P2P Service Terms

These Peer-to-Peer (P2P) Service Terms (“P2P Terms”) govern your use of the EXMO P2P platform.

1. ABOUT EXMO P2P

1.1. By accessing or using EXMO Peer-to-Peer Service (“EXMO P2P”), you confirm that you (“user”) have read, understood, and agreed to these P2P Terms. If you do not agree, you must not use EXMO P2P.

1.2. EXMO P2P is provided by Blue Isthmus Technologies Corp., a company duly incorporated and validly existing under the laws of the Republic of Panama, registered under number 155777354, having its registered office at World Trade Center 200-B, Suite 73, Calle 53 Este, Marbella, Ciudad de Panama, PA Republica de Panama (referred to as “EXMO”, “we”, “us”, or “our”).

1.3. These P2P Terms form part of the EXMO Terms of Use and you must comply with the EXMO Terms of Use as well as these P2P Terms to be able to use the EXMO P2P. If there is any conflict between these P2P Terms and the Terms of Use, these P2P Terms will apply first. References to “EXMO Services” in the Terms of Use shall include EXMO P2P unless stated otherwise.

1.4. By using EXMO P2P, you represent that you are legally allowed to trade Digital Assets in your jurisdiction and that you are not engaging in any prohibited activity, including acting as a payment intermediary, operating an unlicensed financial service, or violating sanctions or other legal restrictions.

2. DEFINITIONS

Capitalised terms not defined here have the meaning given in the EXMO Terms of Use.

“Advertisement” means an offer published on EXMO P2P that includes the amount of Digital Assets that user would like to trade, the price for such Digital Assets, the payment method that user would like to use when trading, the Order Limit, the Payment Window and other applicable terms and conditions for the offer as determined by the user publishing the offer.

“Advertiser” (“Maker”) – a user who publishes an offer.

“Taker” – a user who accepts an offer.

“Order” – a confirmed agreement between users to trade Digital Assets.

“Order Limit” – the minimum and maximum trade amount set by the Advertiser.

“Payment Window” – the time allowed to complete payment.

“Buyer” – a user purchasing Digital Assets.

“Seller” – a user selling Digital Assets.

“Transfer Fees” – payment service provider charges.

Verified Merchant – a user approved for enhanced trading privileges.

3. HOW EXMO P2P WORKS

3.1. EXMO P2P allows users to buy and sell Digital Assets directly with each other.

Users may act as:

• Advertisers (Makers) – users who publish offers to buy or sell Digital Assets; or
• Takers – users who accept and place an order on an existing Advertisement.

3.2. Advertisers set the terms of their offers, including:

• the amount of Digital Assets,
• the price,
• minimum and maximum trade limits,
• accepted payment methods,
• the Payment Window
• any additional conditions.

EXMO may charge fees for using the service from Advertisers and Takers. Applicable fees are published on our Fee page and may be updated from time to time.

3.3. You may act as either a Buyer or a Seller of Digital Assets on EXMO P2P, regardless of whether you are participating in the transaction as an Advertiser or as a Taker.

3.4. We may require you to meet certain eligibility requirements before you are permitted to publish an Advertisement on EXMO P2P. These requirements may be updated or modified by EXMO from time to time at its discretion.

3.5. You acknowledge and agree that when you place an Order in response to an Advertisement on EXMO P2P, you accept all terms specified in that Advertisement, including the applicable Order Limit and the Payment Window, and you enter into a binding commitment to complete the trade of the relevant Digital Assets. Once the Order is placed, EXMO will lock the amount of Digital Assets specified in the Order. The Digital Assets will remain locked until both parties confirm that the Currency transfer has been successfully completed within the applicable Payment Window. While the Digital Assets are locked, they may not be accessed, transferred, withdrawn, or otherwise used, unless the Order is cancelled or the Digital Assets are released to the Buyer following confirmation of receipt of the Currency transfer by both the Buyer and the Seller.

3.6. When a Taker places an order, they agree to the Advertiser’s terms and must use one of the listed payment methods.

3.7. Once an order is placed, the relevant Digital Assets are temporarily locked by EXMO until:

• the Buyer confirms payment has been made; and
• the Seller confirms payment has been received.

Locked Digital Assets cannot be used elsewhere unless the order is cancelled or completed.

3.8. EXMO is not a party to trades between users. We do not control or set prices, payment methods, or trading terms. Our role is limited to providing the platform and facilitating the transactions.

3.9. You acknowledge and agree that EXMO is not a party to any P2P transaction, either separately or jointly with your counterparty. You also acknowledge and agree that you provide your personal information for identity verification to your counterparty as an independent party, and not to EXMO.

3.10. Active and reliable users may apply to become a “Verified Merchant”. Verified Merchants may receive certain benefits. Eligibility requirements are determined by EXMO.

3.11. Users must not attempt to circumvent the platform for trades, including arranging trades directly via messaging apps, social media, or other off-platform means to avoid fees or reporting requirements.

3.12. Users must not engage in any activity that manipulates pricing, order books, trading volume, or ratings (including wash trading or collusive activity). EXMO reserves the right to suspend or terminate accounts engaged in such activities.

3.13. Verified Merchants are required to maintain ongoing performance standards, including timely responses to Orders, sufficient liquidity, and compliance with local regulatory requirements. EXMO may revoke Verified Merchant status if these obligations are not met.

4. PAYMENT RULES

4.1. Payment methods shown on EXMO P2P are provided for user convenience. EXMO does not endorse or guarantee any listed payment provider.

4.2. Advertisers must choose from the available payment methods on EXMO P2P. Takers must use one of the payment methods selected in the Advertisement.

