoin, Ethereum blockchain, Uniswap protocol | This FAQ outlines key information about the wind-down, including redemption paths, timelines, and what to expect if you hold USDM. Mountain Protocol remains committed to supporting all USDM holders throughout this transition and will continue to share updates as the process advances. ### Regulatory Compliance Mountain Protocol has engaged the Bermuda Monetary Authority (BMA) and coordinating the transition in line with Bermuda’s Digital Asset Business Act (DABA) and SCPS Guidance. During Phase 3, compliance obligations for secondary market monitoring of USDM continue, including blocking sanctioned accounts and suspicious activity. Users redeeming via Uniswap no longer fall under BMA-regulated activity, but AML monitoring obligations may persist depending on wallet tracing and volume thresholds. ## Frequently Asked Questions ### **Why is Mountain Protocol winding down USDM?** This decision is based in part on the evolving U.S. regulatory landscape, including upcoming stablecoin legislation. ### **Can I still redeem my USDM?** Yes. All USDM holders will retain redemption options throughout the wind-down process. Users can redeem against Mountain Protocol during Phases 1 and 2. During Phase 3, users will be able to redeem on Uniswap directly. ### **Can I still mint new USDM?** Only through Phase 1 and 2. Minting of new USDM has been disabled. No additional supply will be issued. ### **Will I continue earning rewards on USDM?** USDM rewards will remain active for 30 days after the wind down announcement (Phase 1). After that period, the reward rate will be reduced to 0% and no additional rewards will accrue to USDM holders. ### **What should I do if I’m a Primary Customer with significant USDM holdings?** You are encouraged to redeem directly with Mountain Protocol as soon as commercially possible. If you have any extenuating circumstances please reach out to your Mountain Protocol account manager.\ In case you are not able to redeem during Phase 1 and 2, users will be able to redeem from Uniswap directly on an ongoing basis. ### **As a Primary Customer, would I have to pay any fee to redeem through the Mountain Protocol Platform?** Mountain Protocol does not charge any mint, redemption or any type of transactional fee. Through the Mountain Protocol Platform, customers will be able to redeem USDM for USDC/Fiat or other designated stablecoins at a 1:1 rate, only having to pay for gas fees when depositing the USDM on their deposit address. ### **What happens if I’m not a Primary Customer and I’m holding USDM on-chain?** As a USDM holder, you will be able to redeem your USDM by swapping it for other tokens through existing centralized or decentralized exchanges, including liquidity pools. During Phase 3, the only way to redeem will be through the Uniswap protocol. ### **What will happen to USDM and wUSDM in DeFi protocols such as lending platforms?** Mountain Protocol has conducted a reasonable effort to reach out to protocols where USDM or wUSDM is integrated to notify them of the wind-down. While we cannot directly remove USDM or wUSDM from permissionless protocols, we recommend users withdraw their USDM/wUSDM from these platforms and proceed with redemption through the above-mentioned channels. ### **Is USDM still fully backed?** Yes. USDM will continue to be fully backed by reserve assets during Phase 1 and 2. For Phase 3, USDM will continue to be fully backed, but by the eligible stablecoin/s. Note that in Phase 3, USDM backing will be on-chain held by Uniswap, in the form of stablecoins. ### **What happens to USDM across blockchains?** USDM issued natively can be redeemed by primary users on the Mountain Protocol Platform during Phase 1 and 2. Users can also use Chainlink’s CCIP native bridging capability to bridge their USDM to other networks if needed. During Phase 3, users will need to bridge to ethereum using CCIP in order to be able to redeem. ### **Is this wind-down being conducted in coordination with regulators?** Yes. Mountain Protocol is working closely with the Bermuda Monetary Authority (BMA) throughout the wind-down process, providing regular updates to ensure user protection and full commitment to regulatory compliance and transparency. Mountain Protocol continues to monitor USDM for illegal activity, including ML/TF and continues to work with regulators, including sanctioning addresses. ### **Will Mountain Protocol continue to do attestations? How do I know that USDM in circulation is fully backed?** With the commencement of Phase 3, Mountain Protocol will make available the information of the Uniswap pool that holds the USDM reserves so the public can independently conduct their own process to verify the backing of USDM. Mountain Protocol will also do a step by step “proof of reserves” using public data as of the commencement of Phase 3. Although these numbers will change, the guide will serve as a step by step for the public. At a high level, users will be able to find: 1. Total USDM: as the sum of all USDM issued on all native chains 2. USDM held in Uniswap contract 3. Eligible stablecoin held in Uniswap contract Users should calculate “Total USDM in circulation” as A minus B. This should equal C. ### **I don’t know how to use Uniswap, how can I redeem?** Users can redeem their USDM directly using the uniswap protocol, using the Uniswap frontend (link) or using one of many aggregators, such as Odos, 1Inch or Cowswap. Users should also reach out to the parties or methods with which they initially acquired the USDM and see if they offer a redemption feature. NOTE: Mountain Protocol does not endorse any front-ends or aggregators and use is solely at user risk. ### **How can I stay informed about the wind-down process?** Mountain Protocol will communicate all updates through its website and social media. To review our official social media, please visit:\ # Ongoing proof of reserves As part of the Phase 3 of the wind down plan, Proof-of-Reserves of USDM backing can be found on-chain. This document describes how users can independently verify reserves at any point in time. ## Last 3rd party attestation A sample attestation was performed in Oct 23rd followig the below methodology and published in the [attestation page](/legacy-docs/usdm-reserves-attestations) for reference. This will be the last 3rd party attestation, as the below procedure can be followed to prove reserve adequacy using publicly available Blockchain data. ## Overview As of Aug 22nd, the remaining Reserves held by USDM Reserves Ltd were moved on-chain in the form of USDC and placed on a wUSDM:USDC pool on Uniswap v4 on Ethereum ([link](https://app.uniswap.org/explore/pools/ethereum/0xd3d6e5a73a27081ddd95955f5ae2efbb063013e736f79431c3a31f2817898a35)) In order to calculate the Proof of Reserves, users need to compute the following math: $$ Reserve ratio = Assets / Liabilities $$ Below we explore how to calculate each of the relevant terms ## 1) Assets in Reserve (USDC) Assets can be found in the wUSDM:USDC pool on Uniswap V4. Those can be seen on-chain or via the Uniswap frontend ([link](https://app.uniswap.org/explore/pools/ethereum/0xd3d6e5a73a27081ddd95955f5ae2efbb063013e736f79431c3a31f2817898a35))
The amount of USDC in the pool represents the total "assets" backing USDM. ## 2) Liabilities (USDM in circulation) Liabilities are equivalent to circulating USDM, which is (a) the total USDM in circulation minus (b) wUSDM held in the Uniswap v4 pool. ### 2.1) Total USDM The total USDM is the sum of all USDM on all natively issued chains. This can be calculated by adding the total USDM on the explorers of the below chains, using the USDM token address, as follows: * ETH: * OP: * POL: * BASE: * CELO: * ARB: * ZK: ### 2.2) USDM held in Uniswap pool The wUSDM held on the uniswap pool can be found by using the same link as described above to see USDC balance ([link](https://app.uniswap.org/explore/pools/ethereum/0xd3d6e5a73a27081ddd95955f5ae2efbb063013e736f79431c3a31f2817898a35)). wUSDM balance should then be converted to USDM balances, by using the `convertToAssets` function in the wUSDM smart contract ([link](https://etherscan.io/token/0x57f5e098cad7a3d1eed53991d4d66c45c9af7812#readProxyContract#F9))
$$ Liabilities (2) = Total USDM (2.1) - USDM held On Pool (2.2) $$ Total liabilities are then the total USDM minus the USDM held in the Uniswap pool ## Swapping USDM to USDC In order to swap USDM for USDC in the above-mentioned pool, users can use various options: * Swap using the Uniswap smartcontract directly * Swap using the Uniswap.org frontend * Swap using an aggregator such as Odos () or Jumper () ### Note on wUSDM wrapping Given that USDM is a rebasing token, the pool in Uniswap is built using wUSDM. Services like Odos have integrated wrap/unwrap natively. Other services may require wrapping into wUSDM prior to swapping. Wrapping into wUSDM can be done via: * Directly on the smart-contract ([link](https://etherscan.io/token/0x57f5e098cad7a3d1eed53991d4d66c45c9af7812)) * Using the official Mountain Protocol resource: ### Multi-chain assets Users who hold USDM on other networks that are not Ethereum may have to bridge their USDM to Ethereum in order to swap their USDM. To do this, Chainlink's CCIP native bridging solution will remain open. Users can use the CCIP native bridging using the official briging resource: # Official media accounts The purpose of this page is to share the official accounts used by Mountain Protocol to communicate updates. The company will not communicate any information broadly or directly from any other account than the ones below. ## Official media accounts * Website: * Twitter: * Medium: * GitHub: * LinkedIn: # Terms and Conditions *These terms will enter into effect in Aug 22 2025.* ## Introduction By using our services, you are agreeing to these Terms and Conditions ("Terms") that govern the relationship between you and Mountain Protocol (Mountain Protocol Limited, a Bermuda company), the former issuer and current overseer of the wind-down of the USDM token ("USDM"). Please read these Terms carefully before accessing or using any of our remaining services. As of the commencement of Phase 3 of the USDM wind-down process, Mountain Protocol no longer operates a redemption platform, nor does it offer support, custody, or compliance oversight for the use of USDM. Users may continue to exchange USDM through decentralized protocols (e.g., Uniswap) that are not operated, monitored, or controlled by Mountain Protocol. By holding or interacting with USDM in this Phase, you acknowledge that you have read, understood, and agreed to be bound by these Terms. If you do not agree with these Terms, you must not use USDM or interact with related third-party platforms. These Terms may be updated or modified by Mountain Protocol from time to time. Significant changes will be announced via our website or other appropriate channels providing 30 day notice before effective changes. Continued interaction with USDM after any such changes constitutes your acceptance of the revised Terms. If you have any questions or concerns about these Terms, please contact us at: . ## Definitions “USDM” is a digital asset (rebasing ERC20 token), originally issued by Mountain Protocol Limited (“Mountain Protocol”) operating on blockchains including Ethereum, Polygon POS, Arbitrum, Base, and Optimism. As of Phase 3 of the wind-down process, Mountain Protocol no longer issues, redeems, or guarantees the liquidity or backing of USDM. During its issuance phase, USDM was fully backed by U.S. Dollar-denominated assets (“USDM Reserves”), primarily short-term U.S. treasuries, regulated bank deposits, and certain stablecoins. These reserves were held by USDM Reserves Ltd, a legally separate Special Purpose Vehicle under a Bermuda trust. Users should understand that, following the transition to Phase 3, these reserves are no longer maintained for purposes of redemption or price parity. Instead USDM reserves will be placed on a Uniswap AMM contract on the Ethereum blockchain in a concentrated liquidity pool against an eligible stablecoin. \ “USDM Reserves” are fully segregated from the issuer, in compliance with the DAB Act of 2018, item 18 (1), held by USDM Reserves Ltd, an orphan Special Purpose Vehicle (SPV), which is a charitable trust held by Carey Olsen Fiduciaries Bermuda Limited, a Bermuda regulated Trust Company. USDM Reserves Ltd. is a legally separate entity to ensure that client assets remain segregated and are protected from claims against Mountain Protocol Ltd. Under no circumstance the USDM Reserves held by USDM Reserves Ltd are commingled with Mountain Protocol Ltd assets.\ During Phase 3, USDM Reserves will be held on a Uniswap smart contract on the Ethereum blockchain, in the form of eligible stablecoins “Primary Users” refers to users who hold accounts with Mountain Protocol and have direct access to purchase and redeem USDM through the company’s platform. This category will become inactive following the decommissioning of the platform in Phase 3. “Secondary Users” refers to any holders of USDM who did not hold accounts with Mountain Protocol. In Phase 3, all remaining USDM users are considered secondary users, and redemptions can only occur via third-party decentralized protocols. “The Platform” referres to Mountain Protocol´s web and API interfaces that enabled primary issuance and redemption of USDM. As of the start of Phase 3, the Platform is no longer operational. "U.S. Person" means any of the following: 1. A U.S. Citizen or U.S. Resident, which includes: 1. U.S. citizens; 2. U.S. lawful permanent residents; 3. Individuals who meet the “substantial presence” test described in section 7701(b)(3) of the U.S. Internal Revenue Code of 1986 (as amended); 4. Protected individuals under section 1324b(a)(3) of the U.S. Immigration and Nationality Act; or 5. Individuals who hold a passport issued by the United States Government; 6. A corporation, partnership, or other entity established or organised in or under the laws of the United States; 7. Any estate of a decedent who was a citizen or a resident of the United States; 8. Any trust if: 1. A court within the United States is able to exercise primary supervision over the administration of the trust and 2. One or more United States Persons have the authority to control all substantial decisions of the trust; 2. Any Person organised or incorporated outside the United States and its territories or insular possessions in which any of the foregoing, whether singularly or in the aggregate, directly or indirectly: 1. Holds a 50 percent or greater equity interest by votes or value; 2. Holds a majority of seats or memberships on the board of directors of the entity; or 3. Authorises, establishes, directs, or otherwise controls the actions, policies, personnel decisions, or day-to-day operations of the Person. ## Account Registration 1. As of the commencement of Phase 3 of the USDM wind-down, Mountain Protocol Limited no longer offers account registration, onboarding, or access to its platform. The company no longer accepts new users, institutions, or representatives. All prior institutional accounts have been decommissioned. 2. Users may interact with USDM solely through third-party decentralized platforms that are not operated, maintained, or supervised by Mountain Protocol. Such platforms are not subject to Mountain Protocol’s compliance or monitoring policies. 3. Mountain Protocol prohibits the use of its products and services, including the holding or transfer of USDM, by any person or entity located in, incorporated in, or otherwise associated with jurisdictions subject to sanctions or high-risk AML/CFT exposure, as determined by Mountain Protocol. 4. Additionally, Mountain Protocol prohibits access by U.S. Persons as defined under these Terms. Any engagement with USDM by U.S. Persons or restricted jurisdictions is unauthorized, and such persons must refrain from using or interacting with the token. 1. Supported Jurisdictions: Both your institution and the ultimate beneficial owners must be located in one or more of the jurisdictions supported by Mountain Protocol. A list of supported jurisdictions can be found on our website or obtained by contacting our support team (). 2. Restricted jurisdictions: Abkhazia, Afghanistan, Albania, Algeria, Angola, Bangladesh, Barbados, Belarus, Bhutan, Bosnia-Herzegovina, Botswana, Burkina Faso, Burundi, Cambodia, Cameroon, Central African Rep, China, Congo, the Democratic Republic, Cuba, Croatia, Eritrea, Ethiopia, Gambia, Gaza Strip, Grenada, Guinea, Guinea Bissau, Haiti, Iran, Islamic Republic of Iraq, Ivory Coast (Cote D’Ivoire), Jamaica, Jordan, Kenya, Kosovo, Kuwait, Lebanon, Liberia, Libya, Madagascar, Mali, Montenegro, Morocco, Mozambique, Myanmar, Nagorno-Karabakh, Nepal, Nicaragua, Niger, North Korea, North Macedonia, Pakistan, Qatar, Russian Federation, Sahrawi Arab Democratic Republic, Senegal, Serbia, Seychelles, Slovenia, Solomon Islands, Somalia, South Africa, South Ossetia, South Sudan, Sudan, Suriname, Syria, Tanzania, Togo, Tonga, Trinidad & Tobago, Turkey, Turks & Caicos, Uganda, Ukraine, United States, Vanuatu, Venezuela, Vietnam, West Bank (Occupied Palestinian Territory), Western Sahara, Yemen, Zimbabwe.
