Terms of Service

These Terms of Service ("Terms") govern your use of the Monay platform and services provided by Utilli, LLC (dba Tilli) ("Company", "we", "us", or "our"), including but not limited to Monay ID (identity and authentication services), Monay CaaS (Coin-as-a-Service), and Monay WaaS (Wallet-as-a-Service). By accessing or using our services, you acknowledge that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, Anti-Money Laundering Policy, and all applicable laws and regulations.

1. Acceptance of Terms and Eligibility

By accessing and using the Monay platform, you represent and warrant that:

• You are at least 18 years of age (or the age of majority in your jurisdiction)
• You have the legal capacity to enter into these Terms
• You are not located in, under the control of, or a national or resident of any country subject to U.S. embargo or listed on any U.S. government list of prohibited or restricted parties
• You will comply with all applicable laws and regulations in your use of the services
• If acting on behalf of an entity, you have all necessary authority to bind that entity to these Terms

2. Description of Services

Monay provides a comprehensive dual-rail blockchain financial services platform comprising:

2.1 Monay ID (Identity Services)

• Voice-powered biometric authentication with military-grade encryption
• Non-custodial identity management with custodian recovery options
• Multi-factor authentication and device management
• Compliance with NIST 800-63-3 authentication standards
• GDPR and CCPA compliant data handling

2.2 Monay CaaS (Coin-as-a-Service)

• Enterprise-grade stablecoin issuance on dual-rail blockchain (Base EVM L2 + Solana)
• ERC-3643 compliant token deployment with built-in compliance controls
• Treasury management and cross-rail atomic swaps
• Real-time supply tracking and regulatory reporting
• Multi-signature wallet controls and audit trails
• Integration with Business Rules Framework (BRF) for policy enforcement

2.3 Monay WaaS (Wallet-as-a-Service)

• White-label digital wallet infrastructure with customizable branding
• Virtual and physical card issuance (Visa/Mastercard)
• Cardless ATM access via QR/NFC with AllPoint network
• ACH, wire, and instant payment processing
• Apple Pay, Google Pay, and Samsung Pay integration
• POS transaction processing with MCC filtering
• Cross-border remittance and FX services

3. User Accounts and Registration

To access certain features of our services, you must register for an account. You agree to:

• Provide accurate, current, and complete information
• Maintain and promptly update your account information
• Maintain the security of your account credentials
• Accept responsibility for all activities under your account
• Notify us immediately of any unauthorized use

4. Acceptable Use Policy

You agree not to use our services to:

• Violate any applicable laws or regulations
• Engage in money laundering, terrorist financing, or other illicit activities
• Infringe upon intellectual property rights
• Transmit malicious code or interfere with platform security
• Engage in fraudulent or deceptive practices
• Harass, abuse, or harm other users
• Circumvent any access restrictions or security measures

5. Regulatory Compliance and KYC/AML/OFAC

5.1 Know Your Customer (KYC) Requirements

You acknowledge and agree that:

• We are required by law to verify your identity before providing certain services
• You must provide accurate and complete information including but not limited to: full legal name, date of birth, residential address, government-issued ID, and tax identification number
• For business accounts: corporate documents, beneficial ownership information, and business licenses as required
• We may use third-party services (Persona, Alloy, Onfido) for identity verification
• You consent to periodic re-verification of your identity information

5.2 Anti-Money Laundering (AML) Compliance

In accordance with the Bank Secrecy Act and USA PATRIOT Act:

• We maintain a comprehensive AML program including customer due diligence, transaction monitoring, and suspicious activity reporting
• We will file Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) as required by law
• You agree not to use our services for money laundering, terrorist financing, or any other illicit financial activities
• We reserve the right to delay, freeze, or refuse transactions that raise AML concerns
• You may be required to provide additional information about the source of funds and purpose of transactions

5.3 OFAC and Sanctions Compliance

You represent and warrant that:

• You are not on any U.S. government sanctions list including the OFAC Specially Designated Nationals (SDN) list
• You are not located in or a resident of any sanctioned country (including but not limited to Cuba, Iran, North Korea, Syria, and the Crimea region)
• You will not use our services to transact with sanctioned individuals or entities
• We screen all users and transactions against OFAC and other sanctions lists
• We will block and report any attempted transactions involving sanctioned parties

5.4 Transaction Monitoring and Reporting

• All transactions are subject to real-time monitoring for suspicious patterns
• We employ machine learning and rule-based systems for fraud detection
• Transactions may be delayed or blocked pending compliance review
• We maintain records of all transactions for the period required by law (minimum 5 years)
• You consent to the sharing of your information with law enforcement when legally required

6. Risk Disclosures for Digital Assets

7. Fees and Payment

Our fee structure is outlined on our pricing page and includes:

• Monthly subscription fees based on usage tiers
• Transaction fees for payment processing
• Additional fees for premium features

All fees are subject to change with 30 days' notice. You authorize us to charge your designated payment method for all applicable fees.

