Terms of Service

1. About mbo.finance

mbo.finance Ltd ("mbo.finance", "we", "us", or "our") is a company incorporated and registered in England and Wales (Company Number: [COMPANY NUMBER]) with its registered office at [REGISTERED ADDRESS], United Kingdom.

mbo.finance provides an online platform that enables users to hold multi-currency wallets, send and receive money internationally, convert currencies, purchase and sell cryptocurrency assets, and request physical and virtual payment cards.

mbo.finance is committed to operating in compliance with applicable financial regulations, including Anti-Money Laundering (AML) legislation, Know Your Customer (KYC) requirements, and applicable data protection laws across the jurisdictions in which we operate.

2. Eligibility

To use mbo.finance, you must meet all of the following criteria:

• You are at least 18 years of age (or the age of majority in your jurisdiction, whichever is higher).
• You are a natural person acting on your own behalf, or an authorised representative of a legal entity.
• You are not a resident of, or located in, a country or territory that is subject to international sanctions, including but not limited to those imposed by the United Nations, European Union, United Kingdom, United States, or other applicable authorities.
• You have not been previously banned or removed from using mbo.finance services.
• Your use of the platform does not violate any applicable law or regulation in your jurisdiction.
• You have the legal capacity to enter into a binding agreement.

mbo.finance reserves the right to refuse service to any person or entity at its sole discretion, including where we reasonably believe that providing services would expose us to regulatory, legal, reputational, or financial risk.

Supported Jurisdictions

mbo.finance currently accepts users from the following jurisdictions, subject to local regulatory requirements:

Country	Status	Notes
United Kingdom	✅ Supported	Subject to FCA compliance requirements
Sweden	✅ Supported	Subject to Finansinspektionen requirements and EU regulations
Norway	✅ Supported	Subject to Finanstilsynet requirements and EEA regulations
Germany	✅ Supported	Subject to BaFin requirements and EU regulations
Canada	✅ Supported	Subject to FINTRAC requirements and provincial regulations
Australia	✅ Supported	Subject to AUSTRAC and ASIC requirements
New Zealand	✅ Supported	Subject to DIA and FMA requirements

3. Account Registration

To access our services, you must register for an account. By registering, you confirm that:

• All information you provide is accurate, current, and complete.
• You will maintain the accuracy of your information and promptly update it if it changes.
• You are the sole authorised user of your account.
• You will not share your login credentials with any third party.
• You are responsible for all activity that occurs under your account.

Account Security

You are responsible for maintaining the confidentiality of your password and account credentials. You must notify us immediately at security@mbo.finance if you become aware of any unauthorised access to or use of your account.

mbo.finance offers two-factor authentication (2FA) to enhance account security. We strongly recommend enabling 2FA on your account. 2FA is mandatory for cryptocurrency withdrawals.

mbo.finance will never ask you to disclose your password, verification codes, or any sensitive account credentials by phone, email, or any other means. Any request for such information should be treated as fraudulent and reported to us immediately.

One Account Per Person

Each individual may only hold one personal account on mbo.finance. Creating multiple accounts is prohibited and may result in all accounts being suspended.

4. Identity Verification (KYC / AML)

In accordance with our legal obligations under the Proceeds of Crime Act 2002 (UK), the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (UK), and equivalent legislation in other supported jurisdictions, we are required to verify the identity of all users before enabling full access to our services.

You will be required to provide:

• A valid government-issued photo identification document (passport, national identity card, or driving licence).
• Proof of address dated within the last 3 months (utility bill, bank statement, or official government correspondence).
• In certain circumstances, proof of source of funds or source of wealth.
• A live selfie or video verification as required.

We may request additional documentation at any time in accordance with our ongoing due diligence obligations. Failure to provide requested documentation within the specified timeframe may result in account suspension or termination.

We reserve the right to decline to verify any user or to terminate the verification process at our sole discretion.

5. Our Services

mbo.finance provides the following services, subject to successful identity verification and eligibility requirements:

• Multi-currency wallets: Hold balances in EUR, GBP, USD, AUD, CAD, CHF, JPY, MAD and AED.
• International money transfers: Send money to other mbo.finance users instantly.
• Currency conversion: Convert between supported currencies at live market rates.
• Bank withdrawals: Withdraw funds to bank accounts via SEPA, Faster Payments, ACH, NPP/BSB, and Interac e-Transfer.
• Cryptocurrency services: Purchase, sell, hold and withdraw supported digital assets.
• Payment cards: Virtual and physical Mastercard-branded debit cards (subject to availability).

mbo.finance reserves the right to modify, suspend, or discontinue any service or feature at any time, with reasonable prior notice where practicable.

