USD PARITY (USD.PA)

I.01 – Date of notification
I.02 – Statement in accordance with Article 51(3) of Regulation (EU) 2023/1114
I.03 – Compliance statement in accordance with Article 51(5) of Regulation (EU) 2023/1114
I.04 – Warning in Warning in accordance with Article 51(4), points (a) and (b), of Regulation (EU) 2023/1114accordance with Article 51(4)

SUMMARY
I.05 – Warning in accordance with Article 51(6), second subparagraph of Regulation (EU) 2023/1114
I.06 – Characteristics of the crypto-asset
I.07 – Right of redemption
I.08 – Key information about the offer and/or admission to trading

PART A – INFORMATION ABOUT THE ISSUER OF THE E-MONEY TOKEN
A.1 – Statutory name
A.2 – Trading name
A.3 – Legal form
A.4 – Registered address
A.5 – Head office
A.6 – Registration date
A.7 – Legal entity identifier
A.8 – Another identifier required pursuant to applicable law
A.9 – Contact telephone number
A.10 – E-mail address
A.11 – Response time (days)
A.12 – Parent company
A.13 – Members of the management body
A.14 – Business activity
A.15 – Parent company business activity
A.16 – Conflicts of interest disclosure
A.17 – Issuance of other crypto-assets
A.18 – Activities related to other crypto-assets
A.19 – Connection between the issuer and the entity running the DLT
A.20 – Description of the connection between the issuer and the entity running the DLT
A.21 – Newly established
A.22 – Financial condition for the past three years
A.23 – Financial condition since registration
A.24 – Exemption from authorisation
A.25 – E-money token authorisation
A.26 – Authorisation authority
A.27 – Persons other than the issuer offering to the public or seeking admission to trading of the e-money token in accordance with Article 51(1), second subparagraph, of Regulation (EU) 2023/1114
A.28 – Persons other than the issuer offering to the public or seeking admission to trading of the e-money token in accordance with Article 51(1), second subparagraph, of Regulation (EU) 2023/1114
A.29 – Reason for offering to the public or seeking admission to trading of the e-money token by persons referred to in Article 51(1), second subparagraph, of Regulation (EU) 2023/1114

PART B – INFORMATION ABOUT THE E-MONEY TOKEN
B.1 – Name
B.2 – Abbreviation
B.3 – Details of all natural or legal persons involved in design and development
A DESCRIPTION OF THE CHARACTERISTICS OF THE E-MONEY TOKEN, INCLUDING THE DATA NECESSARY FOR CLASSIFICATION OF THE CRYPTO-ASSET WHITE PAPER IN THE REGISTER REFERRED TO IN ARTICLE 109, AS SPECIFIED IN ACCORDANCE WITH PARAGRAPH 8 OF THAT ARTICLE
B.4 – Type of white paper
B.5 – The type of submission
B.6 – Crypto-assets characteristics
B.7 – Website of the issuer
B.8 – Starting date of offer to the public or admission to trading
B.9 – Publication date
B.10 – Any other services provided by the issuer
B.11 – Language or languages of the white paper
B.12 – Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available
B.13 – Functionally fungible group digital token identifier, where available
B.14 – Personal data flag
B.15 – LEI eligibility
B.16 – Home Member State
B.17 – Host Member States

PART C – INFORMATION ABOUT THE OFFER TO THE PUBLIC OF THE E-MONEY TOKEN OR ITS ADMISSION TO TRADING
C.1 – Public offering or trading
C.2 – Number of units
C.3 – Trading platforms name
C.4 – Trading platforms market identifier code (MIC)
C.5 – Applicable law
C.6 – Competent court

PART D – INFORMATION ON THE RIGHTS AND OBLIGATIONS ATTACHED TO E-MONEY TOKENS
D.1 – Holder’s rights and obligations
D.2 – Conditions of modifications of rights and obligations
D.3 – Description of the rights of the holders
D.4 – Rights in implementation of recovery plan
D.5 – Rights in implementation of redemption plan
D.6 – Complaint submission contact
D.7 – Complaints handling procedures
D.8 – Dispute resolution mechanism
D.9 – Token value protection schemes
D.10 – Token value protection schemes description
D.11 – Compensation schemes
D.12 – Compensation schemes Description
D.13 – Applicable law
D.14 – Competent court

PART E – INFORMATION ON THE UNDERLYING TECHNOLOGY
E.1 – Distributed ledger technology
E.2 – Protocols and technical standards
E.3 – Technology used
E.4 – Purchaser’s technical requirements
E.5 – Consensus mechanism
E.6 – Incentive mechanisms and applicable fees
E.7 – Use of distributed ledger technology
E.8 – DLT functionality description
E.9 – Audit
E.10 – Audit outcome

PART F - INFORMATION ON THE RISKS
F.1 – Issuer-related risks
F.2 – Token-related risks
F.3 – Technology-related risks
F.4 – Mitigation measures

PART G – INFORMATION ON THE SUSTAINABILITY INDICATORS IN RELATION TO ADVERSE IMPACT ON THE CLIMATE AND OTHER ENVIRONMENT-RELATED ADVERSE IMPACTS
G.1 Adverse impacts on climate and other environment-related adverse impacts

2026-03-20

This crypto-asset white paper has not been approved by any competent authority in any Member State of European Union. The issuer of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

This crypto-asset white paper complies with Title IV of Regulation (EU) 2023/1114 of the European Parliament and of the Council and to the best of the knowledge of the management body, the information presented in this crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

This e-money token is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

Warning: This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this e-money token on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and that any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 or any other offer document pursuant to Union or national law.

