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Legal document

Terms & Conditions of Service

Version 2.0 · Last updated: August 17, 2026

1. Introduction

These Terms and Conditions (“Terms”) constitute a legally binding agreement between the user (“Client,” “You”) and Dinaria LLC, a Money Services Business (MSB) organized under the laws of the State of Montana, United States, and duly registered with the Financial Crimes Enforcement Network (FinCEN) under Registration No. 31000321315533 (“Dinaria”).

By accessing or using any of Dinaria’s services, platforms, or systems, you acknowledge that you have read, understood, and agreed to these Terms.

If you do not agree with these Terms, you may not use Dinaria’s services.

Dinaria operates as a group. Certain services may be provided to you by an affiliated entity of the Dinaria group that is registered or licensed in your jurisdiction. Where a service is provided by an affiliate, that entity is your counterparty for that service, and you will be informed of this before the service is provided. References to “Dinaria” in these Terms include the entity providing the relevant service.

2. Nature of the Relationship

Dinaria provides financial infrastructure services and does not operate as a bank, depository institution, custodian, trustee, fiduciary, or escrow agent, unless expressly agreed in writing.

The Client acknowledges that:

  • Funds held or processed by Dinaria are not bank deposits
  • Funds are not insured by the FDIC or any governmental authority
  • The use of Dinaria’s services does not establish a banking relationship

Depending on the specific service, Dinaria acts as a payment processor and/or money transmitter, as a contractual counterparty under a ledger-based settlement model, or as a technology and compliance provider enabling your access to accounts and wallets issued to you by regulated third-party providers.

3. Services Provided

Dinaria provides infrastructure and support for financial transactions, including:

  • Cross-border payment processing
  • Financial technology for payments and collections
  • Foreign currency exchange and conversion, including conversion between fiat currencies and stablecoins
  • Access to accounts issued in your own name by regulated providers, and to multi-currency balances
  • Payouts to bank accounts and to blockchain addresses
  • Treasury and liquidity management
  • Backend financial infrastructure for fintech platforms
  • Settlement, reconciliation, and ledgering services

Dinaria does not provide:

  • Investment, tax, or legal advice
  • Securities brokerage
  • Lending or credit
  • Retail crypto exchange services, except where provided by an affiliated entity of the Dinaria group registered as a Virtual Asset Service Provider (VASP), under that entity's own terms

4. Funds Handling and Safeguarding

Depending on the service and the provider involved, your funds may be held under any of the following arrangements. Dinaria operates more than one at the same time, and the applicable arrangement may vary per transaction.

(a) Accounts held for the benefit of clients

Funds may be held in an omnibus or “For Benefit Of” (FBO) account opened with a regulated financial institution in the name of Dinaria or of a regulated provider, for the benefit of its clients collectively. Under this arrangement your funds may be pooled with those of other clients, your entitlement is determined by Dinaria’s internal records, and the segregation between clients is operational rather than a separate account in your name.

(b) Accounts issued in your own name

Funds may be held in an account issued to you in your own name by a regulated provider. Under this arrangement you retain beneficial ownership of those funds at all times, and access requires you to accept the terms of that provider, which are presented to you when the account is opened.

(c) Digital assets in custody

Digital assets are held in custody by a regulated provider. Title to those assets remains with you and does not transfer to Dinaria. Digital assets held in custody may be pooled with those of other clients, including by being held in omnibus wallets.

Under all of the above arrangements, the Client acknowledges and accepts that:

  • Funds are not bank deposits, do not earn interest, and are not covered by deposit insurance or by any national guarantee scheme
  • Until a transaction settles finally, your rights in respect of the relevant funds are a contractual claim and not a proprietary interest in an identified asset
  • In the event of insolvency, recovery of funds may be subject to applicable law and third-party arrangements

5. Settlement Models

Dinaria may operate under:

(a) Ledger Settlement Model

Balances reflect Dinaria’s contractual obligation to the Client. Settlement may be executed using Dinaria’s own liquidity or float.

(b) Transmission Model (MSB)

Dinaria receives and transmits funds as a Money Services Business.

(c) Regulated Provider Model

The service is provided through a regulated third-party provider that issues an account or wallet to you directly. Under this model that provider is your counterparty for the service it provides, under the terms you accept with it, and Dinaria provides the technology and compliance layer through which you access it.

The applicable model may vary per transaction.

6. Use of Proprietary Float

Dinaria may use its own fiat or digital asset liquidity (“float”) to fulfill settlement obligations.

Such settlement shall be considered:

  • Final
  • Valid
  • Equivalent in value to external settlement

7. Eligibility

By using Dinaria’s services, you represent that:

  • You are at least 18 years old
  • You have legal capacity to enter into these Terms
  • You are not subject to sanctions
  • You are not operating from restricted jurisdictions

Dinaria reserves the right to deny or terminate services based on risk assessment.

8. Regulatory Compliance (KYC / AML / CFT)

Dinaria implements KYC, AML, CTF, and sanctions screening procedures.