5. While Mountain Protocol does not operate the decentralized platforms on which USDM may now be traded or redeemed, it maintains this policy as part of its commitment to regulatory compliance and risk mitigation.
## Services 1. As of the commencement of Phase 3 of the USDM wind-down, Mountain Protocol Limited no longer provides active services related to the issuance, redemption, custody, or transfer of USDM. The Company has decommissioned its platform and no longer offers hosted wallets, account access, or primary market infrastructure. 2. Users who continue to hold or transact USDM may do so exclusively through third-party decentralized protocols (such as Uniswap) that are not operated, monitored, or controlled by Mountain Protocol. These platforms function autonomously via smart contracts and are subject to their own terms, conditions, and risks. 3. Mountain Protocol does not guarantee the availability, price, or liquidity of USDM in these secondary markets. Users are solely responsible for their interactions with decentralized exchanges and for understanding the associated risks, including slippage, front-running, impermanent loss, and the absence of traditional AML/CFT protections. 4. Mountain Protocol will not add new blockchains or services going forward. Any reference to previously supported chains, features, or services is for historical context only.\
## Fees and Charges 1. As of the start of Phase 3 of the USDM wind-down, Mountain Protocol no longer charges any fees or offers any financial incentives, including rewards, for the holding or use of USDM. The Company no longer provides custody, issuance, redemption, or platform services to users. 2. Any fees incurred through the use of USDM in decentralized platforms such as Uniswap (including swap fees, slippage, or network transaction costs) are determined by those third-party protocols and not by Mountain Protocol. Users are solely responsible for understanding and accepting such costs prior to engaging in transactions. 3. Mountain Protocol disclaims any responsibility for fee structures imposed by third parties and does not retain control or visibility over such charges.\
## Transactions 1. As of the commencement of Phase 3 of the USDM wind-down, Mountain Protocol no longer processes transactions involving USDM. All user interactions with USDM now occur through decentralized platforms, such as Uniswap, which operate independently and without direct intervention from Mountain Protocol. 2. Users are fully responsible for: 1. Ensuring the correctness of transaction information, 2. Managing private keys and wallet access, 3. Understanding and accepting the risks associated with trading and transferring assets on decentralized platforms. 3. Transactions conducted on decentralized networks are irreversible, potentially subject to delays or failures beyond Mountain Protocol’s control, and may incur fees determined by the underlying protocols. 4. Mountain Protocol disclaims all liability related to the initiation, processing, failure, or consequences of transactions involving USDM post-transition to Phase 3. ## Account Termination and Suspension 1. As of the commencement of Phase 3 of the USDM wind-down, Mountain Protocol Limited has decommissioned its user platform and ceased the provision of all account-based services. No active user accounts remain, and no new account creation, management, or termination is permitted. 2. Users who continue to hold or interact with USDM do so solely via third-party decentralized protocols, which are not operated, monitored, or supported by Mountain Protocol. Mountain Protocol no longer provides custodial infrastructure or user-specific functionality and therefore cannot suspend, terminate, or re-enable accounts. 3. Mountain Protocol disclaims all responsibility for any user decisions, losses, or risks related to holding or trading USDM on external platforms during or after the wind-down period. ## User Responsibilities 1. Compliance with local laws: Users remain solely responsible for complying with all applicable laws and regulations in their specific jurisdiction, including those relating to digital assets, taxation, financial reporting, and the use of decentralized finance protocols.Prohibited Use of USDMA: The use of USDM for illegal, fraudulent, or malicious purposes is strictly prohibited.. This includes, but is not limited to, money laundering, financing of terrorism, illegal gambling, fraud, blackmail, extortion, ransomware, or any other activities that violate applicable laws, regulations, or our terms and conditions. While Mountain Protocol no longer operates a platform or maintains user accounts, the company reserves the right to take reasonable steps, where technically possible and legally required, to mitigate or report misuse of USDM that violates legal or regulatory standards. 2. Disclaimer on Security: As Mountain Protocol no longer provides account-based or custodial services, users are solely responsible for securing their private keys, wallets, and any associated assets. Mountain Protocol bears no responsibility for losses resulting from unauthorized access, misuse of credentials, or the compromise of user-controlled wallets or devices. ## Security and Fraud Prevention 1. As Mountain Protocol no longer operates a user platform, provides custody services, or maintains accounts, it does not implement or guarantee any security infrastructure for users of USDM. All user interactions with USDM now occur through third-party decentralized platforms and self-managed wallets, which are entirely outside of Mountain Protocol's control. 2. User Responsibility: Users are solely responsible for the security of their wallets, private keys, devices, and any third-party tools they use to store or transact with USDM. Mountain Protocol strongly recommends following best practices for digital asset security, including cold storage, secure backups, and private key protection. 3. Fraud Prevention Disclaimer: Mountain Protocol does notmonitor transactions or user activity and does not maintain the technical ability to detect or intervene in fraudulent activity involving USDM on decentralized platforms. Users must exercise caution and conduct their own due diligence when engaging in transfers, trades, or other blockchain interactions. 4. The use of USDM and digital assets generally involves significant risks. As Mountain Protocol has ceased active issuance, redemption, and custody of USDM, users interact with the token exclusively through decentralized platforms beyond the control of Mountain Protocol. You should carefully assess the following risks before engaging in any transaction involving USDM: 5. Blockchain Risk: Blockchain-based transactions are irreversible and may result in permanent asset loss in the event of errors, unauthorized transfers, or user negligence.Forks and Network Changes: Blockchains on which USDM resides may fork or experience technical disruptions. Mountain Protocol makes no representation as to support for any forked versions of the token. 6. Smart Contract Vulnerabilities: USDM may be traded or held via smart contracts that have not been reviewed or endorsed by Mountain Protocol. Malicious or faulty contracts may lead to asset loss or unexpected behavior.Market and Liquidity Risk: The value and liquidity of USDM on secondary markets are not guaranteed. You may not be able to sell your holdings at a desired price or time. 7. Regulatory Risk: Regulatory changes may impact your ability to hold, use, or trade USDM in your jurisdiction. You are responsible for complying with all applicable laws. 8. No Deposit Insurance: USDM is not a bank deposit, and there is no deposit insurance or guarantee of value from Mountain Protocol or any government agency. 9. Third-Party Platform Risk: USDM can be integrated into permissionless protocols without the involvement of Mountain Protocol. Use of third-party tools, DEXs, or bridges is at your own risk. Mountain Protocol does not assess or endorse such integrations. 10. Custody Risk: Since Mountain Protocol no longer provides custody, users are solely responsible for securing their wallets and private keys. Loss of access to private keys may result in total loss of the asset. 11. Mountain Protocol disclaims all liability for losses or damages arising from these or other risks. By holding or transacting with USDM, you acknowledge and accept these risks. ## Prohibited transactions 1. By holding or using USDM, you agree not to engage in any unlawful or prohibited activity. The following uses of USDM are strictly forbidden:: 1. Violations of any applicable law or regulation. 2. Use in connection with illegal or fraudulent activity, including money laundering, terrorist financing, or the sale of prohibited goods or services; 3. Transacting on behalf of, or knowingly transferring USDM to, any person or entity in a restricted jurisdiction or classified as a U.S. Person; 4. Participation in market manipulation schemes, wash trading, or use of unauthorized marketplaces, including darknet platforms. 2. While Mountain Protocol no longer intermediates transactions, it expressly prohibits any such uses of USDM. Mountain Protocol will continue to monitor secondary markets and may cooperate with legal authorities, when required by law, to support investigations related to misuse of the token. This may include the need to block/freeze assets or accounts, as well as other measures that can be required by regulators. 3. Users are solely responsible for ensuring that their use of USDM complies with all applicable laws and with these Terms. Mountain Protocol disclaims any liability for actions taken by users in violation of these restrictions. ## Insufficient Funds or Funds sent to legacy platform addresses 1. If a payment made to tokenize USD for USDM is reversed after the issuance of USDM is completed, Mountain Protocol reserves the right to: (i) retroactively cancel the issuance and deduct the USDM from your account, (ii) deduct such amounts from future USDM issuances or receipts, (iii) suspend your account until resolved, and (iv) pursue legal action or any other means of recovery available. You grant Mountain Protocol the right to block transactions involving USDM from your account and set off any fees or amounts owed against funds held on your behalf. 2. In case Mountain Protocol engages a third party to recover funds owed by you, you will be responsible for any fees or expenses incurred, including collection fees, legal fees, or convenience fees charged by third parties. You agree that communication regarding funds owed or a delinquent account will be made by email or phone, either by Mountain Protocol or a third party acting on its behalf. Note that engaging third parties for debt recovery may negatively impact your credit. ## Third-Party Services and Links 1. Mountain Protocol does not maintain a user platform or provide any integrations or interfaces with third-party services. All current interactions with USDM are performed through decentralized protocols or platforms operated by independent third parties. 2. No Endorsement or Oversight: Mountain Protocol does not endorse, audit, control, or assume responsibility for any third-party services, tools, or platforms that support or facilitate the trading or transfer of USDM, including decentralized exchanges (DEXs), wallets, or blockchain bridges. Specifically, Mountain Protocol does not endorse the Uniswap protocol, the ethereum network or the eligible stablecoins used as USDM Reserves. Users should do their own risk assessment ith regards to the new risks introduced as part of Phase 3 and redeem their USDM before the initiation of Phase 3 if they chose to. Not doing so is considered an acceptance of this risks. 3. User Responsibility: Users are solely responsible for evaluating the security, reliability, and legal compliance of any third-party service they choose to interact with. Mountain Protocol shall not be liable for any losses, data breaches, or damages resulting from such interactions. 4. External Resources: Any references to third-party websites, protocols, or services are for informational purposes only. Accessing these resources is entirely at your own risk. ## No investment advice 1. Mountain Protocol does not provide any investment advice, financial guidance, or recommendations regarding the purchase, sale, holding of USDM or any other digital assets. 2. All decisions related to USDM are made at the sole discretion and risk of the user.Users should conduct their own independent research, consult professional advisors, and carefully consider the legal, financial, and technological risks before transacting in digital assets. ## Representations and Warranties By holding or using USDM following the wind-down ofMountain Protocol's platform,, you represent and warrant that: 1. Legal Capacity: You have the legal capacity to hold and transact with digital assets, including USDM, in your jurisdiction.Compliance with Laws: You will comply with all applicable laws, regulations, and rules in connection with your use of USDM, including those related to anti-money laundering, terrorism financing, sanctions, taxation, and securities laws. 2. No Illegal Use: You will not use USDM in connection with any illegal, fraudulent, or unauthorized activities, including those prohibited by international sanctions or local laws. 3. No Misrepresentation: You will not misrepresent your identity or the nature of your transactions involving USDM.. 4. Self-Custody and Responsibility: You understand that Mountain Protocol no longer maintains accounts or provides custodial services, and that you alone are responsible for securing and managing your digital assets. By holding or transacting with USDM, you acknowledge that Mountain Protocol relies on these representations and disclaims all responsibility for any violations or legal consequences that may arise from your breach of these representations. ## Disclaimer of Warranties, Limitation of Liability, and Indemnification 1. Disclaimer of Warranties: USDM is a decentralized digital asset and ise provided on an "as is" and "as available" basis. Mountain Protocol does not provide any warranties or representations, express or implied, regarding the use, performance, legality, or fitness of USDM for any particular purpose. Mountain Protocol makes no guarantees regarding the security, functionality, or availability of USDM on any third-party platform, wallet, or smart contract. Your use of USDM is entirely at your own risk and discretion. 