Overview

This Agreement is entered into between Trump Code Pty Ltd (“Company”), an Australian-registered entity (ABN 47644363093), and the undersigned customer (“Customer”), collectively referred to as “the Parties.”

1. Introduction

This Agreement governs the opening, maintenance, and use of accounts maintained with the Company for holding fiat currency (SBD) and the issuance, holding, redemption, and use of closed-loop e-gift cards (stored-value instruments) issued by the Company.

By signing this Agreement, the Customer acknowledges that they have read, understood, and agreed to be bound by its terms.

2. Definitions

For the purposes of this Agreement:

AML/CTF Obligations: Obligations imposed under the Anti‑Money Laundering and Counter‑Terrorism Financing Act 2006, associated Rules, and AUSTRAC guidance, including customer due diligence, transaction monitoring, and reporting.

Business Day: A day on which banks are open for business in Australia, excluding weekends and public holidays.

Customer: Any individual or legal entity that opens and maintains an account with the Company for the use of its payment services and closed-loop stored-value products.

Cut‑Off Time: The latest time on a Business Day by which a transaction instruction must be received to be processed the same day (4.00pm AEST).

E-Gift Card: A prepaid closed-loop stored-value instrument issued by the Company, redeemable only for goods and/or services from participating merchants or approved partners within the Company’s designated network. The E-Gift Card is not redeemable for cash, is non-transferable except as permitted by the Company, and cannot be used outside the approved network

Sanctions: Restrictions imposed under Australian law, including the DFAT Consolidated List and United Nations Security Council sanctions, prohibiting dealings with designated persons or entities.

Stored Value: Monetary value recorded electronically and held in the wallet or the gift card, representing a claim against the Company.

3. Scope of Services

3.1 E-Gift Card Functions

Purchase – Customers may purchase E-Gift Cards through the Company’s approved channels.

Storage of Value – The E-Gift Card stores a prepaid monetary value denominated in the applicable currency.

Redemption – The stored value may be redeemed only for eligible goods and/or services offered by participating merchants or approved partners within the Company’s closed-loop network.

Balance Inquiry – Customers may check the remaining balance through the Company’s designated channels.

Partial Redemption – Where supported, the E-Gift Card may be used for multiple transactions until the stored value is fully exhausted.

Expiry – The E-Gift Card is valid until its stated expiry date, after which any remaining value will be treated in accordance with applicable laws and the Company’s policies.

Restrictions – The E-Gift Card:

• is a closed-loop stored-value instrument;

• is not redeemable for cash except where required by applicable law;

• cannot be used outside the Company’s approved merchant network;

• is not a bank account, deposit, debit card, or credit card; and

• may not be transferred, resold, or exchanged except as permitted by the Company.

4. Customer Obligations

Provide accurate and complete information for identification and verification (Appendix A).

Comply with all AML/CTF requirements, including provision of source of funds/wealth when requested.

Not use services for unlawful purposes, including money laundering, terrorism financing, fraud, or sanctions evasion.

Safeguard login credentials and notify the Company immediately of any suspected compromise.

Keep account details updated

• Keep mobile number/email current

• Comply with card usage rules

• Notify the Company immediately if an e-gift card is lost, compromised, or used without authorisation

5. Company Obligations

Maintain customer funds and stored value in accordance with applicable Australian laws and internal safeguarding procedures.

Comply with AUSTRAC reporting obligations (SMRs, IFTIs, TTRs).

Notify customers of material changes to services in accordance with regulatory requirements.

Exercise reasonable care and skill in providing custodial services.

6. Fees & Charges

The Customer agrees to pay applicable fees for custodial services, as published in the Company’s fee schedule (Appendix B).

The Company may amend fees with 30 days’ notice.

7. Risk Disclosures

Cross-border transfers may involve heightened ML/TF risks.

Jurisdictional risks apply to transactions involving higher-risk countries.

Technology and cyber risks may affect service availability.

Merchants may cease participating

Technical outages

Exchange rate risk (if cross-border)

E-Gift cards are not government guaranteed

Funds are not protected by the Financial Claims Scheme

8. Enhanced Due Diligence (ECDD)

The Company may apply ECDD where required (PEPs, high-risk jurisdictions, unusual transactions).

Customers must provide additional information (source of funds, source of wealth, beneficial ownership) when requested.

Senior management approval is required to establish or continue high-risk relationships.

9. Transaction Monitoring and Reporting

The Company reserves the right to monitor all transactions.

Suspicious matters will be reported to AUSTRAC in accordance with statutory timeframes.

Customers must cooperate with investigations and provide requested information.