USD PARITY (USD.PA) are designed to be USD-backed stablecoins, which are Distributed Ledger Technology (DLT) Assets that are pegged to the value of U.S. Dollar, with each USD PARITY (USD.PA) representing a specific amount of the fiat currency (1 USD).

Holders of USD.PA have the right to redeem the token at any time and at par value (1:1 with U.S. Dollar). Direct purchase and redemption with GR8 Pay SIA is available only to holders who are onboarded as customers and have successfully completed the required AML/CFT and customer due diligence checks (including ongoing due diligence, where applicable). Holders who are not onboarded may still buy, sell, hold and transfer USD.PA on the Ethereum blockchain and/or via authorised crypto-asset service providers (e.g., exchanges), but they do not have a direct customer relationship with the Issuer.

As a last-resort measure, the Issuer may, at its discretion, process an exceptional redemption request from a non-customer where redemption via CASPs/exchanges is not possible and onboarding as a customer is not feasible or appropriate. Exceptional redemptions are discretionary and subject to AML/CTF/CPF and sanctions checks equivalent in substance to onboarding; redemption requests that do not pass these checks are rejected. For such redemptions, the holder must provide a bank account capable of receiving SEPA payments, and third-party fees (e.g., bank/payment-chain fees or blockchain network fees) may apply and are borne by the holder.

Following receipt of USD.PA to the designated redemption address, successful verification and approval, the Issuer burns the redeemed tokens on-chain and executes the corresponding U.S. Dollar payout. For customers, redemption is credited first to the customer’s GR8 Pay account; any onward transfer to an external bank account is processed separately under standard payment processing (including screening and cut-off times). For exceptional non-customer redemptions, the overall process is expected not to exceed five (5) business days, unless discrepancies, compliance concerns, or technical issues are identified.

USD.PA is issued directly by GR8 Pay SIA through its issuance channel and is accessible only to eligible customers (including eligible institutions) who have successfully completed onboarding and the required AML/CFT and sanctions checks, and who are located in jurisdictions permitted under the Issuer’s risk appetite.

USD.PA may also be acquired and/or traded on secondary markets (e.g., authorised crypto-asset service providers such as exchanges) at their discretion. Availability of USD.PA on any third-party platform does not constitute an endorsement by the Issuer and does not create a contractual relationship between the holder and the Issuer.

GR8 Pay SIA

GR8.money

Private Limited Company

Latvia, Malduguņu iela 2, Mārupe, Mārupes nov., LV-2167

Latvia, Malduguņu iela 2, Mārupe, Mārupes nov., LV-2167

2025-04-23

6488GKH17O8XT1326F66

Registration Number 50203643321

+371 28644544

info@gr8.money

7

Not applicable

Guntars Reidzāns, Dmitrijs Dmitrijevs, Bogdans Andruščenko

Electronic Money Institution

Not applicable

Company has no subsidiaries or parent companies. No conflict of interests have been identified as of today in relation to the issuance of USD.PA.

True

False

False

True

True

Not applicable

GR8 Pay SIA was established on 23.04.2025. The EMI licence (No. 27-55/2025/11) was granted on 10.12.2025. Since registration, the Company has been in a start-up / preparation phase for licensing and operational set-up. Paid-in share capital: EUR 353,000.00.

False

GR8 Pay SIA is licensed Electronic Money Institution under No. 27-55/2025/11 in Latvia

Latvijas Banka

Not applicable

Not applicable

Not applicable

USD PARITY (USD.PA)

USD.PA

GR8 Pay SIA

EMTW

NEWT

USD PARITY (USD.PA) are designed to be USD-backed stablecoins, which are Distributed Ledger Technology (DLT) Assets that are pegged to the value of U.S. Dollar, with each USD PARITY (USD.PA) representing a specific amount of the fiat currency (1 USD).

https://gr8.money/

2026-04-21

2026-04-21

Other services provided by the Issuer include payment services and electronic money services regulated under the Law on Payment Services and Electronic Money of the Republic of Latvia, namely execution of direct debits, card-based payment transactions, credit transfers, issuing of payment instruments, and issuance of electronic money.

ENG

PJM1C1PM6

FFBSF3LWN

True

True

Latvia

GR8 Pay SIA license to issue, distribute and redeem electronic money is passported in the following countries:
Austria, Belgium, Bulgaria, Czech Republic, Denmark, France, Greece, Croatia, Estonia, Italy, Ireland, Cyprus, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Finland, Spain, Hungary, Germany, Sweden, Iceland, Liechtenstein, Norway

OTPC

Not applicable as the supply of USD.PA is not limited to any fixed amount within its minting smart contract. There is no limitation in terms of the number of USD.PA to be offered to the public or admitted to trading.

Not applicable

Not applicable

Latvia

Any dispute with the offer to the public of USD.PA in the EEA shall be brought exclusively in the Court of Arbitration of the Latvian Chamber of Commerce and Industry.

USD.PA is an e-money token (EMT) governed by Regulation (EU) 2023/1114 (MiCA) and other applicable laws. An EMT is a crypto-asset that purports to maintain a stable value by referencing the value of one official currency (for USD.PA: U.S. Dollar).
Holding USD.PA does not grant any rights in GR8 Pay SIA beyond those set out in this White Paper and those provided under MiCA and applicable laws.

Holder’s rights
Right of redemption at par value. Eligible holders have the right to request redemption of USD.PA at any time at par value (1:1 in USD), subject to compliance with applicable AML/CFT/CPF and sanctions requirements and any other legal restrictions.
Transferability. USD.PA may be transferred the Ethereum blockchain. When a holder sends USD.PA to another address, the holder acknowledges that the tokens (and the ability to seek redemption, subject to eligibility) are transferred to the owner of that address and any subsequent holder.
Redemption scope. Redemption requests may be submitted in respect of USD.PA issued on the Ethereum blockchain, in line with the Issuer’s processes described in this White Paper.