6. Fees and Charges

Our current fee schedule is as follows:

Service	Fee	Notes
Account opening	Free	No monthly fee
Transfers between mbo.finance accounts	Free	Instant, any supported currency
Currency conversion	Mid-market rate	Small spread may apply on some pairs
SEPA withdrawal (EUR)	Variable	Shown at time of withdrawal
Faster Payments withdrawal (GBP)	Variable	Shown at time of withdrawal
ACH withdrawal (USD)	Variable	Shown at time of withdrawal
NPP/BSB withdrawal (AUD)	Variable	Shown at time of withdrawal
Interac e-Transfer (CAD)	Variable	Shown at time of withdrawal
Crypto purchase / sale	Spread included in price	Live market prices from CoinGecko
Physical card	Subject to issuance	Announced at card launch

All fees are displayed clearly before you confirm any transaction. By confirming a transaction, you agree to pay the applicable fees.

mbo.finance reserves the right to amend its fee schedule at any time. We will provide at least 30 days' notice of any fee increases, except where required by law to implement changes immediately.

7. Sending and Receiving Money

mbo.finance facilitates the transfer of funds between accounts held on our platform. Transfers between mbo.finance accounts are executed in real time.

When sending money, you agree that:

• You are the lawful owner of the funds being transferred or are authorised to transfer them.
• The transfer does not constitute money laundering, terrorist financing, or any other illegal activity.
• The recipient's details you provide are accurate. mbo.finance is not responsible for funds sent to incorrect accounts due to user error.
• Transfers are generally irreversible once confirmed. If you believe you have made an error, contact support@mbo.finance immediately.

mbo.finance reserves the right to delay, block, or reverse any transfer where we have reasonable grounds to suspect it may be connected to fraud, money laundering, or other financial crime.

8. Currency Conversion

Currency conversion rates are determined at the time of conversion using live mid-market rates sourced from reputable financial data providers. The rate applied to your transaction will be displayed before you confirm the conversion.

Due to the volatile nature of currency markets, exchange rates may fluctuate. mbo.finance does not guarantee any particular exchange rate or the availability of any particular currency pair at any time.

You acknowledge that currency conversion involves exchange rate risk and that the value of currencies may increase or decrease between the time you request a conversion and the time it is executed.

9. Withdrawals

You may withdraw funds from your mbo.finance account to a verified bank account in your name. Third-party withdrawals are not permitted.

Withdrawal requests are subject to:

• Successful identity verification (KYC).
• Compliance checks, which may cause delays.
• Network processing times, which vary by payment method and destination country.
• Any applicable fees as disclosed at the time of withdrawal.

mbo.finance reserves the right to delay or decline withdrawal requests where required by law, compliance obligations, or where we have reasonable grounds to suspect fraudulent activity.

Estimated processing times are provided for guidance only and are not guaranteed.

10. Cryptocurrency Services

mbo.finance facilitates the purchase, sale, holding, and withdrawal of the following cryptocurrency assets: Bitcoin (BTC), Ethereum (ETH), Tether (USDT), and Solana (SOL).

By using our cryptocurrency services, you acknowledge and agree that:

• Cryptocurrency transactions are generally irreversible once broadcast to the relevant blockchain network.
• Cryptocurrency withdrawal addresses must be verified carefully. mbo.finance cannot recover funds sent to incorrect addresses.
• Cryptocurrency services are subject to additional regulatory requirements and may be restricted or unavailable in certain jurisdictions.
• Cryptocurrency prices displayed are sourced from CoinGecko and may differ from prices on other exchanges.
• mbo.finance does not provide investment advice in relation to cryptocurrency or any other asset.
• KYC verification and two-factor authentication are mandatory for all cryptocurrency withdrawals.