10. Confidentiality and Data Protection

Customer data will be handled in compliance with Australian privacy laws.

Disclosure will only occur where required by law or regulatory obligations.

11. Sanctions and Prohibited Transactions

Customers will be screened against the DFAT Consolidated List, and Thomson Reuters.

Transactions involving sanctioned persons or entities are prohibited.

Assets may be frozen and reported to authorities if sanctions obligations apply.

12. Liability and Indemnity

The Company is not liable for losses arising from market fluctuations, cyberattacks, or third-party failures, except in cases of gross negligence or fraud.

The Customer indemnifies the Company against losses arising from unlawful use of services.

• merchant refusal

• expired E-gift cards

• customer mistakes

• incorrect beneficiary information

• force majeure

13. Account Opening, Eligibility, and Closure

13.1 Eligibility for Opening Accounts

Accounts may be opened by individuals aged 18 or older, residing lawfully in Australia or other approved jurisdictions, and who pass KYC verification.

Accounts may not be opened for sanctioned persons, or entities.

13.2 Closure of Accounts

Customers may request account closure at any time by written notice.

The Company may close accounts for breach of this Agreement, suspicious activity, or regulatory requirements.

Upon closure, balances will be returned subject to applicable laws and reporting obligations.

14. Termination

The Company may terminate services if the Customer breaches AML/CTF obligations, engages in suspicious activity, or fails to comply with this Agreement.

Upon termination, assets will be returned subject to regulatory restrictions.

15. Operational Terms

15.1 Cut‑Off Times and Office Hours

Transactions submitted after 4:00 PM AEST will be processed the next business day.

Customer support is available Monday to Friday, 9:00 AM to 5:00 PM AEST, excluding public holidays.

15.2 Payment Limits

Daily transaction limits and maximum wallet balances will apply, as published in the Company’s schedule.

Limits may be adjusted for regulatory compliance or risk management.

15.3 Mistaken Payments

Customers must notify the Company immediately of mistaken payments.

The Company will investigate and, where possible, reverse or refund the transaction in accordance with applicable law.

15.4 Unauthorised/Fraudulent Payments

Customers must report unauthorised or fraudulent transactions promptly.

The Company will investigate and may reimburse losses where liability rests with the Company.

Customers may be liable where negligence or misuse of credentials is established.

15.5 Payment Cancellations

Payment instructions may be cancelled only if not yet processed.

Cancellation requests must be submitted in writing or via the Company’s platform.

16. Dispute Resolution and Complaints

16.1 Internal Dispute Resolution

Customers should first raise complaints with the Company’s customer service team. The Company will investigate and respond within 30 days.

Notices shall be delivered electronically to [email protected], or in writing to the following address;

16.2 Australian Financial Complaints Authority (AFCA)

If a complaint is not resolved internally, customers may escalate to the Australian Financial Complaints Authority (AFCA).

Website: www.afca.org.au
Phone: 1800 931 678
Email: [email protected]
Mail: GPO Box 3, Melbourne VIC 3001

17. Intellectual Property

All intellectual property rights in the Company’s platforms, software, trademarks, and content remain the exclusive property of the Company.

Customers are granted a limited, non‑exclusive licence to use the services for lawful purposes.

Customers may not copy, modify, or distribute Company intellectual property without prior written consent.

18. Governing Law and Jurisdiction

This Agreement is governed by the laws of Australia.

Disputes shall be resolved through negotiation, failing which they may be referred to arbitration or courts of competent jurisdiction.

19. Miscellaneous

Amendments must be in writing and notified to the Customer.

This Agreement constitutes the entire agreement between the Parties.

If any provision is invalid, the remainder shall remain enforceable.

Appendix A: KYC Documents

Customers must provide acceptable identification documents prior to account opening:

Individuals: Passport, driver’s licence, or birth certificate; proof of residential address (utility bill, bank statement), clear photo, contact details.

Non‑Individuals: Certificate of incorporation, business registration, details of directors/beneficial owners, and proof of address.

Additional documents may be requested under Enhanced Due Diligence.

Appendix B: Fees & Charges

Item	Charge (AUD)
Account Opening Fee	0.00
Transaction Fee (Domestic)	0.00
Transaction Fee (International)	1.50
Redemptions Fee	1.00
Gift Card Issuance Fee	0.00
Gift Card Replacement Fee	2.00
Utility Payment Fee (AUD 1.00 to AUD 10.00)	0.50
Utility Payment Fee (AUD 11.00 to AUD 100.00)	1.00
Utility Payment Fee (AUD 101.00 to AUD 200.00)	1.50
Airtime Top-up Fee	0.50