Holder’s obligations and key risks
On-chain transactions are generally irreversible. Transfers of USD.PA are not reversible. Once tokens are sent, the sender bears the risk of losing access to those tokens indefinitely or permanently.
Wallet/security responsibility. Holders are responsible for safeguarding private keys, seed phrases, and access credentials. Loss, compromise, or third-party control of keys may result in loss of tokens and/or inability to redeem.
Errors and third-party actions. Losses may occur if (i) an incorrect address is used, (ii) private keys are lost, (iii) the receiving address belongs to a party that refuses to return the tokens, or (iv) the receiving party requires actions such as identity verification before returning tokens.
Compliance cooperation. To request redemption (and/or to be onboarded as a customer), holders must provide accurate information and documentation and cooperate with compliance checks. Failure to do so may result in refusal, delay, suspension, or termination of the redemption request, to the extent permitted by applicable law.
By holding, using, or accessing USD.PA, USD.PA holders further represent and warrant that:
- they are holding and using USD.PA in compliance with this White Paper and applicable laws;
- they are at least 18 years old, are not a Sanctioned Person, are not owned or controlled by a Sanctioned Person, and are not holding USD.PA on behalf of a Sanctioned Person; and
- they will not be using USD.PA for any illegal activity including, but not limited to, illegal gambling, money laundering, fraud, blackmail, extortion, ransoming data, terrorism financing, other violent activities, or any prohibited market practices.

Redemption eligibility and process (customers and exceptional non-customers)
Customers (standard route). Direct purchase/redemption with the Issuer is available only to holders who are onboarded as customers and have successfully completed required AML/CFT and customer due diligence checks (including ongoing due diligence where applicable). The Issuer may request compensation for onboarding/verification procedures where permitted. The Issuer does not charge redemption fees.
Non-customers (last-resort route). Holders without a customer relationship are expected to redeem via an authorised crypto-asset service provider (e.g., an exchange). As a last resort, the Issuer may, at its discretion, process an exceptional redemption for a non-customer in extraordinary circumstances where redemption via external providers is not possible and onboarding as a customer is not feasible or appropriate. Such redemptions remain subject to AML/CFT/CPF and sanctions checks equivalent in substance to onboarding and may be refused if requirements are not met.
Token burn on redemption. Following a successful redemption, the redeemed USD.PA tokens are burned in accordance with the Issuer’s operational process.

No entitlement to interest
Holders acknowledge that they are not entitled to any interest or other returns earned on reserve assets or other funds held in connection with USD.PA. USD.PA itself does not generate yield; it represents the right (subject to eligibility) to redeem USD.PA for an equivalent amount of USD as described in this White Paper.

GR8 Pay SIA may amend or update the rights and obligations described in this White Paper from time to time to reflect changes in applicable laws and regulation, supervisory expectations, the Issuer’s internal policies and procedures, the blockchain infrastructure on which USD.PA is supported, operational arrangements, or risk controls.
Any such changes will be made available through an updated version of this White Paper published on the Issuer’s website, or another publicly accessible channel designated by the Issuer. Where holders are onboarded customers, the Issuer may also notify them through additional communication channels considered valid under the customer agreement, such as in-app or portal notices, email, or other agreed channels. For holders without a customer relationship, publication of the updated White Paper on the Issuer’s website constitutes notice.
In accordance with MiCA, including Article 51, any significant new factor, material mistake, or material inaccuracy that is capable of affecting the assessment of USD.PA will be described in a modified version of this White Paper, notified to the competent authority as required, and published on the Issuer’s website. Changes take effect from the date of publication, or from any later effective date specified in the updated White Paper, and do not limit or waive any mandatory rights provided to holders under MiCA or other applicable laws

In case of insolvency, GR8 Pay SIA has implemented high standards for safe and sound financial management of its business. In a situation of financial duress or in periods of economic uncertainty, GR8 Pay SIA has established contingency plans to prevent any impact on its activities, including the issuance of USD.PA, or the rights of USD.PA holders.
Where GR8 Pay SIA is not able to fulfill its obligations or in case of insolvency, the USD.PA Reserves are duly protected in compliance with the Applicable Laws. In particular, the funds received in exchange for issuance of USD.PA are protected against any recourse by other creditors of GR8 Pay SIA, including in the event of enforcement proceedings or insolvency proceedings against GR8 Pay SIA.
If a situation of financial duress or insolvency were to occur, GR8 Pay SIA will implement its Recovery and/or Redemption Plan to allow USD.PA holders to exercise their redemption rights on USD.PA

Depending on the circumstances under which the Recovery Plan prepared by GR8 Pay SIA in accordance with Article 55 of MiCA is triggered, the Issuer may need to introduce temporary measures that affect the processing of USD.PA redemptions in order to safeguard orderly operations and protect holders’ interests.
Holders will be informed about any such measures via an updated version of this White Paper and/or a public notice on the Issuer’s website (and, for onboarded customers, additionally through other agreed communication channels where appropriate). Depending on the situation, the Issuer may temporarily impose one or more of the following (non-exhaustive examples):
- limits on the amount of USD.PA that can be redeemed on a given business day (set at both aggregate level and, where relevant, per holder/wallet level);
-prioritisation and/or extended processing timelines for redemption requests (including additional verification steps where required); and/or
- temporary suspension of redemptions, as a last resort and for the shortest period necessary.
The Issuer will apply such measures only for as long as needed during periods of market or liquidity stress, and will work to restore normal redemption conditions in line with regulatory requirements, in coordination with the competent authority Latvijas Banka.