Jurisdiction-Specific Cryptocurrency Restrictions

Country	Restrictions
United Kingdom	Crypto promotions subject to FCA financial promotions regime from October 2023
Germany	Crypto services subject to BaFin oversight; additional AML requirements apply
Canada	Subject to FINTRAC registration requirements for money services businesses dealing in virtual currencies
Australia	Subject to AUSTRAC registration and Digital Currency Exchange requirements
New Zealand	Subject to DIA registration as a virtual asset service provider
Sweden / Norway	Subject to EU/EEA MiCA regulations as they come into force

11. Payment Cards

mbo.finance offers physical and virtual Mastercard-branded payment cards to eligible users. Card services are subject to:

• Successful identity verification and KYC approval.
• A minimum account balance of EUR 500 equivalent (for physical cards).
• Availability in your jurisdiction.
• Acceptance of any additional card-specific terms presented at the time of application.

Cards are issued in partnership with licensed card issuers and are subject to the card issuer's terms and conditions in addition to these Terms of Service. Cards are linked to your mbo.finance EUR wallet and transactions will be deducted from your available balance.

mbo.finance reserves the right to cancel or suspend card services at any time, including where required by the card network or card issuer.

12. Prohibited Activities

You must not use mbo.finance for any of the following purposes:

• Money laundering, terrorist financing, or any activity that constitutes a financial crime under applicable law.
• Funding, supporting, or facilitating any activity prohibited under applicable sanctions regimes.
• Fraud, including but not limited to identity fraud, account takeover fraud, or payment fraud.
• Purchasing illegal goods or services, including controlled substances, weapons, or prohibited content.
• Operating a money services business or payment processing business through your personal mbo.finance account without our prior written consent.
• Circumventing, disabling, or otherwise interfering with security features of the platform.
• Attempting to reverse-engineer, decompile, or extract source code from our platform.
• Engaging in market manipulation or any conduct that distorts the price of cryptocurrency assets.
• Creating multiple accounts or using another person's account.
• Providing false or misleading information to mbo.finance at any time.
• Using our platform in a manner that could damage, disable, overburden, or impair our systems.
• Violating any applicable law, regulation, or rule in your jurisdiction.

Violation of these prohibitions may result in immediate account suspension, asset freezing, reporting to relevant authorities, and civil or criminal liability.

13. Anti-Money Laundering and Compliance

mbo.finance is committed to full compliance with applicable anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions regulations across all jurisdictions in which we operate. This includes but is not limited to:

• United Kingdom: Proceeds of Crime Act 2002, Terrorism Act 2000, Money Laundering Regulations 2017, and regulations made pursuant to the Sanctions and Anti-Money Laundering Act 2018.
• European Union / EEA (Sweden, Norway, Germany): EU Fourth and Fifth AML Directives, EU Funds Transfer Regulation, and applicable national implementing legislation.
• Canada: Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC reporting requirements.
• Australia: Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and AUSTRAC requirements.
• New Zealand: Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act).

In furtherance of our compliance obligations, we may:

• Monitor transactions for suspicious activity.
• Request additional documentation or information at any time.
• Delay, block, or reverse transactions that trigger compliance alerts.
• Report suspicious activity to relevant financial intelligence units, including the National Crime Agency (UK), FINTRAC (Canada), AUSTRAC (Australia), DIA (New Zealand), and equivalent bodies in other jurisdictions.
• Cooperate with law enforcement and regulatory authorities in investigations.
• Freeze or terminate accounts where required by law or court order.

We are prohibited by law from disclosing to you whether a suspicious activity report has been made in relation to your account (the "tipping off" prohibition).

14. Account Suspension, Investigation and Fund Holds

mbo.finance may suspend, restrict, or terminate your account at any time, with or without notice, where:

• We have reasonable grounds to believe you have violated these Terms of Service.
• We are required to do so by applicable law, regulation, or court order.
• We reasonably suspect your account has been compromised or is being used fraudulently.
• You have provided false or misleading information to us.
• Your account has been inactive for an extended period.
• Continuing to provide services to you would expose mbo.finance to unacceptable legal, regulatory, or reputational risk.
• We receive instruction from a competent authority, law enforcement agency, or financial regulator to do so.

Where your account is suspended, we will use reasonable endeavours to notify you of the reason, unless we are prohibited from doing so by applicable law (including the "tipping off" provisions of AML legislation). You may appeal a suspension by contacting compliance@mbo.finance.