2. Limitation of Liability: To the fullest extent permitted by applicable law, Mountain Protocol and its affiliates, directors, officers, employees, and agents shall not be liable for any direct, indirect, incidental, special, consequential, or exemplary damages, whether in contract, tort, or otherwise—arising from or related to your use of USDM, including but not limited to loss of funds, loss of data, inability to access assets, or damages caused by third-party platforms, smart contract failures, or regulatory actions,. 3. Indemnification: You agree to indemnify, defend, and hold harmless Mountain Protocol, its affiliates, directors, officers, employees, and agent from and against any and all claims, liabilities, damages, losses, or expenses, including reasonable legal' fees arising from: 1. your use or misuse of USDM; 2. your violation of these Terms; 3. your violation of any applicable law or regulation; or 4. your use of USDM in connection with illegal or unauthorized activities. By using or holding USDM, you acknowledge and accept the disclaimers, limitations of liability, and indemnification obligations outlined above, which apply to the fullest extent permitted by applicable law. ## Governing Law and Jurisdiction 1. These Terms and Conditions shall be governed by and construed in accordance with the laws of Bermuda, without regard to its conflict of laws principles. Any disputes or claims arising out of or in connection with these Terms, or with your holding or use of USDM, shall be subject to the exclusive jurisdiction of the courts of Bermuda. 2. Mountain Protocol remains committed to compliance with all applicable laws and regulatory obligations, including anti-money laundering (AML),counter-terrorism financing (CTF, and sanctions frameworks. This includes adherence to standards issued by the Bermuda Monetary Authority (BMA), the US Treasury Department, the Office of Foreign Assets Control (OFAC), Her Majesty's Treasury (HM) List, CFSP (EU) Sanctions, the Financial Crimes Enforcement Network (FinCEN), the United Nations Security Council, the Financial Intelligence Agency (FIA), international regulators, and other applicable AML, anti-corruption, and economic sanctions laws. 3. Although Mountain Protocol no longer operates a user platform or provides custodial services, it continues to maintain compliance with applicable laws related to the issuance and management of USDM. Mountain Protocol Limited is regulated under Bermuda’s Digital Asset Business Act and has aligned its structure with the BMA’s Guidance forSingle Currency Pegged Stablecoins (SCPS).Users are solely responsible for ensuring that their use of USDM complies with applicable laws and regulatory requirements in their own jurisdictions. ## Miscellaneous 1. Entire Agreement: These Terms and Conditions, along with any referenced policies, constitute the entire agreement between you and Mountain Protocol in connection with the holding or use of USDM, and supersede any prior agreements, understandings, or representations.Severability: If any provision of these Terms is found to be invalid or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect.The invalid or unenforceable provision shall be deemed modified to the extent necessary to make it valid and enforceable. 2. Waiver: No waiver by Mountain Protocol of any provision or breach of these Terms shall be deemed a waiver of any subsequent breach or provision. 3. Assignment: You may not assign or transfer your rights or obligations under these Terms without prior written consent from Mountain Protocol may assign or transfer its rights and obligations at any time without notice. 4. Force Majeure: Mountain Protocol shall not be liable for any failure or delay to perform resulting from causes beyond its reasonable control, including but not limited to natural disasters, war, cyberattacks, labour disruptions, legal or regulatory actions, or failures in communications systems. 5. Notices: Notices regarding these Terms will be published on Mountain Protocol’s official website or communicated via other public means deemed appropriate. Users are responsible for reviewing the latest version of the Terms periodically. ## Contact Information If you have any questions or concerns regarding these Terms and Conditions, or require clarification about the status of USDM, you may contact Mountain Protocol . While Mountain Protocol no longer operates a user platform or provides active services, we will make reasonable efforts to address relevant inquiries related to the wind-down process, regulatory matters, or the general use of USDM. Please note that response times may be limited and support is provided on a best-effort basis only.
# USDM Token The [USDM Token](https://etherscan.io/token/0x59D9356E565Ab3A36dD77763Fc0d87fEaf85508C) is an ERC20 rebasing token, with a redemption value pegged at 1:1 for primary customers. Like other fiat-backed stablecoins, we expect a 1:\~1 in secondary market price, driven by arbitrage opportunities. For more details about rights related to USDM, please visit [Rights of USDM holders](/legacy-docs/product-structuring#rights-conferred-by-the-usdm-token). ## USDM contract overview USDM is built on top of the OpenZeppelin [ERC20 canonical](https://docs.openzeppelin.com/contracts/4.x/api/token/erc20#IERC20) implementation, adding rebasing dynamics to the contract, following the same "share of total supply" pattern as [Lido's stETH](https://docs.lido.fi/contracts/lido). The rebasing mechanism is implemented via the "shares" concept. Instead of storing a map with account balances, the USDM smart contract stores which "share" of the total pool is owned by the account. The balance of an account is calculated as follows: ``` balanceOf(account) = shares[account] * rewardMultiplier ``` `shares` - map of account share of the total supply. Every time USDM is minted or burnt, it is converted to shares and added/deducted and assigned to user's balance. `rewardMultiplier` - is the sum of daily *addRewardMultiplier*, accruing daily for users. ### Rebasing example If a user purchased 100 USDM when the *rewardMultiplier* was 1.00, that user would receive 100 shares of USDM. If the average APY for the year stayed constant at 3.8%, that user would now have 103.8 USDM. Below is an example of the USDM balances, *shares,* and *rewardMultiplier*:
TimeUSDM (balanceOf)SharesrewardsMultiplier
Day 01001001
Day 365103.81001.038
If this user wanted to redeem 100 of the 103.8 USDM, they could transfer 100 USDM to their Mountain Protocol account, via the Platform. Under the hood, the contract will transfer `100/1.038 = 96.339 shares` In this example, the user will receive $100 for their 100 USDM and keep 3.8 USDM. ### How the *rewardMultiplier* works The *rewardMultiplier* variable is updated daily, at or around 12pm UTC, by calling the *addRewardMultiplier* function applying the daily yield*,* changing the value of the *rewardMultiplier*. Below is an example of how the *rewardMultiplier* and the *addRewardMultiplier* work together (note that USDM contract runs on an 18-digit standard, but those have been simplified for this example). The *rewardMultiplier* starts at one and is increased by the *addRewardMultiplier* function on a daily basis. The column shows the value of the *rewardMultiplier* sent to the *addRewardMultiplier* function and the resulting ongoing state of *rewardMultiplier.* | Day | rewardMultiplier | addRewardMultiplier | | --- | ---------------- | ------------------- | | 0 | 1 | 0.000080986 | | 1 | 1.000080986 | 0.000080993 | | 2 | 1.000161979 | 0.000081000 | | 3 | 1.000242979 | 0.000081006 | | 4 | 1.000323985 | 0.000081012 | | 5 | 1.000404997 | | | 6 | ... | | ### Other notable function mentions * **transfer**: The transfer function works like any other ERC20. Note that the transferred amount will be USDM, not shares. This will match the user expected behavior, by sending *balanceOf* and not Shares. * **rewardMultiplier**: Allows developers to read the cumulative yield accrued since the beginning of the contract. Note that past does not predict future. The [Secured Overnight Funding Rate](https://www.sofrrate.com/) is usually a better proxy to USDM yield than historic values. * **totalShares**: This function returns the total number of shares in circulation. Note that this number will be different from the total USDM in circulation, as this does not account for the yield component embedded in the *rewardMultiplier*. * **totalSupply**: This function returns the total number of USDM in circulation. *totalSupply* is calculated by applying the *rewardMultiplier* to the *totalShares.* ## Dependencies The USDM contract builds its foundation on top of OpenZeppelin Contracts library, widely used and recognized battle-tested components throughout the Ethereum ecosystem: * AccessControlUpgradeable.sol * PausableUpgradeable.sol * UUPSUpgradeable.sol * CountersUpgradeable.sol * ECDSAUpgradeable.sol * EIP712Upgradeable.sol * IERC20PermitUpgradeable.sol * IERC20MetadataUpgradeable.sol ## Resources Explore the following essential resources to gain a comprehensive understanding of USDM Token and its associated network: * Open Source Code: [https://github.com/mountainprotocol/](https://github.com/mountainprotocol/tokens) * Bug Bounty Program: * Audit Reports: * Security Center by OpenZeppelin: * Security Policy: * License: * Smart Contract Code Coverage: * Documentation: * USDM Token Addresses: * Ethereum: * Arbitrum: * Base: * Optimism: * Polygon: * Avalanche: * Celo: * ZKSync Era: * wUSDM Token Addresses: * Ethereum: * Arbitrum: * Base: * Optimism: * Polygon: * Avalanche: * Celo: * ZKSync Era: ## Access control roles Below you will find the access control roles and their corresponding addresses for USDM. Each role is linked to a specific set of permissions that are associated with it. * `MINTER_ROLE`: Grants the ability to mint tokens. > 0x48AEB395FB0E4ff8433e9f2fa6E0579838d33B62 * `BURNER_ROLE`: Grants the ability to burn tokens. > 0x48AEB395FB0E4ff8433e9f2fa6E0579838d33B62 * `BLOCKLIST_ROLE`: Grants the ability to manage the blocklist. > 0xB4d98351418c3d35195406e114E56B068F876c8f * `ORACLE_ROLE`: Grants the ability to update the reward multiplier. > 0xD20D492bC338ab234E6970C4B15178bcD429c01C * `PAUSE_ROLE`: Grants the ability to pause/unpause the contract. > 0x16d72b58B8A0bBCf3A6751920ef127Fe746a3BB0 * `UPGRADE_ROLE`: Grants the ability to upgrade the contract. > Not assigned * `DEFAULT_ADMIN_ROLE`: Grants the ability to grant or revoke roles. > 0x313d5B7EfDcd84e8a52D425282B03860e9354d74 ## wUSDM Acknowledging the complexities of handling rebasing tokens in the DeFi ecosystem, the [wUSDM](https://github.com/mountainprotocol/tokens#wUSDM) contract serves as a wrapped token, simplifying integration while preserving stability. The wUSDM contract is an **ERC-4626** (following the [tokenized vault standard](https://ethereum.org/en/developers/docs/standards/tokens/erc-4626/), leveraging the [OpenZeppelin implementation](https://docs.openzeppelin.com/contracts/4.x/erc4626)), enabling users to deposit USDM in exchange for wUSDM tokens. The USDM tokens are rebasing, whereas the wUSDM tokens are non-rebasing, making wUSDM easier to integrate in DeFi protocols. Rebasing tokens have known integration challenges with protocols that assume constant `balanceOf` for tokens (such as Uniswap, 1Inch and Sushiswap). This can lead to daily rewards being captured by players other than the USDM holders in protocols. The stETH issuer, Lido, has [documented this phenomenon here](https://help.lido.fi/en/articles/5231836-what-is-wrapped-steth-wsteth). To solve this problem and ensure USDM holders have full compatibility with DeFi without giving up their rewards, the Mountain Protocol team has built and made permissionlessly available a wrapper on USDM which is called wUSDM. Such wrapper is very similar to Lido's wstETH, a product that is already familiar to the digital asset ecosystem. # Product Structuring Mountain Protocol Limited (the "Company") is a licensed Digital Asset Business (license #202302512) allowed to conduct the following business activities: * Issuing, selling, and redeeming virtual coins, tokens, or any other form of digital assets. * Providing custodial wallet services. The Company provides its services by directly issuing the USDM token, operating the Mountain Protocol platform, and leveraging multiple service providers directly or on users' behalf. ## Rights conferred by the USDM token The Company will ensure US$ 1 or an equivalent amount of USD-denominated assets will be held by USDM Reserves limited, a bankruptcy remote trust, which can exclusively hold USDM liabilities and USDM Reserve assets to support the $1 redemption from users. For more information, please visit the [Terms and Conditions](broken://pages/epNBKTgR4Qvt25K8S4vx). ## Partners Mountain Protocol works with enterprise-grade partners and, when possible, with leading regulated institutions.