The Redemption Plan maintained by GR8 Pay SIA in accordance with MiCA (including Article 55) is an operational plan designed to support the orderly redemption of USD.PA in circulation and to protect the right of redemption in a stressed scenario.
The Redemption Plan may be activated following a decision or instruction of the competent authority Latvijas Banka, in particular where the Issuer is unable, or is likely to become unable, to meet its obligations, including in scenarios such as insolvency proceedings, resolution-related measures (where applicable), or withdrawal of the Issuer’s authorisation as an electronic money institution. The Redemption Plan is designed to ensure equitable treatment of all USD.PA holders and an orderly process for exercising redemption rights.
If the competent authority triggers the Redemption Plan, individual redemptions processed under the standard redemption process described in this White Paper may be suspended, and the Issuer will commence an orderly, centrally coordinated redemption process for all holders on an equitable basis.
In such case, the Issuer (and/or the competent authority, as applicable) will publish a notice describing how USD.PA holders can submit a redemption claim and the applicable timelines. The notice will, at a minimum, set out:
- the date and time when the Redemption Plan has been activated;
- the steps of the redemption process and expected timelines;
- the minimum information and documentation required to submit a claim;
- where and how the claim must be filed (e.g., online form, email, or other designated channel);
- any deadlines for submitting claims; and
- practical information on redemption conditions and technical support.
Redemption claims submitted under the Redemption Plan will be subject to eligibility and verification requirements set out in the notice and the Redemption Plan, which may include (as applicable): confirmation of identity (KYC/KYB), verification of token holdings and wallet control, AML/CFT/CPF and sanctions checks, verification of bank account details for payout, and any additional information required by applicable law or requested by the competent authority.

If you have a complaint, please first contact GR8 Pay SIA at complaints@gr8.money

GR8 Pay SIA maintains a documented complaints-handling process to ensure complaints are managed promptly, fairly, transparently, and free of charge.
Complaints may be submitted via:
Email: complaints@gr8.money
Post/Mail: Mārupes nov., Mārupe, Malduguņu iela 2
Online form: via the Company’s website / internet bank / mobile application (where available).
The Company may request information needed to understand and assess the complaint, such as:
- complainant identification details and contact information (and, where applicable, proof of authority to act);
- a clear description of the issue and the desired outcome; and
-supporting evidence (e.g., screenshots, correspondence, transaction references).
For electronic money token holders without a contractual relationship (non-customer token holders), the Company enables complaints to be submitted even without onboarding. In such cases, the Company may request reasonable information to identify the relevant holding/transaction (e.g., wallet address and transaction details), without applying full customer onboarding requirements solely for complaint handling.
The Company acknowledges receipt of a complaint within 2 business days, using the same channel through which the complaint was received, and provides information on the handling process and any additional information required. Responses are provided in writing and in English.
Each complaint is registered in an internal complaints register and assigned to a designated handler, under Compliance oversight. The Company investigates competently and impartially, gathers relevant records, and documents findings and the proposed resolution (including any corrective actions, compensation where applicable, or a reasoned rejection).
Straightforward cases: resolved within 15 business days from receipt.
Complex cases: may be extended up to 35 business days, with prior written notice explaining the delay.
If the complainant is dissatisfied with the outcome, the complaint may be escalated internally to senior management (board@gr8.money). Complainants may also contact the competent supervisory authority, Latvijas Banka, if the complaint remains unresolved.
Complaints and related correspondence are recorded and retained in accordance with applicable regulatory requirements and GDPR. Access to complaint records is restricted to authorised personnel. Complaint trends are monitored and reported to support service and control improvements.

If a holder considers that GR8 Pay SIA has not resolved a complaint satisfactorily, the holder may escalate the matter to the competent authority Latvijas Banka by submitting an application/complaint:
- By e-address via the Latvian state portal (e-address / e-Adrese), or
- By e-mail: info@bank.lv, or
- By mail: K. Valdemāra iela 2A, Rīga, LV-1050, Latvia, or
- In person (by the submission routes described by Latvijas Banka).

In addition, if the holder qualifies as a consumer (natural person acting outside their trade/profession), the holder may use Latvia’s out-of-court consumer dispute resolution body Out-of-court Consumer Dispute Settlement Commission:
- Address: Brīvības iela 55, Rīga, LV-1010
- Phone: +371 65452554
- E-mail: pasts@ptac.gov.lv

Where applicable, holders may also consider the Latvijas Finanšu nozares asociācijas Ombuds (out-of-court dispute solver):
- Address: Doma laukums 8A, Rīga, LV-1050
- Phone: 67284562
- E-mail: ombuds@financelatvia.eu.

True

As a MiCA-compliant regulated e-money token, USD.PA is designed to be fully backed at all times by USD-denominated backing assets held under dedicated safeguarding arrangements. GR8 Pay SIA maintains one or more segregated “Parity Backing Accounts” (USD) with regulated credit institutions, used exclusively to hold fiat funds backing USD.PA and not used for any other business purpose. Where part of the backing is invested, it is limited to secure, low-risk and highly liquid USD-denominated instruments, held in separate custody accounts with authorised custodians; these custody accounts and positions are recorded as PA backing assets, are segregated from other assets, and are not pledged, rehypothecated, or otherwise encumbered.

False

Not applicable

Latvia

Any dispute concerning the rights and obligations of USD.PA holders arising out of the holding, use, transfer or redemption of USD.PA shall be submitted to the competent courts of the Republic of Latvia, unless mandatory provisions of applicable law provide otherwise

Blockchain: Ethereum.