14.1 Right to Investigate and Hold Funds

mbo.finance has the absolute right to suspend your account and place all associated funds on hold where we have reasonable grounds to suspect, or are required by law to investigate, any of the following:

• Money laundering, terrorist financing, or any other financial crime.
• Fraud, including but not limited to identity fraud, payment fraud, or account takeover.
• Violation of applicable sanctions regulations.
• Tax evasion or other fiscal offences.
• Breach of these Terms of Service.
• Any activity that triggers our automated AML monitoring systems.
• A request or direction from a competent regulatory, judicial, or law enforcement authority.

14.2 Duration of Investigation Holds

An investigation hold may be placed on your account and associated funds for the duration reasonably necessary to complete the investigation, subject to the following terms:

• Standard investigations will be completed within 90 days of the hold being placed, where practicable.
• Complex investigations — including those involving cooperation with law enforcement, regulatory bodies, or international authorities — may extend beyond 90 days. In such cases, we will use reasonable endeavours to provide you with updates every 30 days, unless prohibited by applicable law.
• Maximum hold period: Subject to applicable legal requirements, court orders, or regulatory directions, mbo.finance will not maintain an investigation hold on your funds for more than 12 months (one calendar year) from the date the hold was initially placed, without either: (a) providing you with a substantiated reason for continuing the hold; (b) receiving a formal direction from a competent authority to maintain the hold; or (c) initiating formal legal proceedings in relation to the matter under investigation.
• Automatic release: Where a hold has been in place for 12 months and none of the conditions in the preceding paragraph are satisfied, your funds will be automatically reviewed for release. You will be contacted at your registered email address to arrange the return of your funds, subject to any applicable compliance checks and deduction of any amounts lawfully owed to mbo.finance.

14.3 Your Rights During an Investigation Hold

During any investigation hold period, you retain the following rights:

• The right to be notified that a hold has been placed, to the extent permitted by law.
• The right to submit documentation or information in support of your position to compliance@mbo.finance.
• The right to seek independent legal advice at your own expense.
• The right to request a review of the hold by contacting compliance@mbo.finance after 30 days, if you believe the hold is unjustified.
• The right to refer the matter to the relevant financial regulator or ombudsman in your jurisdiction where you believe the hold is unlawful (see Section 17 for jurisdiction-specific contacts).

mbo.finance will cooperate in good faith with any regulatory or ombudsman investigation into the appropriateness of a fund hold.

14.4 Priority of Law

Nothing in this Section limits or overrides the obligations or powers of mbo.finance under applicable law. Where a court order, regulatory direction, or mandatory legal obligation requires mbo.finance to maintain a hold beyond the periods described above, such legal obligation shall take precedence. In such circumstances, mbo.finance will use reasonable endeavours to notify you of the existence of such a legal requirement, unless prohibited by law from doing so.

14.5 Account Termination and Fund Return

Upon account termination (where not related to an investigation hold), you will have a reasonable opportunity to withdraw your funds, subject to applicable compliance checks, provided such withdrawal is not prohibited by law or court order. mbo.finance will process approved fund returns within 14 business days of account closure confirmation.

15. Limitation of Liability

To the maximum extent permitted by applicable law, mbo.finance, its directors, officers, employees, agents, and affiliates shall not be liable for:

• Any indirect, incidental, special, consequential, or punitive damages.
• Loss of profits, revenue, data, goodwill, or other intangible losses.
• Losses arising from your use of, or inability to use, our services.
• Losses arising from unauthorised access to or alteration of your account, where such access resulted from your failure to maintain adequate security.
• Losses arising from third-party actions, including fraud, hacking, or other malicious acts.
• Losses arising from fluctuations in exchange rates or cryptocurrency prices.
• Any loss caused by our compliance with applicable law or regulatory requirements.

Our total aggregate liability to you for any claim arising from or in connection with these Terms of Service shall not exceed the greater of: (a) the fees you paid to mbo.finance in the 12 months preceding the claim; or (b) EUR 100.

Nothing in these Terms of Service shall exclude or limit liability that cannot be excluded by applicable law, including liability for death or personal injury caused by negligence, or for fraud or fraudulent misrepresentation.

Consumer Rights

If you are a consumer resident in the United Kingdom, your statutory rights under the Consumer Rights Act 2015 and related consumer protection legislation are not affected by these terms. Similar protections apply in other jurisdictions where mandatory consumer protection laws apply.