CategoryPartner
Digital asset issuerMountain Protocol Limited (the Company)
Digital asset custodyFireblocks - link
Smart contract auditOpenZeppelin - link
AuditorThe Network Firm - link
OnrampCoinbase Prime - link
Compliance analyticsChainalysis - link
Investment ManagerEQ Capital - link
US RepresentationWinston & Strawn LLP - link
Offshore representationCarey Olsen - link
3rd party signingSteakhouse Financial - link
AttestationsNephos
## User experience This user experience of USDM will feel familiar to users of other stablecoins such as USDC, USDT, GUSD, or other fiat-backed stablecoins, since they all: * Have Primary users (KYC'd account holders) and Secondary users (pseudonymous users with no direct relationship with the issuer). * Allow primary users to purchase and redeem stablecoins at a 1:1 price via portal or API, used mainly by Exchanges, Arbitrageurs/Market Makers, or large buyers. * Rely on arbitrageurs to maintain secondary market prices at \~$1. * The Token can be used freely in the secondary market, including transfers to other EOAs or Smart Contracts, without any additional approvals. ### User types The Company also recognizes two types of users: primary and secondary users. **Primary users** (or customers) have an approved account with Mountain Protocol, granting them access to the Mountain Protocol platform. The platform allows users to purchase and redeem USDM with USDC (fiat payments coming soon). Accounts will be eligible to incorporate businesses in supported jurisdictions that do not participate in restricted economic activities, pending compliance approval. **Secondary users** (or customers) are those who acquired their USDM via the secondary market, such as a pool in Curve or other DeFi applications, or have been paid in USDM by another USDM holder. Secondary users need to apply for a Mountain Protocol account before they can redeem USDM directly with the Company. Alternatively, users can choose to swap their USDM to other users in the secondary market. {% hint style="info" %} Note that the Company does not directly control secondary market pricing. The company does not guarantee that users can swap their USDM at par in the secondary market. {% endhint %} ### Open composability USDM is an ERC20 token that can be used freely in any ERC20-compatible protocol as long as such activity falls under the terms and conditions. The Company will conduct efforts to provide USDM users with more options, which include: * Swap pools: allowing for cheap swaps from the most popular assets to USDM. * Lending protocols: providing USDM as collateral or borrow asset. * PSMs: by enabling USDM as collateral to mint other assets, users can benefit from 0% interest loans (or even negative interest rate loans). * LPs: Digital asset pools trading against USD-denominated stablecoins benefit from a yield-bearing USD asset to boost returns. {% hint style="info" %} Warning: given the risky nature of bridges, Mountain Protocol does not endorse or support any bridges. Users who leverage bridges do so at their own risk. To minimize such risk, the Company will aim to offer native USDM in all large blockchains over time. {% endhint %} ### Supported blockchains USDM is currently live on Mainnet Ethereum, Polygon, Arbitrum One, Optimism, Base, ZKSync Era, Avalanche, and Celo, with more blockchains to come in the future. Since the main bottleneck to launching in alternative blockchains is initial liquidity, if you are a large liquidity provider and are interested in partnering for launch in other blockchains, feel free to reach out to [contact@mountainprotocol.com](mailto:contact@mountianprotocol.com). # Mountain Protocol Platform The Mountain Protocol platform allows Primary users (users with an approved Mountain Protocol account) to purchase and redeem USDM at a pegged value of $1. To open an account, incorporated business users need to apply and undergo KYC/AML screening. This process usually takes 24hs from the submission of all required paperwork. ## Functionality The Mountain Protocol platform allows users to gather digital asset wallet addresses and wire details to fund their accounts. All funds in the platform are auto-converted to USDM once settled. The USDM balance can be withdrawn via direct transfer to an allowed EOA in USDM or USDC or to a bank in USD (to be activated soon). Users can choose to custody their USDM directly within the Mountain Protocol platform, where USDM balances will accrue rewards in the same way as if they were held in external addresses. However, in line with crypto guiding principles, we suggest users self-custody their assets. {% hint style="info" %} Users are responsible for controlling and securing access to the Mountain Protocol Platform. If you have any doubts about potential compromises, please reach out as soon as possible so the team can freeze your account and allow time to investigate and create new accesses. Note that losses related to user mismanagement of credentials are not Mountain Protocol's responsibility. {% endhint %} ### Portal Users can access the portal directly to transact with USDM. The portal is similar to Circle/Tether/Paxos or other Enterprise financial platforms. The portal is protected with enterprise-grade security practices. We suggest users who choose to use the portal only give access to users with signing power within their account limits. ### API Users can integrate with the Mountain Protocol platform via API. This allows for faster transactions, especially for Arbitrageurs/ Market Makers. Such APIs are built in line with best practices. For more information on the API, refer to the [API Reference](/legacy-docs/api-overview). ## Accepted means of payment ### Stablecoins Users can purchase USDM with USDC. Balances will be credited in the platform when funds settle (usually in seconds) and are ready to withdraw. Other stablecoins may be added in the future, pending sufficient market demand and a fast and efficient way to off-ramp such stablecoins to minimize [USDM Reserves ](/legacy-docs/usdm-reserves)exposure to non-T-Bill assets. ### Fiat Wire transfers will be live soon. ## Security The platform was built to protect users by implementing enterprise-grade security features, including: * Username and secure password scheme * Two Factor Authentication (2FA) * Whitelisted wallets with 24h cool-down period * IP whitelisting (optional) * Suspicious activity tracking # USDM Reserves The purpose of USDM Reserves is to provide strong assurances regarding the solvency of issued USDM, so users can be comfortable that their USDM can always be redeemed at $1. USDM Reserves are held in the name of the Company with regulated financial institutions in bankruptcy-remote accounts, segregated from the Company's operating accounts, held on behalf of, and for the benefit of, Users that request a redemption of USDM. ## Collateral ### Main collateral USDM is collateralized by short-duration US Treasuries (T-Bills) with an average duration of 60 days or less. US Treasuries are considered the safest USD-denominated asset. Collateral can be composed by any of the following instruments: * Treasury bills, or treasury notes with near maturity. * Money Market Funds investing in short term US treasuries. * Treasury ETFs. * Reverse Repurchase Agreements (repo's) collateralized with US Treasuries. More information about our [partners is here](#partners) and [USDM Reserves - Investment mandate here](/legacy-docs/usdm-reserves-investment-mandate). ### Assets in transit A small portion of the USDM Reserves will inevitably be "in transit". Such occurrence happens when users purchase new USDM, as those assets need to be off-ramped and sent to the broker account. Given the 24/7 nature of USDM can result in assets waiting for banks to open for fiat transfers to settle and for markets to open to purchase assets. Assets in transit should generally account for a small single percentage of assets. Notwithstanding, the company goes to a great extent to minimize such non-T-Bill exposure. ### Collateral buffer To protect USDM holders from interest rate risk, USDM Reserves are always over-collateralized. This over-collateralization acts as an [equity buffer](#user-content-fn-1)[^1] to absorb potential variations in the underlying asset values resulting from interest rate increases. The collateral buffer is sized using a worst-case scenario of interest rate hikes. By providing a collateral buffer to support changes in underlying asset values, USDM holders can be ensured that their USDM will be available for redemption at par, even in a rate hike scenario. ## Liquidity To minimize exposure to assets other than US Treasuries, the company does not keep a portion of "USDM Reserves" in the form of USDC for redemption, nor does it keep cash in transactional banks. This way, USDM holders are protected from potential **USDC depegs** and potential **future bank failures**. Instead, the company provides liquidity by securing multiple OTC **USDC-denominated lines of credit,** collateralized by USDM Reserves. Such facility provides "advances" to users in the form of USDC, which are then re-paid by the USDM Reserves when markets open. This setup allows users to be comfortable that during black-swan events, USDM Reserves are always fully backing their USDM. {% hint style="info" %} Note that in rare occurrences, financial partners might pause operations. Mountain Protocol might also pause purchasing and redeeming USDM with affected payment channels, to protect the quality of USDM Reserves. {% endhint %} ## Transparency and proof-of-reserves The company issues monthly reserve attestations by a licensed accounting firm, as a way to provide transparency to users on the existence and composition of "USDM Reserves". Attestations can be found in the [USDM Reserves - Attestations ](/legacy-docs/usdm-reserves-attestations)page. [^1]: Equity buffers were introduced by the Basel accord to ensure banks can absorb losses above the expected loss, mainly to deal correlated losses during a crisis. # USDM Reserves - Attestations Mountain Protocol engages with UK accountants working at [Nephos Group](https://nephosgroup.co/). Reports are signed by ATA registered accountants, license: [here](https://www.aat.org.uk/find-an-accountant-or-bookkeeper/results?size=25\&from=0\&fullName=Joseph%20David). As part of our commitment to enhanced transparency, two different attestations are issued for each month: * **Attestation report**: attests to USDM Reserves balance, USDM issuance and USDM being fully collateralized at a point in time. * **USDM Reserves full transactional verification**: attests that all transactions involving USDM Reserves were done in line with policies and regulations (will be added soon) Given that the "Full transactional verification" requires a full reconciliation of the month, this report is released later than the "Attestation" report. All attestations can be independently verified in the [Nephos website](https://www.nephosgroup.co/reports/mountain-protocol). NOTE: USDM Reserve attestations are Accountant Reports and not audits, in line with industry standard and to ensure timely availability of information. Mountain Protocol has yearly financial audits that review USDM Reserves as part of the process.