Token standard used for USD.PA
Ethereum - ERC-20

USD.PA is implemented on Ethereum as an ERC-20 token and incorporates additional issuer controls required for a regulated e-money token. These controls include minting and burning functions for issuance and redemption, as well as compliance and security features such as pause, freeze, and other address-level restriction actions, where required by law and internal procedures.

GR8 Pay SIA will likely add additional blockchain support in the future and update the relevant sections of the White Paper accordingly.

USD.PA integrates with a range of supporting technologies beyond its smart-contract deployment on Ethereum. GR8 Pay SIA provides regulated fiat on-/off-ramp functionality in respect of issuance and redemption, supported by compliance workflows for onboarding, screening, and transaction monitoring, in order to facilitate compliance-aligned integrations with authorised crypto-asset service providers, custodians, and other partners.

Blockchain interaction and developer interfaces:
On Ethereum, USD.PA is interoperable with the standard JSON-RPC interface and commonly used Ethereum-compatible tooling, including standard Web3 libraries and developer stacks, thereby enabling integration with typical wallets, exchanges, and infrastructure providers.

USD.PA uses established conventions so that token information can be displayed consistently in wallets, block explorers, and token registries. The smart contract exposes standard ERC-20 metadata, including the token name, symbol, and decimals, as part of the contract interface.

Holders need a secure wallet supporting the token standard and sufficient native gas tokens.

Not applicable. USD.PA is a token and therefore does not have its own consensus mechanism. USD.PA is issued on Ethereum and relies on the Ethereum network’s consensus mechanism to enable decentralised validators to agree on transaction validity and ordering. Accordingly, USD.PA inherits the security and settlement properties of the Ethereum network.

Ethereum has its own protocol-level incentive mechanisms and charges network transaction fees for the recording and execution of transactions. Such fees are determined in accordance with the Ethereum protocol and are not set by the Issuer.

Holders should consult the official documentation relating to Ethereum for further details on its incentive and fee model, including the manner in which transaction fees are calculated and paid.

GR8 Pay SIA does not impose any additional fee for on-chain transfers of USD.PA and does not receive any portion of Ethereum network fees.

False

Not applicable.

True

As of the date of this White Paper, GR8 Pay SIA has not yet issued USD.PA and, accordingly, no external smart-contract audit has yet been completed in respect of the USD.PA smart-contract deployment on Ethereum.
Prior to the initial launch of USD.PA on Ethereum, and prior to any material upgrade or modification to the USD.PA smart contract or other critical on-chain components, the Issuer will commission an independent security audit by a recognised specialist firm.
Any audit findings will be reviewed, validated, risk-rated, and remediated in accordance with their severity before launch or upgrade. Findings that could reasonably result in loss of funds, loss of control over minting or burning functions, or material disruption to redemption or transferability will be remediated prior to deployment.

As part of issuing and managing USD.PA, GR8 Pay SIA is exposed to a range of risks. The principal issuer-related risks include:
1. Insolvency / bankruptcy risk
This is the risk that the Issuer becomes insolvent or enters bankruptcy or insolvency proceedings. It may arise from losses, operational disruption, regulatory actions, or broader financial stress. A related risk is the insolvency or operational failure of a credit institution or custodian holding safeguarding accounts or custody accounts used for USD.PA backing assets, which could delay or disrupt access to funds and the Issuer’s ability to perform issuance and redemption in an orderly manner.

2. Third-party and counterparty risk
The Issuer relies on third parties for critical services, including, among others, credit institutions for safeguarding and settlement accounts, custodians, payment service providers, technology providers, blockchain infrastructure providers such as node or RPC providers, and compliance tooling providers. Failure, outage, cyber incident, termination of service, or contractual disputes with such providers may negatively affect issuance, redemption, transaction processing, monitoring, and customer service.
In addition, USD.PA may be supported by exchanges, wallets, and other third-party platforms without the Issuer’s authorisation. Such support does not constitute an endorsement by the Issuer, and the Issuer is not responsible for losses arising from the use of USD.PA on third-party platforms.

3. Liquidity and market risk in backing assets
Even with conservative investment and liquidity rules, backing assets may include instruments that could become less liquid during market stress. In a scenario of exceptionally high redemption demand, market dislocation, settlement delays, or operational constraints at counterparties, the Issuer may experience difficulty in meeting all redemptions within ordinary timeframes and may need to apply measures under its Recovery Plan, where permitted.

4. Fraud, theft, and operational risk (risk of loss)
This includes risks of losses caused by internal or external fraud, theft, cyberattacks, human error, inadequate segregation of duties, failed processes, or improper administration of treasury keys, minting and burning operations, or backing asset operations. It also includes the risk of loss due to errors in smart-contract deployment, address management, or reconciliation processes.

5. AML/CFT/CPF and sanctions risk
USD.PA and related wallets or transactions could be used for money laundering, terrorist financing, proliferation financing, or sanctions evasion. The Issuer may be required to block, freeze, reject, delay, or report certain transactions or redemption requests, and may face enforcement actions or reputational damage if controls are ineffective.

6. Personal data and confidentiality risk
The Issuer processes personal data of customers and, in certain cases, such as complaints or last-resort redemptions, may process limited information relating to non-customer token holders. Security breaches, cyber incidents, or inadequate access controls could result in unauthorised access to or disclosure of personal data and confidential information.

7. Business, competitive, and strategic risk
The crypto-asset and payments environment is rapidly evolving and highly competitive. Changes in customer demand, technology, partner behaviour, market sentiment, or competitor actions may negatively affect the Issuer’s business model and the adoption of USD.PA.

8. Legal and regulatory risk
The Issuer is subject to MiCA, electronic money regulation, AML/CFT requirements, sanctions rules, data protection rules, and other applicable laws. Regulatory expectations may change, and non-compliance or perceived weaknesses in internal controls may lead to supervisory measures, penalties, restrictions on activities, or withdrawal of authorisation.