16. Intellectual Property

All intellectual property rights in the mbo.finance platform, including but not limited to software, design, branding, trademarks, logos, and content, are owned by or licensed to mbo.finance Ltd. Nothing in these Terms of Service grants you any right, title, or interest in our intellectual property.

You are granted a limited, non-exclusive, non-transferable, revocable licence to access and use the mbo.finance platform solely for your personal use in accordance with these Terms of Service.

17. Jurisdiction-Specific Terms

United Kingdom

mbo.finance Ltd is incorporated in England and Wales. Users in the United Kingdom are subject to the FCA's Consumer Duty rules. We are committed to delivering good outcomes for retail customers, acting in good faith, avoiding foreseeable harm, and enabling customers to pursue their financial objectives. Complaints may be referred to the Financial Ombudsman Service (FOS) where applicable.

Sweden and Norway

Users in Sweden and Norway benefit from the protections afforded by EU/EEA consumer protection legislation. Swedish users may contact Konsumentverket (Swedish Consumer Agency) and Norwegian users may contact Forbrukertilsynet (Norwegian Consumer Authority) for consumer disputes. Our services in these jurisdictions comply with applicable EU regulations including PSD2 and relevant AML directives.

Germany

Users in Germany benefit from the protections of the German Civil Code (BGB), the German Payment Services Supervision Act (ZAG), and applicable consumer protection regulations. The EU right to an out-of-court redress procedure applies. The Verbraucherzentrale (consumer advice centres) may assist German users with disputes.

Canada

mbo.finance operates as a Money Services Business (MSB) in Canada and complies with obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Canadian users may contact the Financial Consumer Agency of Canada (FCAC) for information on their rights. Provincial regulations may apply in addition to federal requirements.

Australia

mbo.finance complies with the Australian Consumer Law (ACL) contained in Schedule 2 of the Competition and Consumer Act 2010. Australian users have statutory guarantees under the ACL that cannot be excluded. We are registered with AUSTRAC as a Digital Currency Exchange Provider. Complaints may be referred to the Australian Financial Complaints Authority (AFCA).

New Zealand

mbo.finance complies with the Consumer Guarantees Act 1993, the Fair Trading Act 1986, and the Privacy Act 2020 in New Zealand. We are registered with the Department of Internal Affairs (DIA) as a reporting entity under the AML/CFT Act 2009. New Zealand users may contact the Financial Markets Authority (FMA) or Commerce Commission for consumer disputes.

18. Governing Law and Dispute Resolution

These Terms of Service are governed by and construed in accordance with the laws of England and Wales, without regard to its conflict of law principles.

Any dispute arising from or in connection with these Terms of Service shall be subject to the exclusive jurisdiction of the courts of England and Wales, except where:

• Mandatory consumer protection laws in your jurisdiction of residence require disputes to be resolved locally.
• You elect to pursue an alternative dispute resolution mechanism available in your jurisdiction.

Before initiating formal legal proceedings, we encourage you to contact us at support@mbo.finance to seek an amicable resolution.

Alternative Dispute Resolution

UK consumers may refer unresolved complaints to the Financial Ombudsman Service (FOS). EU/EEA consumers may use the European Commission's Online Dispute Resolution (ODR) platform at ec.europa.eu/consumers/odr. Australian consumers may refer complaints to the Australian Financial Complaints Authority (AFCA) at afca.org.au.

19. Changes to These Terms

mbo.finance reserves the right to amend these Terms of Service at any time. We will provide at least 30 days' notice of material changes by:

• Sending an email to your registered email address.
• Displaying a prominent notice on our platform.
• Updating the "Last Updated" date at the top of this page.

Your continued use of mbo.finance after the effective date of any changes constitutes your acceptance of the revised terms. If you do not agree to the changes, you must stop using our services and close your account before the effective date.

20. Contact Us

If you have any questions about these Terms of Service, please contact us:

Department	Email	Purpose
General Support	support@mbo.finance	Account queries, general assistance
Compliance	compliance@mbo.finance	AML, KYC, regulatory matters
Security	security@mbo.finance	Security concerns, suspicious activity
Legal	legal@mbo.finance	Legal notices, formal correspondence

mbo.finance Ltd
[Registered Address]
United Kingdom