Month closedAttestation reportFull month view
Sep 2023Attestation Sept 2023To be released soon
Oct 2023Attestation Oct 2023
Nov 2023Attestation Nov 2023
Dec 2023Attestation Dec 2023
Jan 2024Attestation Jan 2024
Feb 2024Attestation Feb 2024
Mar 2024Attestation Mar 2024
Apr 2024Attestation Apr 2024
May 2024Attestation May 2024
June 2024Attestation Jun 2024
July 2024Attestation July 2024
Aug 2024Attestation Aug 2024
Sep 2024Attestation Sep 2024
Oct 2024Attestation Oct 2024
Nov 2024Attestation Nov 2024
Dec 2024Attestation Dec 2024
Jan 2025Attestation Jan 2025
Feb 2025Attestation Feb 2025
Mar 2025Attestation Mar 2025
Apr 2025Attestation Apr 2025
May 2025Attestation May 2025
Jun 2025Attestation June 2025
July 2025Attestation July 2025
Final Phase 3 attestationAttestation Oct 2025
# USDM Reserves - Investment mandate **REFERENCE AND ASSET VALUATION CURRENCY**: USD **INVESTMENT DURATION**: 12 months or less **PERMISSABLE INVESTMENTS** * Fixed Income Selection * Fixed or Floating rate bonds denominated in USD * Final maturity limited to 397 days or less * Maintain a dollar-weighted average maturity of 60 days or less and a dollar-weighted average life of 120 days or less * Not acquire any security other than a daily liquid asset unless, immediately following such purchase, at least 10% of its total assets would be invested in daily liquid assets, and the Fund will not acquire any security other than a weekly liquid asset unless, immediately following such purchase, at least 30% of its total assets would be invested in weekly liquid assets * Mutual Funds; Index-tracking securities, including ETFs * Invests at least 99.5% of its total assets in cash, U.S. Treasury bills, notes and other obligations issued or guaranteed as to principal and interest by the U.S. Treasury, and repurchase agreements secured by such obligations or cash. * Repurchase agreements * US Treasury Obligations * US Government risk Money Market Funds and ETFs * Invested in assets with 97% or more in Qualified Interest Income (QII), via RICs to avoid withholding tax for NRAs # API Overview Note: only Primary Users have access to a Mountain Protocol account. For more information on user types, refer to [User Types](/legacy-docs/product-structuring#user-types). For access to the API documentation and your API keys, get in touch with us at or contact your Account Executive at Mountain Protocol.. The API allows Primary Users to: * Deposit and withdraw USDM in/out of their Mountain Protocol account * Deposit and withdraw USDC in/out of their Mountain Protocol account * Query account balance of their Mountain Protocol account, measured in USDM * Consult immediate availability of USDC liquidity, for traders looking for market-neutral trades Secondary users looking to mint/redeem USDM directly from Mountain Protocol need to open an account with the company. To do so, consult [www.mountainprotocol.com](https://docs.mountainprotocol.com/legacy-docs/www.mountainprotocol.com) # Security resources Mountain Protocol is built to be safe. As such, only tried and tested standards are used, including the ERC20 standard and rebasing, as well as known digital asset management solutions, including Fireblocks, Safe multisigs and OpenZeppelin Defender. We also partner with security leading firm, OpenZeppelin ## Security resources * Security center (by OpenZeppelin): * Smart contract security audit (by OpenZeppelin): [Github](https://github.com/mountainprotocol/audits/blob/main/OpenZeppelin%20Mountain%20Protocol%20USDM%20-%20Audit%20Report%20Jun%202023.pdf) * Bug bounty (by Immunefi): [Immunefi bug bounty](https://immunefi.com/bounty/mountainprotocol/) ## Reporting security incidents Mountain Protocol is an open source project. If you have discovered a potential security issue or vulnerability in our smart contract, we greatly appreciate your help in disclosing it to us in a responsible manner. Please send us a detailed description of the issue to our dedicated email address: . The report should include the steps to reproduce, potential impact, and any other relevant information. # Risks USDM was built to be the safest asset in crypto. This page provides transparency on the risks involved and the mitigating strategies Mountain Protocol takes to reduce such risks. This disclosure can help current and prospective USDM holders understand their risk level compared to other on and off-chain alternatives. Users should do their own research when deciding to purchase any digital asset. If you have questions about these risks, please contact us at [contact@mountainprotocol.com](mailto:contact@montainprotocol.com). ## Collateral/solvency ### US debt default USDM Reserves are invested only in short-term (3mo or less) US Treasuries risk. These assets are considered the lowest risk USD-denominated assets. However, these assets rely on the US continuing to service its debt, a systemic risk present in most modern financial instruments. ### Interest rate USDM Reserves are over-collateralized to ensure solvency even in an interest rate scenario. However, interest rates are unpredictable and accelerated interest hikes could reduce the value of the portfolio which, coupled with a bank run, could result in impairment of USDM. Such interest rate hikes would need to be over 200bps in a short period (\~6 weeks). ## Liquidity ### 24/7 redemption availability Mountain Protocol provides 24/7 liquidity to primary customers via a USDC-denominated line of credit. If net withdrawals are higher than the available liquidity, withdrawal times will default to [T+2](https://www.investor.gov/introduction-investing/investing-basics/glossary/settling-securities-transactions-t2) business days, in line with Traditional Financial markets. There is no limit to the amount of funds that can be withdrawn on a T+2 business day timeline. ### Financial partner uptime Mountain Protocol is built on top of enterprise-grade partners, providing Service Level Agreements (SLA) of 99%+. However, the uptime of services of such partners is not guaranteed. Mountain Protocol reserves the right to delay liquidity in the rare occurrences when partners' services are interrupted. ### Counterparty risk Mountain Protocol is built with minimal counterparty risk, leveraging regulated financial partners whenever possible. Main counterparties include: * Custodians * Brokers * Banks * Onramps (e.g. Coinbase Prime) In the rare cases where Mountain Protocol determines that counterparties are facing potential risks, measures may be applied to mitigate placing USDM Reserves at risk. These measures might include the temporary pausing of purchase and redemption of USDM. ## Market ### Secondary market pricing Due to the permissionless nature of USDM as an ERC20 token, we expect trading venues to open for USDM against other digital assets and/or fiat. The pricing of USDM in these venues might differ from $1. Secondary market pricing for USDM might vary due to lack of liquidity, failure of arbitrageurs or market makers working in such pools, technological risks, and oracle manipulations or other types of attacks. The Company is not liable for losses related to secondary market pricing risks. ### Non-endorsement of 3rd party protocols Due to the permissionless nature of USDM as an ERC20 token, we expect protocols to build with USDM. This does not mean an endorsement of such protocols, and users should do their own research before interacting with such protocols. Although Mountain Protocol may engage in co-marketing campaigns with other protocols, such marketing does not endorse the safe use of those platforms. It should not be seen as a guarantee of the safety of such protocols. The Company will not be liable for losses related to using USDM in 3rd party protocols, including hacks or any other losses that could materialize. ## Digital assets ### Blockchain Transactions in the blockchain are irreversible. This means that once you submit an order, whether in the Mountain Protocol platform or the blockchain, the Company or the network will execute such order on your behalf. The Company is not responsible for losses related to errors in orders initiated by users. ### Authentication and private keys Users are the sole responsible for keeping their platform credentials and private keys secure. Users are also responsible for other users they share those credentials too, whether that is by adding additional users in the platform or by sharing signing privileges. The Company is not responsible for losses arising from login credential security compromises, transactions initiated by users added by the account opener, or loss or mismanagement of private keys. ## Technology Mountain Protocol's technology was designed to minimize the surface area for attacks. In the front, the smart contract is a simple ERC20, audited, and battle-tested contract. In the back, Mountain Protocol leverages banking-grade technology, protected from external access, making it hard for attackers to penetrate. ### Smart contract The USDM smart contract, described in the [USDM Token](/legacy-docs/usdm-token) section, is a modified version of the battle-tested ERC20 canonical implementation to enable rebasing and has been audited by [Open Zeppelin](https://www.openzeppelin.com/), a leading audit firm. However, no software product is ever risk-free. The USDM smart contract is public; more information [can be found here](/legacy-docs/usdm-token). The Company suggests that users conduct their own research before purchasing any digital assets, including USDM. ## Management and Directors At Mountain Protocol, we acknowledge that centralized protocols require higher trust assumptions than those necessary for decentralized protocols, especially for Management and Directors of the Company. The Company implements several strategies to mitigate the risks arising from centralization, including: * Regulatory oversight by the Bermuda Monetary Authority. * A bankruptcy-remote "USDM Reserve" setup. * Proof of reserves and monthly attestations. * Requiring an [external signer](/legacy-docs/product-structuring#partners) to sign large transactions and changes in Transaction Approval Policy (TAP), which protects users from collusion from executives or directors. * Delegation of management of "USDM Reserves" to a licensed Investment Manager. * Whitelisting bank accounts where "USDM Reserves" can be transferred to. * Public disclosure of Directors and Management identities. Users should conduct their own research before engaging with any digital asset, including USDM. If you have more questions during your process, reach out to and talk with our team about the product setup and specific concerns. > If you have suggestions on how to further mitigate USDM risks or any other aspect of the management of USDM in general, please contact us at . # Terms and Conditions ## 1. Introduction By using our services, you are agreeing to these Terms and Conditions ("Terms") that govern the relationship between you and Mountain Protocol (Mountain Protocol Limited, a Bermuda company), the issuer of the USDM token ("USDM") and the operator of "The Platform". Please read these Terms carefully before accessing or using our services. By registering for an account, accessing or using the Platform, or purchasing, holding, or using USDM, you acknowledge that you have read, understood, and agreed to be bound by these Terms. If you do not agree with these Terms, you must not use the Platform or the USDM token. These Terms may be updated or modified by Mountain Protocol from time to time. We will notify you of any significant changes to these Terms by posting a notice on our website or through other appropriate means. Your continued use of the Platform or USDM after any such changes constitutes your acceptance of the new Terms. If you do not agree to any changes in the Terms, you must stop using the Platform and USDM immediately. If you have any questions or concerns about these Terms or our services, please contact us at . ## 2. Definitions 1. “USDM” is a digital asset (rebasing ERC20 token), issued by Mountain Protocol Limited (“Mountain Protocol”) that operates natively on the Ethereum, Polygon POS, Arbitrum, Base, Optimism, ZKSync Era, Avalanche, and Celo blockchains (other blockchains will be added in the future, with due notice to users). USDM is fully backed by an equivalent amount of U.S. Dollar-denominated assets managed by Mountain Protocol in the form of “USDM Reserves”. Such reserves are composed mostly by short-term U.S. treasuries and equivalents, and –in smaller portions– in the form of deposits in regulated banks and other low-risk stablecoins that the company accepts as a means to purchase USDM (known as “assets in transit”). 2. “USDM Reserves” are fully segregated from the issuer, in compliance with the DAB Act of 2018, item 18 (1), held by USDM Reserves Ltd, an orphan Special Purpose Vehicle (SPV), which is a charitable trust held by Carey Olsen Fiduciaries Bermuda Limited, a Bermuda regulated Trust Company. USDM Reserves Ltd. is a legally separate entity to ensure that client assets remain segregated and are protected from claims against Mountain Protocol Ltd. Under no circumstance the USDM Reserves held by USDM Reserves Ltd are commingled with Mountain Protocol Ltd assets. 3. “Primary Users” are users of Mountain Protocol products that have opened an account with Mountain Protocol and have direct access to purchase and redeem USDM from “the company”. These users have access to the platform, in the form of web access or API access, to purchase and redeem USDM. 4. “Secondary Users” of Mountain Protocol products are still held under the terms and conditions in this policy. These users do not have access to purchase or redeem USDM directly with Mountain Protocol until they open and are approved for a Mountain Protocol account. 5. “The Platform” refers to both the web portal that allows users to purchase and redeem USDM and the API version with the same functionality. 6. "U.S. Person" means any of the following: 1. A U.S. Citizen or U.S. Resident, which includes: 1. U.S. citizens; 2. U.S. lawful permanent residents; 3. Individuals who meet the “substantial presence” test described in section 7701(b)(3) of the U.S. Internal Revenue Code of 1986 (as amended); 4. Protected individuals under section 1324b(a)(3) of the U.S. Immigration and Nationality Act; or 5. Individuals who hold a passport issued by the United States Government; 2. A corporation, partnership, or other entity established or organised in or under the laws of the United States; 3. Any estate of a decedent who was a citizen or a resident of the United States; 4. Any trust if: 1. A court within the United States is able to exercise primary supervision over the administration of the trust and 2. One or more United States Persons have the authority to control all substantial decisions of the trust; 5. Any Person organised or incorporated outside the United States and its territories or insular possessions in which any of the foregoing, whether singularly or in the aggregate, directly or indirectly: 1. Holds a 50 percent or greater equity interest by votes or value; 2. Holds a majority of seats or memberships on the board of directors of the entity; or 3. Authorises, establishes, directs, or otherwise controls the actions, policies, personnel decisions, or day-to-day operations of the Person. ## 3. Account Registration 1. Eligibility: To be eligible to open an account with Mountain Protocol and use our services, including the USDM token, you must meet the following criteria: 1. Supported Jurisdictions: Both your institution and the ultimate beneficial owners must be located in one or more of the jurisdictions supported by Mountain Protocol. A list of supported jurisdictions can be found on our website or obtained by contacting our support team (). 