1. Introduction
These Terms of Service apply to trading and liquidity services provided by Trillion Capital Markets AG ("Trillion Digital," "we," "us," or "our"). They apply to the Swiss entity only. Services provided by Trillion Capital Markets Inc. are subject to its separate U.S. Terms of Service.
Trillion Digital provides services exclusively to approved counterparties who have entered into a signed Master Trade Agreement with Trillion Capital Markets AG. Accessing the Website does not establish a counterparty relationship or constitute acceptance of a trading agreement. Website use is governed separately by the Website Terms & Conditions.
Before becoming an approved counterparty, you must complete our onboarding process, including satisfactory counterparty due diligence and Know Your Customer/Anti-Money Laundering ("KYC/AML") checks. Approval remains subject to ongoing compliance requirements.
Trillion Digital operates as a dealer, counterparty, and liquidity provider in over-the-counter digital asset markets where such activities are permissible. We engage in price discovery, price quoting, order taking, and trade execution. Unless expressly agreed otherwise in writing and permitted by applicable law, we act as principal for our own account, not as your agent, fiduciary, or financial advisor. Our interests may differ from yours, as described in Section 4.
These terms supplement your Master Trade Agreement and the terms agreed for each transaction. Your signed agreement determines the services available to you and the contractual order of precedence; these Terms of Service do not override that agreement or mandatory law. Neither these terms nor a private agreement excludes duties or rights that cannot lawfully be excluded.
Nothing in this document constitutes an offer, solicitation, or recommendation in a jurisdiction where it is prohibited. Service availability depends on the activity, asset, counterparty, and jurisdiction involved.
2. Intended Audience
Our communications and services are intended for approved counterparties with professional experience in digital asset transactions who can assess their terms and risks. They are not intended for retail clients. You are responsible for obtaining independent legal, accounting, and financial advice where needed.
This description of our intended audience does not itself classify you as a professional or institutional client under the Swiss Financial Services Act (FinSA). Where a statutory client classification or other eligibility requirement applies, it must be assessed and documented separately. Experience or acceptance of these terms does not waive mandatory protections.
3. No Investment Advice
Unless expressly agreed otherwise in writing and permitted by applicable law, Trillion Digital does not provide investment advice. You make your own investment decisions and are responsible for understanding the risks associated with trading digital assets. This allocation of responsibility does not exclude any information, conduct, or other duty imposed by mandatory law.
4. Conflicts of Interest
Unless explicitly agreed otherwise and permitted by applicable law, Trillion Digital acts as principal in transactions with counterparties and does not act as an agent. As a liquidity provider, we manage positions involving counterparties with competing interests and engage in proprietary trading activities.
Where permitted by applicable law and the agreed terms, we may trade before or alongside a counterparty transaction to manage risk, source liquidity, or facilitate execution. This may include pre-hedging and may affect pricing and liquidity. This disclosure does not authorize conduct prohibited by law or displace applicable confidentiality, conflict-management, or market conduct obligations.
We maintain policies and procedures designed to manage potential conflicts of interest, treat counterparties fairly, and execute transactions in accordance with agreed terms and applicable law.
5. Pricing, Execution, and Order Internalization
Digital assets can be highly volatile and lack a centralized pricing authority. Our quotes take market conditions and other relevant factors into account. For principal OTC transactions, the transaction price is the price agreed with you; we do not make a general promise that it is the best price available across all venues.
Where permitted by applicable law and the agreed terms, transactions may be executed against our own positions or through internalization of counterparty interest on an OTC basis. Any best-execution or other execution duties that apply by law or agreement remain in force and are not waived by these terms.
6. No Offer of Securities
This document is not an offer to sell or a solicitation to buy securities or other financial instruments. It does not determine an asset's legal classification. An asset or service that requires additional authorization or compliance measures may be offered only when the applicable requirements are met; SRO membership alone does not satisfy those requirements.
7. Risks Associated with Digital Assets
Trading digital assets involves significant risks, including substantial or total financial loss. Prices can fluctuate sharply. You should consider your financial circumstances and the risks of the relevant asset and transaction before trading. Review our Risks & Disclosures for further information.
VQF membership does not provide deposit insurance, a guarantee of your assets, or protection from trading losses. It is not an endorsement of a transaction or investment by VQF or FINMA.
8. Amendments
Updates to these terms will be published on the Website. Their application to an existing relationship is subject to the amendment and notice provisions of your Master Trade Agreement and applicable law. Publication alone does not override your signed agreement or retroactively change the agreed terms of an executed transaction.
9. Swiss Regulatory Framework and Due Diligence
Trillion Capital Markets AG is a member of VQF, a self-regulatory organisation recognised by FINMA, under member number 101081. VQF supervises members' compliance with the Swiss Anti-Money Laundering Act (AMLA) and its SRO regulations. This membership is not a FINMA banking or securities firm licence and does not amount to prudential supervision of AG by FINMA.
You must provide accurate, current information requested for due diligence, including identity, beneficial ownership, authority to act, source of funds, transaction purpose, and transfer or wallet information. Additional checks may be required during the relationship. We may decline or delay onboarding or transactions while required checks remain incomplete, subject to applicable law.
Statutory reporting, record-retention, asset-freezing, and restrictions on disclosure take precedence over inconsistent instructions or contractual terms. Information may be provided to competent authorities, VQF, or auditors as required or permitted by law. We may be legally prohibited from informing you of a report or related measures. Termination and handling of affected assets remain subject to the applicable legal requirements.
Contact Information
Questions about these terms or your contracting entity can be sent to compliance@trilliondigital.io.