User Disclosure
1. Overview
ANDX USA LLC (“ANDX USA”, “we”, “us”, or “our”) is committed to providing a secure, compliant, and transparent environment for digital asset transactions.
To support digital asset custody, settlement, and related operational functions, ANDX USA integrates with BitGo Trust Company, Inc. (“BitGo”), a South Dakota–chartered public trust company regulated under U.S. state and federal laws applicable to trust institutions.
This Disclosure describes:
how digital asset custody is structured,
the respective roles of ANDX USA and BitGo,
the regulatory framework governing custodial services, and
key risks associated with digital assets.
This Disclosure supplements—but does not replace—our Terms and Conditions, Privacy Policy, and any other notices provided to you through the Platform.
2. Digital Asset Custody Structure
2.1 Custody
When you use the Platform to hold or transact in digital assets, those assets are custodied within BitGo’s regulated trust framework. BitGo maintains custodial accounts, safekeeping arrangements, and operational controls designed to protect customer assets in accordance with trust and fiduciary standards.
2.2 ANDX USA’s Role
ANDX USA provides:
the Platform interface through which you submit instructions,
onboarding, identity verification, and AML/CTF screening,
ongoing monitoring and fraud-prevention controls,
routing of your instructions into BitGo’s custodial infrastructure.
ANDX USA does not:
provide custodial services,
hold or control private keys, or
conduct blockchain settlements.
Digital asset custody and safekeeping responsibilities remain with BitGo under its regulatory framework.
3. Regulatory Licensing and Compliance
3.1 BitGo’s Licensing and Regulatory Obligations
All digital asset custodial, settlement, operational, and ledgering functions made available through the Platform are performed within BitGo’s regulated trust framework, which governs the safekeeping and movement of digital assets. BitGo is responsible for the custodial environment in which assets are held, the processing of blockchain settlements, and the integrity of custodial records and operational controls.
ANDX USA does not perform custodial or settlement functions.
ANDX USA provides the Platform interface through which users access services supported by BitGo, and is responsible for onboarding, identity verification, sanctions screening, ongoing AML/CTF monitoring, fraud prevention measures, and the secure routing of user instructions into BitGo’s custodial infrastructure.
As part of these activities, ANDX USA may transmit certain identity, transactional, or compliance information to BitGo as necessary for BitGo to perform its custodial and operational responsibilities in accordance with applicable laws and industry standards.
Details are provided in our Privacy Policy.
4. Transaction and Operational Flow
When you initiate an action on the Platform—such as depositing digital assets, requesting a withdrawal, or submitting other instructions—ANDX USA processes your request and securely transmits it to BitGo for custodial execution.
BitGo is responsible for:
recording digital asset balances within its custodial system,
processing blockchain settlements required to complete transactions,
ensuring accurate reconciliation and safekeeping of assets,
maintaining operational controls required under trust regulations.
This structure ensures that asset safekeeping remains within BitGo’s regulated environment while ANDX USA provides the user interface and customer-facing platform.
5. Protection of Customer Assets
BitGo maintains safeguards consistent with its obligations as a trust company, which may include:
segregation of customer custodial assets from company assets,
institutional-grade security including multi-signature infrastructure,
operational and cybersecurity controls,
independent audits where required.
Although these protections reduce risk, digital assets inherently carry unique risks, as described below.
6. Risks of Digital Assets
Digital assets are subject to a variety of risks, including but not limited to:
6.1 Market Risk
Digital assets may experience significant price volatility, liquidity limitations, network congestion, or protocol changes.
6.2 Security Risk
Despite advanced controls, digital assets may be subject to hacking, cyberattacks, unauthorized access, technical failures, or other forms of compromise.
6.3 Operational Risk
System outages, network delays, third-party service interruptions, or custodial infrastructure incidents may impact your ability to access or transact with your assets.
6.4 Regulatory Risk
Changes in U.S. federal or state law may affect the availability, legality, or treatment of digital assets or custodial services.
6.5 Issuer and Counterparty Risk
Assets such as stablecoins may depend on the reserves, governance, or operational stability of their issuers.
You should carefully evaluate these risks before engaging in digital asset activities.
7. User Acknowledgment
By using the Platform, you acknowledge and agree that:
Digital assets you hold through the Platform are custodied under BitGo’s regulated trust company framework.
ANDX USA does not custody digital assets or control private keys.
Certain personal and transactional data may be shared with BitGo to enable custodial, settlement, and compliance functions.
Your ability to transact in digital assets depends on system availability and the operational environments of multiple regulated and unregulated parties.
Digital assets carry inherent risks that may result in loss of value or access.
For questions regarding this Disclosure or our custodial structure, please contact:
support@andxus.io