2. Restricted jurisdictions: Afghanistan, Albania, Algeria, Bangladesh, Barbados, Belarus, Bhutan, Bosnia-Herzegovina, Botswana, Burkina Faso, Burundi, Cambodia, Cameroon, Central African Rep, China, Congo, the Democratic Republic, Cuba, Croatia, Eritrea, Ethiopia, Gambia, Gaza Strip, Grenada, Guinea, Guinea Bissau, Haiti, Iran, Islamic Republic of, Iraq, Jamaica, Jordan, Kenya, Kosovo, Kuwait, Lebanon, Liberia, Libya, Madagascar, Mali, Montenegro, Morocco, Mozambique, Myanmar, Nepal, Nicaragua, Niger,, North Korea, North Macedonia, Pakistan, Qatar, Russian Federation, Senegal, Serbia, Seychelles, Slovenia, Solomon Islands, Somalia, South Africa, South Sudan, Sudan, Suriname, Syria, Tanzania, Togo, Tonga, Trinidad & Tobago, Turkey, Turks & Caicos, Uganda, Ukraine, United States, Vanuatu, Venezuela, Vietnam, West Bank (Palestinian Territory, Occupied), Western Sahara, Yemen, Zimbabwe. 3. Institutional Accounts Only: Only institutions are eligible to create an account with Mountain Protocol. Individual accounts are not supported. 4. Institution Existence: The institution must be a legally established and recognised entity in one of the supported jurisdictions. 5. Authorised Representative: The representative opening the account on behalf of the institution must have the legal authority to act on behalf of the institution and bind it to these Terms. 6. No Previous Suspension: The institution or its representative must not have had a previous account with Mountain Protocol that was suspended or terminated for any reason. If you would like to reactivate a suspended account, get in touch with the support team. Reactivations are subject to company review. 7. Age requirement: The representative opening the account must be at least 18 years of age. 8. No existing sanctions: Neither the institution nor its representative must appear on any eligible sanctions lists, as determined by Mountain Protocol. 9. Legal Use Only: The institution and its representative/s agree that the Mountain Protocol account and USDM token will not be used for any illegal activity, including but not limited to, illegal gambling, money laundering, fraud, blackmail, extortion, ransoming data, terrorism financing, other violent activities, or any prohibited market practices. 10. Restrictions for U.S. Persons: Mountain Protocol restricts U.S. Persons' access to and usage of its Services, including but not limited to the USDM token. By using the Services, you represent and warrant that you are not a U.S. Person, as defined in our Terms and Conditions. Mountain Protocol reserves the right to monitor and investigate any transactions or activities involving USDM tokens to ensure compliance with this eligibility restriction. In the event that Mountain Protocol determines, in its sole discretion, that a user is a U.S. Person or has knowingly facilitated the sale or transfer of USDM tokens to a U.S. Person, Mountain Protocol may take appropriate action, including but not limited to address blocking, account suspension or termination, or other actions that the company sees fit. All accounts are subject to review and approval. The Company reserves the right to deny, suspend, or terminate an account if we determine that an institution or its representative does not meet the eligibility criteria outlined above or for any other reason at our sole discretion. 2. Account Information: Upon registering for an account with Mountain Protocol, the institution and its representative will be required to provide accurate, complete, and up-to-date information. This information may include, but is not limited to: the institution's name, address, contact details, tax identification number, incorporation documents, and information about the authorised representative, such as their name, title, and contact information. The institution and its representative agree to promptly update any account information if there are changes or if Mountain Protocol requests it. 3. Account Security: The institution and its representative are responsible for maintaining the confidentiality of their account credentials, including their username and password. They must take reasonable steps to protect the security of their account and prevent unauthorised access or use. This includes, but is not limited to, using strong and unique passwords, enabling two-factor authentication (2FA), and securing the devices used to access the account. The institution and its representative agree to notify Mountain Protocol immediately of any unauthorised access or use of their account, or any other security breach they become aware of. Mountain Protocol will not be liable for any loss or damage resulting from the institution's or representative's failure to comply with these account security requirements. ## 4. Services 1. Description of Services 1. USDM-related services: Mountain Protocol issues the USDM token, which is a digital asset designed to facilitate transactions within the blockchain ecosystem. Users can purchase, hold, and redeem tokens in “the platform”. 2. Bridged USDM-related services: the company does not offer bridged USDM tokens on other blockchains. Users will be informed when new blockchains are added. The use of third-party bridges carries inherent risks, and any resulting losses or damages are the responsibility of the users. 3. Custody services: Mountain Protocol provides access to hosted digital currency wallet(s) ("Hosted Wallet"). Your Hosted Wallet allows you to store, track, transfer, and manage your USDM balances. We store the private keys of said wallets, which are used to process transactions, using industry-standard security procedures and controls in a combination of online and offline storage. Based on our use of our security controls, it may be necessary for us to retrieve private keys or related information from offline storage in order to facilitate certain transactions in accordance with your instructions, and you acknowledge that this may delay the initiation or crediting of such transactions. You are the owner of the Digital Currencies held in your Hosted Wallet. As long as you custody your Digital Currencies in a Hosted Wallet with Mountain Protocol, we maintain control over the private keys associated with the blockchain addresses holding your Digital Currency. While you may generally withdraw your Digital Currency by sending it to an external blockchain address at any time, your ability to do so is subject to outages and downtime of the Mountain Protocol website and our policies. When using the Platform, you will have access to information regarding your balances, type, and amount of Supported Digital Currencies in your Hosted Wallet, individual transactions, and fees. 4. Digital asset transfers: When you or a third party sends Digital Currency to a Hosted Wallet from an external wallet not hosted on Mountain Protocol ("Inbound Transfers"), the person initiating the transfer is solely responsible for executing the transaction properly, which may include, among other things, payment of sufficient network fees for the transaction to be successful. Failure to pay such fees may cause an Inbound Transfer to remain in a pending state outside of Mountain Protocol's control, and we are not responsible for delays or losses incurred as a result of an error in the initiation of the transaction and have no obligation to assist in the remediation of such transactions. By initiating an Inbound Transfer, you attest that you are transacting in a Supported Digital Currency, which conforms to the particular Hosted Wallet into which funds are directed. For example, if you select an Ethereum wallet address to receive funds, you attest that you are initiating an Inbound Transfer of Ethereum alone and not any other Digital Currency. Mountain Protocol incurs no obligation whatsoever with regard to unsupported Digital Currency sent to a Mountain Protocol account or incompatible Hosted Wallet. Erroneously transmitted funds will be lost. You agree, represent, and warrant that all Inbound Transfers are not the direct or indirect proceeds of any criminal or fraudulent activity. We reserve the right to investigate the source of any funds in your account and determine, in our sole discretion, how to handle their disposition. Such reviews may delay the settlement of these funds. Following our review of any funds in question and the circumstances by which you received them, we may determine that you are not the owner of such funds. If such a determination is made, we reserve the right to dispose of these funds in accordance with applicable laws and regulations and in our sole discretion, which may include, but is not limited to, returning them to the destination of their origin. When you send Digital Currency from your Hosted Wallet to an external wallet ("Outbound Transfers" and together with Inbound Transfers, "Digital Currency Transfers"), such transfers are executed at your instruction by Mountain Protocol. You should verify all transaction information prior to submitting instructions to us. Mountain Protocol shall bear no liability or responsibility in the event you enter an incorrect blockchain destination address. We do not guarantee the identity or value received by a recipient of an Outbound Transfer. 5. Digital Currency Transfers cannot be reversed once they have been broadcast to the relevant blockchain, although they may be in a pending state and designated accordingly, while the transaction is processed by network operators. Mountain Protocol does not control any blockchain or Digital Currency network and makes no guarantees that a Digital Currency Transfer will be confirmed by a Digital Currency network. Mountain Protocol may refuse to process or cancel any pending Outbound Transfers as required by law or any court or other authority to which Mountain Protocol is subject in any jurisdiction. Additionally, Mountain Protocol may require you to wait some amount of time after completion of a Digital Currency Transfer before permitting you to use further Services and/or before permitting you to engage in transactions beyond certain volume limits. By using any of the services provided by Mountain Protocol, you acknowledge and agree that the availability and functionality of these services may be subject to limitations, delays, and other issues inherent in the use of blockchain technology and digital assets. Mountain Protocol is not responsible for any losses or damages arising from such issues, and your use of our services is at your own risk. 2. Service Limitations: By using the services provided by Mountain Protocol, you acknowledge and agree that the availability and functionality of these services may be subject to limitations, delays, and other issues inherent in the use of blockchain technology, digital assets, compliance and speed of services of vendors, especially financial partners. Mountain Protocol is not responsible for any losses or damages arising from such issues, and your use of our services is at your own risk. 3. Service Availability: Mountain Protocol strives to provide consistent and reliable access to our services. However, we cannot guarantee that our services will be available at all times, without interruption, or that they will always function as intended. By using our services, you acknowledge and accept the risk of potential service disruptions or unavailability. ## 5. Fees and Charges 1. Fee Structure: Mountain Protocol provides transparency in its fee structure by ensuring that all fees, including those charged by the company and any applicable partners, are clearly shown prior to the execution of any transaction. By using our services, you acknowledge and agree to these fees. 2. Rewards rate: USDM Rewards are presented as a “net” annualised percentage, meaning no fees are charged. There are no charges for using USDM on secondary markets. By holding or using USDM, you acknowledge and accept the terms of USDM Rewards. 3. Fee or Reward Rate Changes: Mountain Protocol reserves the right to unilaterally change fees and reward rates on a daily basis, in line with market conditions. Users will be notified via official channels. 4. Third-Party Fees: Mountain Protocol reserves the right to pass-through transactional fees to users. This can include transfer fees related to blockchain transactions, as well as banking fees. If applicable, users will be informed of any incurring pass-through fees expenses to be charged. ## 6. Transactions 1. Transaction Limits: To ensure the security and compliance of our platform, Mountain Protocol imposes basic weekly transaction limits for users. Higher transaction limits can be requested by submitting an application through the platform. Please note that any increase in transaction limit is subject to further due diligence by Mountain Protocol. We reserve the right to approve or deny such requests at our sole discretion, based on the results of our assessment and compliance with our internal policies and applicable regulations. By using our services, you acknowledge and agree to abide by these limitations. 2. Transaction Processing: Mountain Protocol is committed to providing efficient transaction processing for our users. However, processing times may vary depending on various factors, including the blockchain network's congestion, transaction complexity, and required confirmation or settlement. While we strive to facilitate transactions promptly, we cannot guarantee immediate processing or completion of transactions. 3. Transaction Errors: Users are responsible for ensuring the accuracy of transaction details, including recipient addresses, amounts, and digital asset types. Mountain Protocol is not liable for any losses or damages resulting from user errors or inaccurate transaction information. Once a transaction has been initiated, it cannot be reversed or modified. Please verify all transaction details before submitting them for processing. 4. Compliance Checks: Mountain Protocol monitors and may review transactions to ensure compliance with our policies, as well as applicable laws and regulations. We reserve the right to delay, suspend, or cancel transactions that we suspect may involve illegal or fraudulent activities or that violate our terms and conditions. In such cases, we may be required to report the transaction to the relevant authorities. ## 7. Account Termination and Suspension 1. Termination by User: Users may terminate their account with Mountain Protocol at any time by following the account closure process provided on the platform. Prior to termination, it is the user's responsibility to withdraw or transfer all digital assets from their own wallets. 2. Termination by Mountain Protocol: Mountain Protocol reserves the right to terminate your account and access to our services at our sole discretion, or as required by relevant rules and regulations. 3. When we paralyse, block or terminate our Services and/or your Mountain Protocol account, we will take reasonable steps to provide you with sufficient notice. However, there may be times when we have to stop, block or terminate our Services and/or your 4. Mountain Protocol account without notifying you in advance. The cases in which account closure is appropriate are detailed below (non-exhaustive list): 1. The client's involvement in any illegal, fraudulent activities and/or any illegal activity that the AML/ATF Compliance Department indicates. 2. Security or regulatory risk 3. Request, order, and resolution of a jurisdictional body. 4. Breach of the previously accepted terms and conditions of use. 5. Inappropriate use of the platform. 5. Consequences of Termination: Upon account termination, whether by the user or Mountain Protocol, users will lose access to all services and features provided by the platform. Mountain Protocol will not be liable for any losses, damages, or consequences resulting from account termination. Mountain Protocol will take reasonable business efforts for users to withdraw their funds, in compliance with relevant rules and regulations. 6. Account suspension: We reserve the right to suspend an account for an indeterminate period in which the user cannot carry out new operations. 7. The cases in which account suspension is appropriate are (non-exhaustive list): 1. Not responding to the request for relevant documentation to update the file 2. Do not perform operations within a relevant period. 3. Have relevant reputational and negative news that the client cannot explain sufficiently. 