Legal

Basis of dealing, and who we will not deal with

Synterra Innovations Ltd. does not market or promote its services. Every relationship begins at the client's own initiative, with a verified client, in a jurisdiction where what we are asked to do is lawful. This page states that in full.

Draft — not yet settled by counsel. This notice states the basis on which the firm intends to deal and is legally operative once published. It has not been reviewed by a qualified adviser in any of the jurisdictions it touches, and clause 11 is unfilled. Do not publish it in this state.

  1. What this notice is

    This notice states the basis on which Synterra Innovations Ltd. provides its services, and the limits on whom it will provide them to. It applies to this website and to every enquiry and relationship arising through it.

    Synterra Innovations Ltd. is a corporation incorporated in Canada under corporation number 1639649-6, with its registered office at 204-78 George St, Ottawa ON K1N 5W1. It is registered with the Financial Transactions and Reports Analysis Centre of Canada as a money services business under registration number N300000167. It holds no other authorisation, and nothing in this notice or elsewhere on this website should be read as a claim to one.

  2. No offer and no solicitation

    Nothing on this website is an offer, an invitation, an inducement or a recommendation to buy, sell, exchange or hold any asset, or to enter into any service. Descriptions of services are informational. Figures, rates and examples are illustrative and are not quotes; no price is dealable unless we have confirmed it to a client in writing.

    No content on this website is directed at any person in any jurisdiction where its publication or availability would be contrary to local law, or where it would subject Synterra to a registration, licensing or authorisation requirement it does not hold. If you are such a person, this website is not addressed to you and you should not act on it.

  3. We act on reverse solicitation only

    Synterra does not market, advertise or promote its services. It runs no outbound campaigns, buys no advertising, makes no cold approaches, holds no promotional events, and operates no self-service sign-up. This website is a passive statement of what the firm does. It is not a channel through which services are offered.

    Every client relationship is entered into at the exclusive initiative of the client. A person who wishes to enquire does so having sought us out, on their own initiative and without any approach from us. We record how each relationship was initiated, and we decline where that initiative did not come from the prospective client.

    A service provided on this basis is provided only in respect of what the client asked for. We do not treat an enquiry about one service as an opening to offer another.

  4. Introductions and partners

    Where a third party introduces a prospective client to us, the introduction must itself originate in that person's own approach to the introducer. Partners are bound in writing not to market, advertise or promote Synterra's services, not to make unsolicited approaches, and not to hold themselves out as able to offer our services on our behalf.

    Partners are verified and contracted before any introduction is made, and where agent-registration rules apply they are registered and reported as agents of Synterra Innovations Ltd. An introduction does not commit us to accept anyone: a referred person is assessed exactly as any other, and is declined on the same grounds.

  5. We deal only with verified clients

    No service begins before onboarding is complete. That means full identity verification of the individual, or of the entity and its beneficial owners; documentation of the source of funds above set thresholds, with enhanced review where the relationship warrants it; and screening against sanctions, politically exposed person and watchlist databases at onboarding and on an ongoing basis.

    There is no anonymous access, no provisional access and no threshold below which verification is waived. We decline relationships, including introduced ones, and a relationship whose source of funds cannot be documented is not one we will take on at any size.

  6. Eligible jurisdictions

    We will not enter into or continue a relationship with a person who is resident, established, or acting from a jurisdiction in which:

    • holding, exchanging or transferring crypto assets is prohibited, outlawed or otherwise unlawful;
    • providing the services described on this website would require an authorisation that Synterra does not hold;
    • the person or the flow is subject to sanctions, or which is itself subject to comprehensive sanctions or an equivalent restriction.

    Eligibility is assessed at onboarding and monitored for the life of the relationship. Where the position changes — because the law changes, because the client moves, or because a restriction is imposed — we will restrict or exit the relationship.

    It remains your own responsibility to satisfy yourself that your use of these services is lawful where you are, and to meet any tax, reporting or licensing obligation that arises for you. We do not advise on that and our accepting you as a client is not a conclusion that you have met it.

  7. We do not promote crypto assets

    Synterra expresses no view on the merits of any crypto asset. We do not recommend acquiring or holding one, do not offer any service whose purpose is speculation on one, and do not operate an investment, portfolio or asset management service of any kind.

    Our services convert and settle value that a client already holds, or receives in the ordinary course of their own economic activity. Naming an asset on this website says only that we can convert or settle it — nothing more.

  8. No advice

    Nothing on this website or said in the course of a relationship is investment, legal, tax or accounting advice, and nothing should be relied on as such. Where a decision has consequences of that kind, take advice from someone qualified to give it in your own jurisdiction.

  9. Risk

    Crypto assets are volatile and can lose value, quickly and completely. Networks can fail, stall or fork, and a transfer once settled on a public network cannot be reversed by us or by anyone.

    Synterra Innovations Ltd. is not a bank and does not hold client funds. It has no deposit-taking authorisation, accepts no deposits, and nothing arising from its services is covered by any deposit guarantee, investor compensation or insurance scheme.

  10. This website

    Content is provided as it stands and may change without notice. Rates and figures shown for illustration are not offers and do not bind us. Where this website links to a third party, that is not an endorsement and we are not responsible for what is on the other side of the link.

    References to other companies in the Whales Corp AG group describe the group's activities. They are not an offer of those companies' services by Synterra Innovations Ltd, and each is subject to its own terms and its own regulatory position.

  11. Governing law

    This notice and any relationship formed under it are governed by the law to be specified here, and the courts of that place have jurisdiction to be specified here. Nothing in this clause removes a protection that the mandatory law of your own country of residence gives you and that cannot be varied by agreement.

  12. Contact

    Questions about this notice, and correspondence from regulators, law enforcement or a banking partner, should be addressed in writing to the compliance function of Synterra Innovations Ltd. at info@synterrainnovations.ca, or to the registered office at 204-78 George St, Ottawa ON K1N 5W1, Canada.

Synterra Innovations Ltd. · FINTRAC MSB N300000167 · drafted 2 September 2026 · not yet in force