Risk Disclosure – EMT Minting & Redemption Service

Last updated: 18 May 2026

Investing and trading in crypto assets involves risk. This Risk Disclosure summarises the key risks associated with the crypto-asset services provided by ClearBank Europe N.V. (ClearBank Europe, we, us). It is not exhaustive and you should carry out your own assessment before purchasing or trading crypto assets.

We provide minting and redemption of EURC and USDC (the Service) to regulated financial institutions only (you, client).

This disclosure is intended for regulated financial institutions. It does not replace or override your contract with us. If there is any inconsistency, the contract prevails.

If applicable, you are responsible for informing your clients of these risks if they intend to invest or trade in crypto assets.

As part of the Services, in relation to crypto-assets, we: 

• Receive and transmit orders;
• Execute orders; and 
• Provide transfer services. 

The Service relies on the following operating chain:

• ClearBank Europe: responsible for client onboarding, order execution, transfer services, AML/CTF controls and regulatory compliance;
• Circle Internet Financial Europe SAS, a regulated e‑money token issuer: responsible for minting and burning EURC and USDC under its own regulatory framework;
• Specialist technology and infrastructure providers: support wallet infrastructure, transaction execution and operational resilience; and
• ClearBank Group: provides operational and technology support to us.

ClearBank Europe retains full regulatory responsibility for the crypto-asset services we provide. However, outages, disruptions or restrictions affecting any part of the service chain may impact availability and timing.

A. Token and issuer risks (EURC/USDC)

EURC and USDC are designed to track their reference currency, but may not maintain par in all conditions.

• EURC/USDC are issued and redeemed by a third-party issuer (not ClearBank Europe). Issuer operational, financial or regulatory issues may delay, suspend or restrict minting/redemption.
• Issuance, governance and backing may be affected by legal/regulatory actions in multiple jurisdictions (including non-EU regimes), which may impact transferability, redemption or value.
• Secondary-market prices may deviate temporarily from par due to liquidity constraints, network congestion or market stress.

B. Execution, operational, cyber and fraud risks

• Delays and outages: Execution/settlement depend on payment rails, blockchain confirmation times and third-party platforms; outages, cyber incidents or operational failures may suspend processing.
• Irreversibility: Blockchain transfers are irreversible; you are responsible for correct wallet addresses and network selection.
• Cyber, hacking and technical issues: Crypto-assets and supporting infrastructure may be vulnerable to hacking, system failures or other technical issues, resulting in loss, delay or restrictions on use or transfer.
• Wallet access: Loss of a recovery/mnemonic phrase may permanently prevent access to crypto-assets.
• Fraud and scams: Phishing, spoofing and scams may cause irreversible loss; transfers to unknown wallets may be unrecoverable.

C. Financial crime controls, third-party dependency and legal/regulatory risk

ClearBank Europe applies AML/CTF, sanctions and blockchain analytics controls. This may result in delays, rejections or suspensions, temporary restrictions while checks are performed, and reporting to competent authorities where required.

The Service relies on intragroup and third-party providers. Failures, outages or concentration risk in these arrangements may affect service continuity.

Crypto-asset laws, supervisory expectations and technical standards may change. This may require service changes, impose jurisdictional restrictions, or lead to suspension or termination of services.

D. Pricing and fees

Fees are set out in your contract. You may also incur issuer, network and third-party wallet/settlement fees. ClearBank Europe does not set EMT prices.

ClearBank Europe does not maintain insurance that specifically compensates clients for crypto-asset losses. This reflects the non-custodial, execution and transfer nature of the EMT Minting & Redemption Service.