4. Requests from regulators or enforcement agencies. 8. Before the account closure progresses, and as long as the circumstances of the case allow it, the client will be notified of such a situation by email, giving them a response period of 15 days so that they can respond and appeal to such a decision. In that context, the client will have the possibility of appealing their application via email, indicating the reasons why the account closure should not proceed and withdrawing their funds. The client will have the function enabled to withdraw funds deposited on the Platform, as long as permitted by relevant rules and regulations. ## 8. User Responsibilities 1. Compliance with local laws: Users are responsible for complying with all local laws in their specific jurisdiction, including financial, tax, and other legal obligations related to their use of our services. 2. Prohibited Activities: Users of Mountain Protocol's services are prohibited from engaging in any illegal, fraudulent, or malicious activities. This includes, but is not limited to, money laundering, financing of terrorism, illegal gambling, fraud, blackmail, extortion, ransomware, or any other activities that violate applicable laws, regulations, or our terms and conditions. Mountain Protocol reserves the right to monitor and investigate any suspicious activities and may take appropriate action, including account suspension or termination, and reporting to the relevant authorities. 3. User Responsibility for Account Security: Users are solely responsible for maintaining the security and confidentiality of their account information, including login credentials and any other sensitive information related to their Mountain Protocol account. You must promptly notify us of any unauthorised access to or use of your account or any other security breach. Mountain Protocol is not responsible for any losses or damages resulting from unauthorised access to your account or the use of our services by unauthorised parties. ## 9. Security and Fraud Prevention 1. Security: Mountain Protocol uses industry-standard measures to protect your accounts and assets, including encryption, multi-factor authentication, and regular security audits, to protect your account and digital assets from unauthorised access, loss, or theft. 2. Fraud Prevention: Mountain Protocol actively monitors activity for signs of fraud and suspicious activities. We may implement various tools and processes to detect and prevent fraudulent activities, such as transaction monitoring, user behaviour analysis, and identity verification. If we detect any suspicious activities or transactions, we may take appropriate action, including freezing the affected accounts, blocking transactions, or reporting the incident to the relevant authorities. ## 10. Risk factors 1. USDM Reserves risk: USDM Reserves are held in short-term US Treasuries. Defaults on these instruments could lead to loss of collateral value. 2. Blockchain-Related Risk: The use of blockchain technology entails inherent risks, such as irreversible transactions, which may lead to permanent loss of assets in cases of errors or unauthorized transactions. 3. Fork risk: The permissionless nature of blockchains means that existing supported blockchains may fork. The company will inform users in advance in case new forks are supported, so that users can track the blockchains where ownership of assets continues to be supported for redemptions. 4. Smart Contract Risk: Smart contracts used on the platform may contain vulnerabilities or unforeseen issues that could result in asset loss or disruptions to our services. The company has taken steps to mitigate such risks, including audits and monitoring, but no smart contract is free of risk. 5. Liquidity and Listing Risk: Market fluctuations, changes in listing status, or other factors may impact the liquidity and value of digital assets held in your account. 6. Legal risk: Changes in laws or regulations in your jurisdiction or internationally may impact your ability to use our services or the legal status of your digital assets. 7. Exchange risk: The loss or compromise of digital asset exchanges may result in the loss of your assets or disruptions to our services. 8. Trading Risk: Trading digital assets involves inherent risks, including market volatility, and may result in the loss of some or all of your assets. 9. Banking Risk: Changes in banking relationships or regulations may impact the availability of our services, including the ability to deposit or withdraw fiat currency. 10. No Deposit Insurance: Mountain Protocol does not provide deposit insurance, and digital assets held in your account are not insured against loss. 11. Third-Party Platform Risk: USDM’s permissionless feature enables third-party platforms to integrate without the company's consent. This may lead users to interact with malicious contracts or contracts with security features that have not been assessed by the company. The company is not liable for losses related to the usage of third-party platforms. 12. Blocked addresses, Blacklisting and Forfeited funds: Mountain Protocol reserves the right to block certain USDM addresses and freeze associated USDM (temporarily or permanently) if it determines, in its sole discretion, that they may be associated with illegal activity or activity violating the Terms. If you send or receive USDM to/from a Blocked or Blacklisted Address, Mountain Protocol may freeze the USDM and take steps to suspend or terminate your USDM Account. In certain cases, Mountain Protocol may report suspected illegal activity to law enforcement agencies, which could result in the forfeiture of rights associated with your USDM, including redemption for USD. Mountain Protocol may also be required to freeze USDM or surrender associated USD if mandated by a legal order from a valid government authority. ## 11. Prohibited transactions 1. In connection with your holding or use of USDM, you agree not to engage in the following activities: 1. Violate any applicable law, statute, ordinance, or regulation. 2. Intentionally defraud Mountain Protocol or other users. 3. Provide false, inaccurate, or misleading information. 4. Participate in any transaction involving the proceeds of illegal activity. 5. Knowingly sell or transfer USDM to US persons. 2. Using USDM for transactions related to the following is prohibited, and Mountain Protocol reserves the right to monitor and, if appropriate, block or otherwise prevent transactions that relate to: 1. Restricted Persons and US persons, as defined in the Terms and Conditions. 2. Weapons, controlled substances, gambling activities, or money laundering/terrorist financing. 3. Ponzi schemes, pyramid schemes, or multi-level marketing programs. 4. Goods or services that infringe on copyright, trademark, or proprietary rights. 5. Credit repair services or other services that may present consumer protection risks. 6. Court-ordered payments, structured settlements, tax payments, or tax settlements. 7. Unlicensed money transmitter activity, layaway systems, or annuities. 8. Counterfeit goods or fraudulent activities, such as wash trading or market manipulation. 9. Purchasing goods from "Darknet" markets or any other service or website that acts as a marketplace for illegal goods. 3. If Mountain Protocol learns you are engaging in any Prohibited Transactions, it will be considered a violation of the Terms and may result in the suspension or termination of your account, potentially leading to the forfeiture of any USD funds otherwise eligible for redemption. The company may also be required by law to inform authorities about such transactions and follow court orders regarding information and assets held in the account. ## 12. Insufficient Funds 1. If a payment made to tokenize USD for USDM is reversed after the issuance of USDM is completed, Mountain Protocol reserves the right to: (i) retroactively cancel the issuance and deduct the USDM from your account, (ii) deduct such amounts from future USDM issuances or receipts, (iii) suspend your account until resolved, and (iv) pursue legal action or any other means of recovery available. You grant Mountain Protocol the right to block transactions involving USDM from your account and set off any fees or amounts owed against funds held on your behalf. 2. In case Mountain Protocol engages a third party to recover funds owed by you, you will be responsible for any fees or expenses incurred, including collection fees, legal fees, or convenience fees charged by third parties. You agree that communication regarding funds owed or a delinquent account will be made by email or phone, either by Mountain Protocol or a third party acting on its behalf. Note that engaging third parties for debt recovery may negatively impact your credit. ## 13. Third-Party Services and Links 1. Use of Third-Party Services: Mountain Protocol's platform may integrate with or provide access to various third-party services, tools, or platforms to enhance the user experience and provide additional functionalities. By using these third-party services, you agree to their respective terms and conditions, privacy policies, and any other applicable agreements. 2. No Endorsement: The integration or provision of access to third-party services does not constitute an endorsement, guarantee, or recommendation by Mountain Protocol. We are not responsible for the content, accuracy, reliability, or performance of these third-party services. 3. Risks and Liability: You acknowledge that the use of third-party services may involve risks, including security, data privacy, or other risks, and that Mountain Protocol shall not be liable for any losses, damages, or other consequences arising from your use of such services. 4. Third-Party Links: Our platform or communications may contain links to external websites or resources operated by third parties. These links are provided for your convenience and reference only, and Mountain Protocol is not responsible for the content, accuracy, or security of these external websites. Accessing and using these external websites is at your own risk, and Mountain Protocol shall not be liable for any losses or damages resulting from your use of these websites. ## 14. No investment advice 1. Please note that Mountain Protocol does not provide any investment advice or recommendations regarding the purchase, sale, or holding of USDM or any other digital assets. 2. All decisions to buy, sell, or hold digital assets are solely the responsibility of the user. Users should conduct their own research, seek professional advice, and carefully consider the risks associated with digital asset transactions before making any decisions. ## 15. Representations and Warranties By using Mountain Protocol's services, you represent and warrant the following: 1. Legal Capacity: You have the legal capacity and authority to enter into and be bound by these Terms and Conditions, and if you are representing an institution, you have the authority to bind the institution to these Terms and Conditions. 2. Compliance with Laws: You will comply with all applicable laws, regulations, and rules in your jurisdiction, including those related to financial transactions, taxes, and anti-money laundering. 3. Accurate Information: All information you provide to Mountain Protocol, including your registration and account information, is true, accurate, and complete, and you will promptly update any changes to this information. 4. No Conflicts: Your use of Mountain Protocol's services does not conflict with or violate any agreements, contracts, or obligations you have with any third parties. 5. No Illegal Activities: You will not use Mountain Protocol's services for any illegal or unauthorised activities, including, but not limited to, money laundering, terrorism financing, or other criminal activities. 6. No Infringement: You will not infringe upon any intellectual property rights, privacy rights, or other rights of Mountain Protocol or any third party in connection with your use of our services. 7. No Misrepresentation: You will not impersonate any person or entity, or falsely state or otherwise misrepresent your affiliation with any person or entity, in connection with your use of Mountain Protocol's services. By using our services, you acknowledge that Mountain Protocol relies on these representations and warranties in providing our services to you, and that any breach of these representations and warranties may result in account suspension, termination, or other consequences as determined by Mountain Protocol at our sole discretion. ## 16. Disclaimer of Warranties, Limitation of Liability, and Indemnification 1. Disclaimer of Warranties: Mountain Protocol's services are provided on an "as is" and "as available" basis, without any warranties or representations, either express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, title, or non-infringement. Mountain Protocol does not warrant that our services will be uninterrupted, timely, secure, error-free, or free from viruses, bugs, or other harmful components. Your use of our services is at your own risk and discretion. 2. Limitation of Liability: To the fullest extent permitted by applicable law, Mountain Protocol and its affiliates, directors, officers, employees, agents, and licensors shall not be liable for any direct, indirect, incidental, special, consequential, or exemplary damages, including but not limited to damages for loss of profits, goodwill, use, data, or other intangible losses, resulting from your use of our services, even if Mountain Protocol has been advised of the possibility of such damages. 3. Indemnification: You agree to indemnify, defend, and hold harmless Mountain Protocol, its affiliates, directors, officers, employees, agents, and licensors from and against any and all claims, liabilities, damages, losses, or expenses, including reasonable attorneys' fees and costs, arising out of or in any way connected with your access to or use of our services, your violation of these Terms and Conditions, or your infringement of any intellectual property or other rights of Mountain Protocol or any third party. By using Mountain Protocol's services, you acknowledge and agree to the disclaimers, limitations of liability, and indemnification provisions set forth in this chapter, and that they apply to the fullest extent permitted by applicable law. ## 17. Governing Law and Jurisdiction 1. These Terms and Conditions shall be governed by and construed in accordance with the laws of Bermuda, without regard to its conflict of laws principles. You agree to submit to the exclusive jurisdiction of the courts of Bermuda for the resolution of any disputes or claims arising out of or in connection with these Terms and Conditions or your use of Mountain Protocol's services. 2. Mountain Protocol is committed to complying with all relevant laws and regulations, including those pertaining to anti-money laundering (AML) and counter-terrorism financing (CTF). Our compliance efforts encompass guidelines and sanctions from various authorities, such as the Bermuda Monetary Authority (BMA), the US Treasury Department, the Office of Foreign Assets Control (OFAC), Her Majesty's Treasury (HM) List, CFSP (EU) Sanctions, the Financial Crimes Enforcement Network (FinCEN), the United Nations Security Council, the Financial Intelligence Agency (FIA), international regulators, and other applicable AML, anti-corruption, and economic sanctions laws. We have designed our policies and procedures to ensure adherence to these legal frameworks, maintaining the highest levels of transparency, security, and integrity. Users are also required to abide by these legal requirements and collaborate with Mountain Protocol to uphold a compliant and secure platform. 