The Client agrees to:

  • Provide accurate and complete information
  • Disclose beneficial ownership
  • Provide source of funds and source of wealth information

Dinaria may:

  • Request additional information at any time
  • Apply Enhanced Due Diligence (EDD)
  • Restrict or terminate services

Dinaria may report transactions or Client activity to regulatory or law enforcement authorities without prior notice, as required by law.

9. Third-Party Providers and Dependencies

Dinaria relies on third parties, including:

  • Banks and correspondent institutions
  • Payment processors
  • Liquidity providers
  • Blockchain networks
  • Compliance and KYC providers

The Client acknowledges that:

  • These third parties may delay, reject, or freeze transactions
  • Dinaria does not control their actions
  • Dinaria shall not be liable for third-party failures

For certain services you may be required to accept the terms of the relevant regulated provider directly. Those terms are presented to you before the service is enabled, and they govern the relationship between you and that provider in respect of the service it provides.

10. Accuracy of Instructions

The Client is solely responsible for all instructions submitted.

All transactions:

  • Are final
  • May be irreversible

Dinaria may attempt recovery but does not guarantee success.

11. Fees and Pricing

Fees may include:

  • Transaction fees
  • FX spreads
  • Service fees

All fees will be disclosed via:

  • Platform
  • Onboarding documentation
  • Commercial agreements

The Client authorizes Dinaria to deduct applicable fees.

12. Acceptable Use

The Client agrees to use the services lawfully.

Prohibited activities include:

  • Financial crime
  • Fraud
  • Sanctions evasion
  • Misrepresentation

The Client may not:

  • Act on behalf of undisclosed third parties
  • Use Dinaria without proper authorization

13. Restricted Activities and Industries

The Client may not use the services for:

  • Sanctioned activities
  • Illegal gambling
  • Adult content
  • Weapons, illicit trade, or high-risk sectors
  • Crypto mixing or anonymization tools

Dinaria reserves discretion to approve or reject specific use cases.

14. Jurisdiction Restrictions

Dinaria maintains a dynamic list of restricted jurisdictions based on:

  • OFAC
  • FinCEN
  • FATF
  • EU / UN

The Client agrees not to transact with such jurisdictions.

15. Data Privacy and Monitoring

Dinaria processes data in accordance with applicable laws.

The Client acknowledges that Dinaria may:

  • Monitor transactions and behavior
  • Analyze data for compliance and risk purposes, including through automated tools
  • Share data with regulators and service providers

The categories of personal data collected, the purposes for which they are processed, the parties with whom they are shared and the rights available to you are described in the Dinaria Privacy Policy, which forms part of your agreement with Dinaria and is available at dinaria.com/legal/privacy.

16. Cryptocurrency Risk Disclosure

The Client acknowledges risks including:

  • Volatility
  • Depegging of stablecoins from their reference currency
  • Network failures, forks, and protocol changes
  • Irreversibility of blockchain transactions
  • Pooling: digital assets held in custody may be held together with those of other clients in omnibus wallets

All risks are borne by the Client.

17. Service Availability

Dinaria does not guarantee:

  • Continuous availability
  • Error-free operation
  • Immediate execution

Services may be interrupted due to:

  • Maintenance
  • Technical issues
  • Regulatory requirements

18. Suspension and Termination

Dinaria may suspend or terminate services if:

  • AML risk is detected
  • Information is inaccurate
  • Terms are breached
  • Required by law

19. Limitation of Liability

Dinaria shall not be liable for:

  • Indirect or consequential damages
  • Loss of profits or data
  • Third-party failures

Total liability shall not exceed fees paid in the prior three (3) months.

20. Indemnification

The Client agrees to indemnify Dinaria against any losses arising from misuse of the services.

21. Governing Law & Dispute Resolution

These Terms are governed by the laws of Montana.

Disputes shall be resolved in:

  • State or federal courts in Montana

Dinaria may elect arbitration where applicable.

22. Complaints

If you are not satisfied with a service, you may submit a complaint in writing to support@dinaria.com.

Dinaria will acknowledge your complaint in writing within one (1) business day, giving you a reference number and the name of the person handling it, and will send you a final response within fifteen (15) business days. Where that timeframe cannot be met, Dinaria will write to you explaining the reason for the delay and the date by which you can expect a final response.

The final response will set out a summary of your complaint, the investigation carried out, the outcome and the reasons for it, and any redress offered. Where the complaint concerns a service provided by a regulated third-party provider, Dinaria will escalate it to that provider and inform you accordingly.

23. Amendments

Dinaria may update these Terms at any time.

Where an update materially changes your rights or obligations, Dinaria will present the updated Terms for your acceptance before you continue using the affected services. For all other updates, continued use constitutes acceptance.

24. Entire Agreement

These Terms, together with the Dinaria Privacy Policy and the terms of any regulated provider you accept in connection with a specific service, constitute the entire agreement between the parties.