9. ESG and sustainability-related risk
USD.PA is initially issued on the Ethereum public blockchain. Future regulation, market standards, or supervisory expectations relating to sustainability disclosures or the environmental impact of blockchain networks may affect the Issuer’s ability to issue or continue supporting USD.PA on Ethereum and/or any additional networks that may be supported in the future.

10. Outsourcing and concentration risk
The Issuer may become dependent on a limited number of service providers for critical functions, such as banking partners, custody, key-management solutions, compliance tooling, and blockchain infrastructure. Concentration increases vulnerability to outages, commercial disputes, or provider failure and may require contingency arrangements and provider substitution plans.

Holding, transferring, or redeeming USD.PA exposes holders to several token-related risks, including:

1. Secondary-market price dislocation risk
Although USD.PA is designed to maintain a stable value by referencing U.S. Dollar and is redeemable at par value (subject to eligibility), the market price of USD.PA on secondary markets (e.g., exchanges, brokers, OTC venues) may deviate from 1 USD. Such deviations may be caused by supply/demand imbalances, market stress, liquidity constraints, operational incidents, perceived issuer risk, delays in redemption channels, or restrictions applied under recovery/redemption measures.

2. Under-collateralisation / reserve shortfall risk
This is the risk that, due to fraud, error, cyber incident, mismanagement, or third-party failure, the value of backing assets becomes lower than the value of USD.PA in circulation. A reserve shortfall would likely increase secondary-market price volatility and could impair the Issuer’s ability to meet redemptions at par value and/or within expected timeframes.

3. Redemption liquidity and timing risk
Even where reserves are conservatively managed, exceptionally high redemption demand, market disruption, settlement delays, or operational issues (including outages at banks, custodians, payment providers, or blockchain infrastructure) may delay the Issuer’s ability to process redemptions within ordinary timelines. In stressed conditions, the Issuer may apply temporary measures under its Recovery Plan and/or Redemption Plan (where legally permitted and/or required).

4. Network and protocol risk
USD.PA relies on the Ethereum blockchain and its supporting infrastructure. Congestion, chain reorganisations, validator issues, protocol upgrades, downtime, censorship, denial-of-service attacks, RPC outages, or vulnerabilities affecting token standards or related infrastructure may cause failed or delayed transactions, unexpected fees, or temporary inability to transfer USD.PA.

5. Smart-contract and technical implementation risk
USD.PA may be exposed to vulnerabilities in smart contracts or token-program implementations (including integration code), upgrade or configuration errors, or dependency issues. These could lead to loss of funds, incorrect mint/burn operations, freezing/pausing errors, or disruption of transfers/redemptions. Even with audits and controls, no software is risk-free.

6. Wallet and key-management risk
USD.PA holders are responsible for their wallets and private keys (or for choosing a secure custodian). Loss of private keys/seed phrases, compromised devices, malware, SIM-swap attacks, or custody-provider failures may result in irreversible loss of tokens or inability to access them. Blockchain transfers are generally irreversible.

7. Fraud, scams, and impersonation risk
Holders may be targeted by phishing, fake websites, fake support accounts, fraudulent “airdrop” or giveaway campaigns, impersonation of the Issuer or its staff, or creation of counterfeit tokens, including fake tokens on networks other than Ethereum. Holders may suffer losses by interacting with such scams. The Issuer does not control third-party websites, social media, or unofficial token listings.

8. Eligibility and compliance restriction risk
Redemption and certain services may be restricted by AML/CFT/CPF, sanctions, fraud prevention, or other legal requirements. The Issuer and/or service providers (e.g., CASPs/exchanges) may reject, delay, freeze, or report transactions or redemption requests associated with prohibited jurisdictions, sanctioned persons, high-risk typologies, or suspicious activity.

9. Third-party platform risk
Many holders access USD.PA through third-party services (exchanges, wallets, brokers, custodians, DeFi protocols, bridges). These platforms may suffer hacks, insolvency, operational failures, legal restrictions, or delistings. Use of USD.PA on a third-party platform does not imply endorsement by the Issuer, and losses on such platforms may not be recoverable.

10. Taxation risk
The tax treatment of acquiring, holding, transferring, and disposing of USD.PA depends on the holder’s jurisdiction and personal circumstances and may change over time. Holders should seek independent tax advice. The classification and reporting obligations for transactions involving USD.PA may differ across jurisdictions.

+C96
Outside the EEA, crypto-asset activities may be restricted, unregulated, or subject to rapidly changing rules. Regulatory divergence across jurisdictions may affect the ability to hold, transfer, trade, or redeem USD.PA through certain intermediaries and may impact secondary-market availability.

Purchasing, holding, transferring, or redeeming USD.PA may expose holders to technological and operational risks, including:

1. Blockchain / network risks
USD.PA is issued on the Ethereum public blockchain. Ethereum may experience vulnerabilities, attacks, congestion, chain reorganisations, validator failures, protocol upgrades, downtime, censorship, or other disruptions. Such events may result in delayed or failed transactions, unexpectedly high transaction fees, temporary inability to transfer USD.PA, or broader instability affecting network participants.

2. Smart-contract risks
USD.PA relies on a smart contract deployed on Ethereum. This smart contract, or related integration and administration processes, may contain vulnerabilities, configuration errors, upgrade or access-control errors (where upgradeability is used), or dependency issues that could lead to loss of funds, unintended minting or burning behaviour, disrupted transfers, or the need to pause or freeze certain functionality in order to protect users and the system. Even where audits and strong controls are applied, software may contain unknown vulnerabilities.

