1. Introduction and Scope
These Legal Terms (“Terms”) govern the relationship between TFG and any institutional client, partner, counterparty, or user (collectively, “you” or “Client”) accessing or using any product, service, or platform operated by TFG, including digital-asset lending, custody, settlement, and financial infrastructure services (the “Services”).
By engaging with TFG, you agree to comply with these Terms and all applicable laws and regulations.
These Terms do not constitute an offer to the public. TFG provides services only to professional or institutional clients who have completed TFG’s onboarding process.
2. Relationship with Tether and Other Third Parties
TFG operates independently and is not the issuer, redeemer, or controller of Tether tokens (including USDt or XAUt).
All matters concerning the issuance, ownership, redemption, transfer, or use of Tether tokens are governed exclusively by the Tether Terms of Service, available at https://tether.to/en/legal.
By engaging in any transaction, holding, or activity involving USDt or XAUt through or in connection with TFG, each Client expressly acknowledges and agrees to comply with all applicable provisions of the Tether Terms, as amended from time to time.
TFG does not guarantee, endorse, or assume any responsibility or liability for the performance, redemption, solvency, or value of any Tether token, or for any obligations of Tether or other third-party service providers.
Any reference to Tether, USDt, or XAUt within TFG materials is made solely for operational, informational, or settlement purposes and does not imply any affiliation, partnership, or representation of Tether by TFG.
3. Eligibility, Compliance, and Prohibited Use
You may not access or use TFG Services if:
- You are a Prohibited Person as defined below;
- You are located in, a citizen of, or operating from a Prohibited Jurisdiction; or
- Your use of the Services would violate any applicable law, regulation, or sanction program.
3.1 Prohibited Persons
- Appear on any sanctions or watch list issued by the United Nations, the European Union, the United States (OFAC), the UK (HMT), or other competent authorities;
- Have been convicted or are under investigation for financial crimes, terrorism financing, or corruption;
- Act as an intermediary for, or on behalf of, any sanctioned or prohibited entity or individual;
- Are resident or organized in a jurisdiction classified as high-risk or under FATF countermeasures.
3.2 Prohibited Jurisdictions
TFG does not provide Services to residents, nationals, or entities established in the following jurisdictions (the “Prohibited Jurisdictions”):
Afghanistan, Belarus, Burundi, Central African Republic, Democratic Republic of Congo, Cuba, Iran, Iraq, Libya, Mali, Myanmar (Burma), Nicaragua, North Korea, Russia, Somalia, South Sudan, Sudan, Syria, Venezuela, Yemen, Zimbabwe, and any other country subject to comprehensive international sanctions.
Any other jurisdiction where TFG is not legally authorized to operate. TFG reserves the right to update this list at any time without prior notice.
3.3 Compliance and Monitoring
TFG applies international AML/CFT and Sanctions compliance standards in accordance with FATF Recommendations and Salvadoran law. TFG conducts ongoing due diligence, transaction monitoring, and blockchain analytics. We may request additional information or documentation at any time, and you agree to cooperate promptly.
4. Use of Services and Risk Disclosure
TFG Services may involve blockchain-based assets, tokens, or distributed ledger systems. You acknowledge and accept the inherent risks of using digital assets, including:
- Volatility and potential loss of value;
- Irreversibility of blockchain transactions;
- Technological vulnerabilities or failures;
- Regulatory or policy changes that may affect asset treatment.
TFG does not guarantee the stability, liquidity, or redemption of any token or asset, and provides all Services on an “as is” and “as available” basis.
5. No Offer or Advice
Nothing on TFG’s website or in any communication from TFG constitutes an offer, solicitation, or recommendation to buy, sell, or hold any financial product. TFG does not provide investment, legal, or tax advice. Clients are solely responsible for their investment and operational decisions.
6. Limitation of Liability
To the fullest extent permitted by law, TFG and its affiliates, directors, officers, and employees shall not be liable for any indirect, consequential, incidental, special, or punitive damages arising from or related to the use or inability to use the Services.
TFG’s total liability, if any, shall not exceed the amount of fees paid by the Client to TFG in the twelve (12) months preceding the event giving rise to the claim.
7. Indemnification
You agree to indemnify, defend, and hold harmless TFG and its affiliates from any losses, claims, or liabilities (including legal fees) resulting from your violation of these Terms, your breach of applicable law, or your use of the Services in connection with prohibited conduct or jurisdictions.
8. Confidentiality and Data Protection
TFG processes personal and corporate data in accordance with applicable data protection laws, including the GDPR and the Law on Personal Data Protection of El Salvador. Information may be shared with regulatory authorities, auditors, or service providers on a confidential basis as required by law or compliance obligations.
9. Amendments
TFG may amend or update these Terms at any time by publishing the revised version on turingfig.com/legal. Your continued use of TFG’s Services after such publication constitutes acceptance of the updated Terms.
10. Governing Law and Dispute Resolution
These Terms shall be governed by and construed in accordance with the laws of England and Wales. Any dispute shall be resolved by arbitration under the London Court of International Arbitration (LCIA) Rules, with three arbitrators seated in London, and proceedings conducted in English. TFG may, at its sole discretion, seek injunctive or interim relief in any competent court.