3. Mountain Protocol Limited complies with the Bermuda Monetary Authority's (BMA) Digital Asset Business – Single Currency Pegged Stablecoins (SCPS) Guidance ([link](https://www.bma.bm/viewPDF/documents/2024-12-02-16-55-46-Digital-Asset-Business--Single-Currency-Pegged-Stablecoins-SCPS-Guidance.pdf)). Our operations, risk management framework, and asset backing structure adhere to the requirements set forth in this guidance, ensuring compliance with Bermuda’s regulatory framework for stablecoin issuers. ## 18. Dispute Resolution 1. Informal Resolution: If any dispute arises between you and Mountain Protocol in connection with these Terms and Conditions or your use of our services, both parties shall first attempt to resolve the dispute informally through good faith negotiations. 2. Arbitration: In the event that the parties cannot resolve the dispute informally, the dispute shall be settled by binding arbitration in accordance with the rules of the arbitration body selected by Mountain Protocol. The arbitration proceedings shall take place in Bermuda, and the language of the arbitration shall be English. 3. Class Action Waiver: You agree that any dispute resolution proceedings, including arbitration, will be conducted only on an individual basis and not in a class, consolidated, or representative action. You hereby waive any right to participate in any class action or class-wide arbitration against Mountain Protocol related to any claim or dispute. ## 19. Miscellaneous 1. Entire Agreement: These Terms and Conditions, along with any additional terms and policies referenced herein, constitute the entire agreement between you and Mountain Protocol with respect to your use of our services and supersede any prior agreements or understandings between the parties. 2. Severability: If any provision of these Terms and Conditions is found to be invalid or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect, and the invalid or unenforceable provision shall be deemed modified to the minimum extent necessary to make it valid and enforceable. 3. Waiver: No waiver by Mountain Protocol of any breach or default under these Terms and Conditions shall be deemed a waiver of any subsequent breach or default. 4. Assignment: You may not assign or transfer any rights or obligations under these Terms and Conditions without Mountain Protocol's prior written consent. Mountain Protocol may freely assign or transfer its rights and obligations under these Terms and Conditions. 5. Force Majeure: Mountain Protocol shall not be liable for any failure or delay in performance due to circumstances beyond its reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, labour disputes, or governmental actions. 6. Notices: All notices or other communications required or permitted under these Terms and Conditions shall be in writing and shall be deemed given when delivered personally, sent by email, or mailed by certified or registered mail, postage prepaid, to the respective parties at the addresses provided during registration or as otherwise specified by the parties in writing. ## 20. Contact Information If you have any questions or concerns regarding these Terms and Conditions, or if you require any assistance or support related to our services, please feel free to contact us at . You can also submit a complaint or provide feedback about our services at . Our team is available to address your inquiries and provide guidance as needed. Your feedback and satisfaction are important to us, and we look forward to serving you. # U.S. Restrictions Mountain Protocol's products, including the USDM token, the platform or any other services, are not available to U.S. Persons. There is no certainty of the standing of digital assets in the U.S. For that reason, the Company has taken the conservative approach of complying with Reg S. This means that: * USDM cannot be purchased by US Persons. * Mountain Protocol will not do any marketing to US Persons. * Our main website ([www.mountainprotocol.com](http://www.mountainprotocol.com)) is not accessible from the U.S. If you have any questions about U.S. restrictions or believe that the U.S. restrictions do not apply to you, via a valid exception, please contact us at # Data Privacy Policy ## 1. Introduction In Mountain Protocol, we are dedicated to safeguarding your privacy and ensuring secure personal and institutional information. This Privacy Policy outlines how we collect, use, store, and protect your data in compliance with the Personal Information Protection Act (PIPA) of Bermuda. At Mountain Protocol, we aim to provide a secure environment for managing and transacting with the USDM token and other crypto assets. Our commitment extends to transparency, so you can feel confident and informed about how your information is handled when you access or use our platform. ## 2. Definitions For the purposes of this privacy policy, the following terms shall have the meanings ascribed to them below: “Personal Information”: means any information that relates to an identified or identifiable individual. Examples: names, dates of birth, photographs, video footage, email addresses, IP address, cookie identifier, and telephone numbers. Information about organisations (i.e., companies and public authorities) is not personal information. “Sensitive Personal Information”: includes information relating to such aspects as place of origin, race, colour, national or ethnic origin, sex, sexual life, health, marital status, family status, disabilities, trader union membership, religious beliefs, and biometric and genetic information. “Informed Consent”: explicit authorization given by an individual for the processing of their personal data, after being informed about how and for what purposes their data will be used. “Data Processing”: any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction. “Right to Withdraw the Consent”: the right of individuals to revoke the consent they have given for the processing of their personal data at any time. Upon withdrawal, the organisation must cease processing the personal data unless processing is permitted or required by law. “Breach of Security”: it is defined as any incident that results in the loss, unlawful destruction, alteration, unauthorized disclosure of, or access to personal information. ## 3. Data Protection Principles Our data management is based on the following fundamental principles: 1. Responsibility and Compliance: Take responsibility for protecting personal data and complying with data protection laws. 2. Conditions for Using Personal Information: Personal data should only be used for specific and legitimate purposes. 3. Sensitive Personal Information: Sensitive personal information must be treated with more excellent care and protection. 4. Fairness: Personal data must be handled in a fair and transparent manner. 5. Privacy Notices: provide clear notices about how personal data is handled. 6. Purpose Limitation: Personal data should only be collected for specific purposes and not used for other purposes without the individual's consent. 7. Proportionality: The collection and use of personal data must be proportional to the purposes for which it is collected. 8. Personal Data Integrity: the company must ensure that personal data is accurate and up-to-date. 9. Security Measures: The company must implement appropriate security measures to protect personal data against unauthorised access. ## 4. Information we collect During the onboarding processes and when accessing or using our services we may collect various types of information, including personal information, sensitive personal information, institutional information, and transactional information. This may include, but is not limited to, your name, contact details, identification information, information about your institution, and details about your transactions on the Platform. ## 5. Data Processing We use your personal information for the following purposes: * Legal and Compliance: To comply with our legal and regulatory obligations. * Service Provision: To provide, operate, and maintain our crypto asset services. * Service Improvement: To analyse and improve our products and services. * Communication: To communicate with you about updates, changes to our terms, and other relevant information. * Security: To protect the integrity and security of our services and your personal information. * Audits: To conduct audits and ensure compliance with internal and external standards. ## 6. Integrity of Personal Information In accordance with the law, we are committed to maintaining the integrity of personal information. We ensure that any personal information we utilise is accurate and kept up to date as necessary for its intended purposes. To achieve this, we will periodically update the information provided by our clients during the onboarding process, utilising public sources to stay informed of any changes. We will also consult with clients regarding any updates. Additionally, it is the user's responsibility to notify us of any substantial changes to their personal information to keep this information updated. Furthermore, we are dedicated to not retaining personal information for longer than is required for those purposes, thereby safeguarding your privacy and ensuring responsible data management. ## 7. Provision of Privacy Notices Mountain Protocol is committed to providing individuals with a clear and easily accessible privacy notice about its practices and policies regarding personal information. This notice will always include: * The use of personal information. * The purposes for which personal information is used. * The individuals or organisations to whom personal information may be disclosed. * The identity and contact information for Mountain Protocol regarding the handling of personal information. Mountain Protocol takes all reasonably practicable steps to ensure that the privacy notice is provided either before or at the time of collection of personal information, or, where that is not possible, as soon thereafter as is reasonably practicable. #### 7.1. Exemption from Providing Privacy Notices 7.1.1. Mountain Protocol is not required to provide a privacy notice if all personal information in its possession is publicly available information. 7.1.2. If the information is required by legal authorities. ## 8. Purpose Limitation We use your personal information only for the specific purposes for which it was collected and do not use it for other purposes without your prior consent. ## 9. Data Proportionality We ensure that the amount of personal information collected is adequate and relevant for the specific purposes of processing. We strictly adhere to the principle of data minimisation, meaning we only collect the data that is necessary to achieve our legitimate business objectives. By doing so, we reduce the risk of handling unnecessary or excessive information, thereby protecting individual privacy and maintaining compliance with data protection regulations. ## 10. Security Measures We implement appropriate technical, administrative, and physical security measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. ### 10.1. Physical Protection Ensure that databases and equipment where data is stored are secured and that access is strictly controlled. Limit physical access to these areas to only those employees who require it for their job functions. Implement measures such as locked rooms, access badges, and surveillance systems to enhance physical security. ### 10.2.Technical Protection Employ encryption mechanisms to protect data during transmission and storage. Utilize firewalls, intrusion detection systems, and other advanced security technologies to prevent unauthorised access. Regularly update and patch software to defend against vulnerabilities and cyber threats. ### 10.3. Administrative Protection Develop and enforce internal policies and procedures that restrict access to personal data only to employees who need it for their specific job responsibilities. Conduct regular training and awareness programs to ensure that all employees understand data protection principles and their roles in maintaining security. Implement access control measures such as role-based access controls to ensure that employees can only access data necessary for their tasks. ## 11. Data Breach In the event of unauthorized access, loss, or disclosure of personal information, we have established internal protocols for immediate notification of the relevant authorities and affected individuals, as outlined in our Privacy Policy. If your personal information is affected, you will be promptly notified of this situation. Our protocols include detailed assessments of the breach's nature and potential consequences, as well as decisive measures to mitigate its impact. Our dedicated team is trained to handle such situations swiftly and responsibly, ensuring that we uphold our commitment to protecting your personal information and maintaining transparency throughout the process. ## 12. Data Transfers If we transfer your personal information to third parties, we ensure that these third parties also comply with PIPA regulations and provide an adequate level of security protection. We only share your information with: * Service Providers: Which help us operate our business. * Legal Authorities: When required by law. The company is responsible for any data transfers made to third parties. These third parties must always meet security requirements before any transfer occurs. The company will inform users or clients about any new third parties to whom data will be transferred, including the purpose of such transfers. ## 13. Children’s Information Mountain Protocol does not allow minors to use its platforms. To ensure this, we have implemented identity verification mechanisms that instantly detect any attempts at onboarding by unauthorised users, resulting in the denial of approval. All this under the regulations of Bermuda law. ## 14. Individual Rights According to the PIPA regulations and general data protection standards, data subjects have the right to request access, block, delete, or update their information, and even withdraw consent at any time. The exercise of these rights must always be done in writing. To do so, please contact us at . Please be advised that this process may require verification of the requestor's identity. Once the request is sent, our Data Protection Officer (DPO) will contact you shortly to provide more precise information regarding your case. ## 15. Changes to This Policy We may update this privacy policy from time to time. We will notify you of any significant changes through our website or other appropriate means. You will be notified of any changes to the privacy policy, and if necessary, new consent will be requested. ## 16. Contact If you have any questions or concerns about this privacy policy or our data protection practices, you can contact us: DPO: Erika Gonzalez Email: ## 17. Complaint Procedures with PrivCom Authority If you have any complaints about how we handle your personal information, you can contact us directly. You also have the right to file a complaint with the Office of the Privacy Commissioner for Bermuda (PrivCom). PrivCom information: Privacy Commissioner - Alexander White Email: Phone: 1-441-543-7748 ## 18. Providers That Receive Personal Information From Mountain Protocol Customers. | Provider | Purpose or Use of the information | Security level | | ----------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------- | | Cloud provider | Back up of all our data. | Certifications | | KYB provider | Contains the files of our customers. | Certifications | | KYB provider | NDA and Onboarding process. | Certifications | | Audit Provider | Financial Audits of our company. They process information from our clients in order to prepare the reports. |

NDA/Contract

Adverse new review

| | Backup provider | Contains the files of our customers. | Certifications | | Internal System | Internal communication channels among employees to process customer information for various purposes, including registrations, limit increases, cancellations, and information update. | Certifications | | System to communicate with BMA | We send files of the customers if BMA asks for them. | Certifications | | Provider to support customer transactions | To support customer transactions. | Certifications |