3. Third-party interoperability and bridging risks
Where holders use third-party bridges, wrapping mechanisms, or interoperability solutions in relation to USD.PA, additional risks may arise from smart-contract vulnerabilities, oracle failures, custody or validator compromise, operational failures, or insolvency of the relevant service provider. These risks may result in delays, loss of tokens, or inability to complete transfers. The Issuer does not control third-party bridges or interoperability solutions unless explicitly stated in this White Paper.

4. Settlement finality and irreversibility
Blockchain transactions are generally irreversible once confirmed. If a holder sends USD.PA to an incorrect address, interacts with a malicious contract, or loses access credentials, the holder may permanently lose access to the tokens. Examples include: (i) entering an incorrect address, (ii) losing the private key or seed phrase, (iii) sending USD.PA to an address controlled by a third party that refuses to return the tokens, or (iv) sending USD.PA to an entity that will return tokens only after additional steps, such as identity verification.

5. Wallet, key-management, and endpoint security risks
Holders are responsible for the security of their wallets, devices, and authentication methods, or for selecting a secure custodian. Malware, phishing, SIM-swap attacks, compromised devices, insecure backups, or custody-provider failures can lead to unauthorised transactions and irreversible loss of USD.PA.

6. Infrastructure and service-provider risks
Use of USD.PA often depends on third-party infrastructure such as wallet providers, exchanges or CASPs, custodians, node or RPC providers, block explorers, and data or monitoring services. Outages, termination of service, cyber incidents, or errors at these providers may limit a holder’s ability to access, transfer, trade, or redeem USD.PA, even if the Ethereum network itself remains operational.

7. Personal data and cybersecurity risks
When holders interact directly with the Issuer, for example in connection with onboarding, redemption, or complaints, the Issuer processes personal data and applies appropriate technical, organisational, and security measures to protect such data against unauthorised access, alteration, loss, or disclosure. Despite these safeguards, no system can fully eliminate the risk of security breaches.

8. Unanticipated and emergent risks
E-money tokens and associated blockchain infrastructure remain relatively novel and rapidly evolving. In addition to the risks described above, other currently unknown risks may emerge, or combinations of risks may materialise in ways that are difficult to predict, potentially leading to disruptions, losses, or additional compliance measures.

The Company has designed USD PARITY (USD.PA) operating model so that the key risks described in Sections F1 (Issuer-related risks), F2 (Token-related risks) and F3 (Technology-related risks) are mitigated through a combination of governance, safeguarding of backing assets, AML/CFT and sanctions controls, operational controls, and ICT/cybersecurity measures.

1. Mitigation measures concerning issuer-related risks
1.1. Bankruptcy / insolvency risk.
The Company mitigates this risk by maintaining full backing for USD.PA and holding the backing assets under dedicated safeguarding arrangements that are segregated from the Company’s own funds and other business assets. Fiat funds backing USD.PA are held in designated Parity Backing Accounts, and any eligible financial instruments (if used) are held in separate custody accounts; such assets are recorded as backing assets in internal ledgers and are not pledged or otherwise encumbered. The Company monitors backing coverage through frequent or daily reconciliations between (i) USD.PA supply on Ethereum (including treasury holdings) and (ii) the total backing assets.
1.2. Third-party / outsourcing risk.
The Company relies on multiple specialised third parties (e.g., safeguarding/custody banks, identity and wallet screening providers, node/RPC providers, and key-management technology). This risk is mitigated through (i) due diligence before onboarding, (ii) contractual requirements on confidentiality, availability, incident notification and cooperation, (iii) secure technical integration (segregated credentials, encryption, restricted permissions), and (iv) ongoing monitoring and periodic reviews of critical providers.
1.3. Market and liquidity risk.
Backing assets are managed so that redemption at par can be supported under normal conditions. The Company maintains a minimum portion of backing as deposits in the Parity Backing Accounts, and limits any investments of backing assets to secure, low-risk, highly liquid instruments with minimal market, credit and concentration risk and with currency matching (USD for USD.PA). In addition, operational liquidity is supported through treasury minting controls and monitoring of liquidity needs.
1.4. Operational risk and risk of loss.
The Company mitigates operational risk through strict segregation of duties so that no single person can initiate, approve, sign, and reconcile the same critical operation, controlled workflows for minting and burning, and frequent reconciliations. On-chain operations are executed only on the basis of approved and documented internal instructions and are supported by audit logs, defined escalation paths, and record-keeping enabling full reconstruction of key actions.
1.5. AML/CFT/CPF and sanctions risk.
The Company applies a risk-based approach to customer eligibility and transactions, including customer onboarding (KYC/KYB), sanctions and adverse media screening, and wallet risk screening. Before issuing USD.PA to a wallet, the Company verifies control of the wallet address, including through an ownership verification test, and performs screening. Before redeeming USD.PA into fiat, the Company re-screens the sending address and performs additional checks based on risk indicators and transaction patterns; cases may be held, escalated, refused, and reported as required. The USD.PA smart contract includes restricted control functions (e.g., freeze, confiscation and pause) that may be used only under strict governance and legal or operational criteria.
1.6. Personal data and confidentiality risk.
The Company mitigates data-related risks through access controls, least-privilege permissions, encrypted communications with third-party providers, secure storage of customer and screening outputs, logging and monitoring, and incident response procedures, including escalation and notification where required by law.
1.7. Legal and regulatory risk.
The Company’s model is implemented under an internal control framework with defined roles and responsibilities, documented procedures, controlled changes, record-keeping, and reporting and escalation paths. Policies and procedures are maintained and updated to reflect applicable requirements, and material incidents are handled through defined incident management and communication processes with competent authorities where required.
1.8. Environmental / sustainability and governance risk.
The Company mitigates sustainability-related exposure by deploying USD.PA on Ethereum, which uses a proof-of-stake consensus mechanism rather than proof-of-work, thereby supporting more predictable operational characteristics and lower energy intensity than proof-of-work-based systems.