4.3. The name on your payment account must exactly match the verified name on your EXMO Account. Using third-party payment accounts is prohibited and may result in suspension.

4.4. When you trade, EXMO may share your verified name and username with the counterparty for transaction purposes.

4.5. If you are a Buyer:

• You must send payment within the Payment Window.
• Payment must be made outside the EXMO platform using the selected method.
• After paying, you must confirm the transfer by clicking the confirmation button.

EXMO reserves the right to restrict the Account in case of repeated failures to complete payments.

4.6. If you are a Seller:

• You must independently verify that payment has been fully received.
• Only release Digital Assets after confirming receipt.
• Releasing assets is final and cannot be reversed.
• Do not release assets before receiving full payment.

4.7. Unless otherwise agreed, Buyers are responsible for any payment Transfer Fees charged by payment providers. The Seller must receive the full agreed amount.

4.8. Users acknowledge that EXMO is not responsible for chargebacks, payment reversals, or errors by payment service providers. Buyers bear the risk of failed transfers, and Sellers bear the risk of releasing Digital Assets before confirmed payment receipt.

4.9. Users must comply with all applicable anti-money laundering (AML), counter-terrorism financing (CTF), and sanctions laws. EXMO may request documentation to verify the source of funds and may report suspicious activity to regulatory or law enforcement authorities.

5. WITHDRAWAL WAITING PERIOD

5.1 In certain cases, Digital Assets purchased on EXMO P2P may be subject to a withdrawal hold. This restriction begins once the assets are released to you. Other account activities remain unaffected.

5.2. EXMO may extend, shorten, reapply, or otherwise modify withdrawal waiting periods based on internal risk assessment, transaction patterns, payment method risk level, account history, regulatory requirements, or security considerations.

5.3. The duration of any withdrawal restriction is not fixed and may vary depending on the circumstances of each case.

6. APPEALS AND DISPUTE

6.1. Since EXMO is not a party to trades, we are not responsible for disputes or payment issues between users.

6.2. If a dispute arises, users may file an appeal through the Platform. EXMO may review submitted evidence and facilitate communication. This appeal process is a mediation service only and does not guarantee a particular outcome.

6.3. EXMO may restrict access for users who abuse, do not cooperate or misuse the appeal process. EXMO’s decisions regarding appeals are final.

6.4. During the appeal review process, both parties are required to cooperate with each other and respond to requests for information from EXMO within the timeframe specified by EXMO. If a party fails to communicate with the other party and/or with EXMO within 12 hours from the request for clarification or evidence, EXMO may proceed to resolve the dispute based on the available information and confirmations received. In such a case, EXMO may make a determination in favour of the party that has provided sufficient evidence confirming fulfillment of its obligations under the relevant Order.

6.5. By using EXMO P2P, you agree to indemnify and hold EXMO harmless from any claims, losses, or damages arising from your trades, including disputes with other users, fraud, third-party claims, banking losses or regulatory investigations. This indemnification survives termination of your account.

7. RATINGS AND CONDUCT

7.1. After each completed trade, users may rate one another. Ratings are visible to other users and may affect your ability to continue using EXMO P2P.

7.2. Usernames must not contain the name “EXMO”, names of financial institutions, or misleading wording.

7.3. Users must not share personal contact details, social media accounts, or other private information within Advertisements or chat messages.

7.4. EXMO may display third-party content or links. We are not responsible for third-party services or content accessed through the platform.

7.5. Users must act honestly and not misrepresent themselves or their trading intentions. EXMO reserves the right to adjust ratings or restrict access in case of manipulative or abusive conduct.

8. SUSPICIOUS OR PROHIBITTED ACTIVITIES

8.1. EXMO may restrict, suspend, or terminate access to EXMO P2P where we suspect fraud, illegal conduct, security risks, or other violations. In some cases, we may not be able to disclose the reasons during an ongoing investigation.

8.2. Access may be restored once the issue is resolved, but EXMO is not required to provide notice in advance.

8.3. EXMO may share user information with regulators or authorities if unlawful activity is suspected.

8.4. EXMO may temporarily or permanently freeze Digital Assets in your account in the event of suspected fraud, illegal activity, or regulatory request. EXMO is not liable for any losses incurred during such freezes.

8.5. EXMO reserves the right to monitor IP addresses, device identifiers, browser fingerprints, geolocation data, and other technical information associated with the use of EXMO P2P for fraud prevention, security, and compliance purposes.

Users are prohibited from creating or controlling multiple accounts to circumvent trading limits, evade restrictions, manipulate ratings, or otherwise abuse the Platform.

Where EXMO reasonably determines that multiple accounts are controlled by the same person or group, EXMO may suspend, merge, restrict, or terminate such accounts and freeze related Digital Assets.

9. RISK DISCLOSURE

9.1. Digital Asset prices are volatile. The value of assets may increase or decrease at any time. You are solely responsible for your trading decisions.

9.2. If funds or Digital Assets are transferred incorrectly, fraudulently, or by mistake, EXMO may reverse or recover such amounts where legally and technically permitted.

9.3. By using EXMO P2P, you acknowledge and accept that trading Digital Assets involves risk and that EXMO is not responsible for any indirect, consequential, or punitive damages.

9.4. EXMO is not liable for any losses arising from technical failures, system downtime, API errors, or force majeure events, including natural disasters, internet outages, or government interventions.

10. GOVERNING LAW AND DISPUTE RESOLUTION

10.1. Any disputes relating to these P2P Terms are governed by the dispute resolution provisions set out in the EXMO Terms of Use.

11. TRANSLATIONS

11.1. If this document is translated into other languages, the English version will prevail in the event of inconsistency.