8. Transaction Limits and Velocity Controls

To ensure security and regulatory compliance, we enforce the following limits:

• Daily transaction limits based on account tier and verification level
• Monthly aggregate limits for transfers and withdrawals
• Velocity checks to prevent rapid successive transactions
• Geographic restrictions for certain transaction types
• Enhanced due diligence for transactions exceeding $10,000
• Automatic holds on unusual transaction patterns pending review

9. Intellectual Property

All content, features, and functionality of the Monay platform, including but not limited to text, graphics, logos, icons, images, audio clips, digital downloads, data compilations, and software, are the exclusive property of Utilli, LLC or its licensors and are protected by international copyright, trademark, patent, trade secret, and other intellectual property laws.

10. Data Privacy and Security

Your use of our services is also governed by our Privacy Policy. We implement industry-standard security measures including:

• AES-256 encryption for data at rest and in transit
• Hardware Security Module (HSM) key management
• PCI-DSS compliance for payment processing
• SOC2 Type II certification

11. Prohibited Activities

In addition to the Acceptable Use Policy, you specifically agree not to:

• Engage in any form of market manipulation, wash trading, or artificial volume generation
• Use the services for illegal gambling, Ponzi schemes, or pyramid schemes
• Facilitate human trafficking, slavery, or forced labor in any form
• Trade in or finance illegal weapons, drugs, or contraband
• Evade taxes or assist others in tax evasion
• Engage in bribery, corruption, or facilitation payments
• Use the services to finance terrorism or violent extremism
• Violate export controls or trade sanctions
• Engage in predatory lending or usurious practices
• Create multiple accounts to circumvent limits or restrictions

12. Disclaimer of Warranties

THE SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

13. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, UTILLI, LLC SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS OR REVENUES, WHETHER INCURRED DIRECTLY OR INDIRECTLY, OR ANY LOSS OF DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES.

14. Indemnification

You agree to indemnify, defend, and hold harmless Utilli, LLC, its officers, directors, employees, agents, and affiliates from and against any claims, liabilities, damages, losses, and expenses, including reasonable attorney's fees, arising out of or in any way connected with your access to or use of the services.

15. Account Termination and Suspension

We may terminate or suspend your account and access to the services immediately, without prior notice or liability, for any reason, including but not limited to breach of these Terms. Upon termination, your right to use the services will cease immediately.

16. Dispute Resolution and Arbitration

PLEASE READ THIS SECTION CAREFULLY - IT AFFECTS YOUR LEGAL RIGHTS

• Any dispute arising from these Terms shall first be subject to good faith negotiations for 30 days
• If unresolved, disputes shall be settled by binding arbitration under JAMS rules
• Arbitration shall be conducted in Montgomery County, Maryland with one arbitrator
• You waive any right to a jury trial or class action lawsuit
• Small claims court actions may be brought in your local jurisdiction for disputes under $10,000
• Injunctive relief may be sought in court for intellectual property violations

17. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of the State of Maryland, United States, without regard to its conflict of law provisions. Any legal action or proceeding arising under these Terms will be brought exclusively in the federal or state courts located in Montgomery County, Maryland.

18. Electronic Communications and Signatures

By using our services, you consent to:

• Receive all communications from us electronically
• Electronic signatures being legally binding and enforceable
• Electronic records satisfying any legal requirement for written documentation
• Receiving notices via email or through your account dashboard

19. Force Majeure

We shall not be liable for any failure or delay in performance due to circumstances beyond our reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, riots, embargoes, acts of civil or military authorities, fire, floods, pandemic, accidents, network infrastructure failures, strikes, or shortages of transportation facilities, fuel, energy, labor, or materials.

20. Changes to Terms

We reserve the right to modify these Terms at any time. We will provide notice of material changes by posting the updated Terms on our website and updating the "Last Updated" date. Your continued use of the services after such modifications constitutes your acceptance of the updated Terms.

21. Severability and Waiver

If any provision of these Terms is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that these Terms shall otherwise remain in full force and effect. Our failure to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision.

22. Entire Agreement

These Terms, together with our Privacy Policy, Anti-Money Laundering Policy, and any other policies referenced herein, constitute the entire agreement between you and Utilli, LLC regarding the use of the Monay platform and supersede all prior agreements and understandings.

23. Contact Information

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