2. Mitigation measures concerning token-related risks
2.1. Financial stability / ecosystem risk.
The Company mitigates systemic concerns by maintaining full backing and enabling redemption at par, subject to eligibility and compliance controls. The Company’s issuance and redemption are governed by controlled workflows, reconciliations, and safeguarding requirements, reducing the likelihood that token-related issues propagate into broader market infrastructure.
2.2. Secondary-market price dislocation risk.
While the Company does not control secondary-market pricing on exchanges or peer-to-peer markets, it supports the USD.PA parity objective by maintaining full backing and enabling redemption at par value for eligible holders, which can contribute to market discipline under normal conditions.
2.3. Under-collateralisation risk.
Under-collateralisation is mitigated through (i) segregated safeguarding of backing assets, (ii) limitations on backing asset eligibility and encumbrance, and (iii) daily reconciliation of USD.PA supply versus backing assets. Discrepancies trigger investigation, escalation, and remediation.
2.4. Liquidity risk in redemption.
Liquidity risk is mitigated through the composition of backing assets, including deposits and, where applicable, only highly liquid eligible instruments, together with operational controls around redemption processing, such as wallet and transaction checks before burning and payout, monitoring of the redemption pipeline, and escalation of exceptions.
2.5. Scam / spoofing / fake token risk.
To help holders identify the genuine USD.PA contract on Ethereum, the Company maintains an internal registry of the official contract address and publishes official contract information through its official channels. The Company monitors for spoofed or fake tokens and misuse of the Parity (PA) name or symbols and may issue public warnings and/or inform relevant counterparties or authorities, as appropriate.
2.6. Taxation and legal classification risk.
Tax treatment and legal consequences depend on the holder’s jurisdiction and individual circumstances. The Company mitigates misunderstanding risk through disclosures in the White Paper and encourages holders to seek independent tax and legal advice where relevant.
2.7. Global regulatory divergence risk.
The Company mitigates cross-border legal risk through eligibility controls, risk-based restrictions, and compliance checks that may limit access or impose additional verification where required by law or the Company’s risk appetite.

3. Mitigation measures concerning technology-related risks
3.1. Blockchain / network risk.
The Company mitigates Ethereum network risk through (i) monitoring of network conditions, including fees, congestion, and technical incidents, and (ii) operational contingency measures, including controlled pausing of transfers on the USD.PA contract in emergency circumstances where legally and technically appropriate.
3.2. Smart-contract risk.
The Company applies formal smart-contract governance, including controlled design principles, minimised admin roles, and formal change management comprising review, testing in non-production environments, approvals, and updated documentation. Where a critical vulnerability is identified, the Company can implement containment actions, including pausing transfers on the affected contract, and deploy fixes under controlled release procedures. Prior to launch and prior to material upgrades, the Company intends to obtain independent external security reviews or audits of the smart contract.
3.3. Key management and wallet security risk.
Private keys for production wallets are protected through enterprise-grade hardware-based multi-signature control. Critical on-chain actions require multiple authorised signers, and the Company prohibits private key export and applies strong operational security requirements, including hardened endpoints, restricted environments, and access reviews. Backup and recovery procedures exist for device failure or key-loss scenarios and are accessible only under defined dual-control processes.
3.4. Irreversibility of blockchain transactions.
Because blockchain transfers can be irreversible, the Company mitigates user-error exposure primarily through preventive controls in its direct issuance and redemption flows, including wallet ownership verification, wallet screening, address linkage to customer profile, and controlled redemption workflows. For transfers outside the Company’s direct control, including peer-to-peer or exchange activity, the Company discloses the risk and encourages holders to apply strong wallet security and careful transaction practices.
3.5. Integration / API security and data integrity risk.
Integrations between core systems and third parties are protected through encryption, authentication, restricted network access, detailed logging, error handling, and reconciliation routines designed to detect mismatches between fiat ledgers and on-chain activity. Credentials are segregated by environment, stored securely, and rotated as appropriate.
3.6. Unanticipated / emerging risks.
The Company maintains monitoring, incident response, and periodic review processes to identify new threats and vulnerabilities. Where needed, controls, policies, and technical measures are updated, and material incidents are escalated and handled through defined processes.

USD.PA is an e-money token issued as a smart-contract token on the Ethereum distributed ledger network. USD.PA itself does not operate a consensus mechanism; transactions are validated and ordered by the Ethereum network on which USD.PA is deployed.
USD.PA is intended to be deployed on Ethereum only. Ethereum uses a proof-of-stake consensus mechanism, and the Issuer does not deploy USD.PA on proof-of-work blockchains. In accordance with the applicable MiCA sustainability disclosure requirements, the Issuer provides sustainability indicators relating to the adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism used by the Ethereum network, including the mandatory key indicator on energy consumption, expressed in kWh per calendar year, and any additional indicators required under the applicable thresholds and methodologies.
Because USD.PA has not yet been issued and therefore has no historical on-chain usage data attributable to the token, the Issuer discloses network- and consensus-mechanism-level indicators for Ethereum, based on publicly available information and/or independent specialist methodologies, and will update these disclosures as part of its ongoing transparency commitments, including where material methodology updates occur. The Issuer expects USD.PA activity to represent a marginal share of overall Ethereum network activity; nevertheless, the indicators are presented to enable holders to assess the sustainability characteristics of the network used for issuance.