Legal Agreement

Terms and Conditions

Please read these terms carefully before establishing an account or using our financial infrastructure.

Effective Date: September 8, 2026 • Entity: Polar Financial

1

Acceptance of Terms & Regulatory Framework

These Terms of Service ("Terms", "Agreement") constitute a legally binding agreement between you ("Client", "User", or "Account Holder") and Polar Financial ("the Bank", "we", "us", or "our"), governing your access to and use of our consumer and corporate banking services, web platforms, mobile applications, APIs, and associated financial products.

By registering an account, submitting identity documents, executing transactions, or maintaining balances with Polar Financial, you unconditionally acknowledge and agree to be bound by these Terms and our companion Privacy Policy.

2

Eligibility & Account Opening Rules

To open and operate an account with Polar Financial, you must be at least 18 years of age (or the legal age of majority in your jurisdiction) and possess full legal capacity to enter into binding contracts.

First Account Currency Rule:

In accordance with regulatory mandates in United States, every client's initial account opened upon registration is automatically denominated in the official base domestic currency of United States. Subsequent multi-currency checking, savings, or investment accounts may be created in supported global currencies.

All account openings are contingent upon satisfactory completion of Know Your Customer (KYC), Anti-Money Laundering (AML), and Customer Due Diligence (CDD) identity verification procedures.

3

3-Tier Transfer Architecture & Processing

Funds transfers initiated through Polar Financial are strictly categorized and processed under our three-tier settlement architecture:

  • Internal Transfers: Instantaneous fund movements between verified accounts maintained directly within Polar Financial.
  • Domestic External Transfers: Electronic funds transfers routed to verified external depository institutions operating strictly within the domestic borders of United States.
  • International SWIFT Transfers: Cross-border international telegraphic wires routed via correspondent banking partners to financial institutions outside United States.

All outgoing wire transfers require two-factor transaction PIN verification and are subject to real-time compliance screening against OFAC, PEP, and international sanctions lists.

4

Joint Accounts & Dual-Signature Governance

Where an account is established as a Joint Account with multiple co-owners, or where Dual-Signature settings are activated:

Any transfer initiated by one co-owner is placed into a "Pending Approval" state and routed to the Action Required queue of all designated partners. The transaction will only be executed once all required partner approvals and PIN confirmations are completed. Rejection by any co-owner will immediately cancel the transfer and release held balances.

5

Payment Cards, PIN Security & ATM Limits

Physical and virtual debit cards issued by Polar Financial are linked to designated account balances. Cardholders are responsible for safeguarding card numbers, CVV security codes, and cardholder PINs.

You may freeze or block cards instantaneously through the dashboard command center if a card is lost, compromised, or stolen. Transactions exceeding customized daily or monthly spending limits will be declined for your protection.

6

Multi-Currency Operations & Exchange Rates

Cross-currency transfers and loan settlements are converted in real time using official interbank market exchange rates maintained by Polar Financial. The applicable exchange rate and exact destination amount are clearly disclosed prior to transaction authorization.

7

Fees, Limits & Account Maintenance

Polar Financial discloses all applicable fees—including fixed transfer fees, currency conversion spreads, and wire processing surcharges—transparently within the application interface prior to payment execution. We reserve the right to revise fee structures upon providing 30 days written or electronic notice.

8

Prohibited Activities & Account Suspension

Accounts may not be used for unlawful purposes, including but not limited to money laundering, terrorist financing, fraud, unauthorized money transmission, sanctions evasion, or abusive transaction spoofing.

Polar Financial reserves the right to immediately freeze, restrict, or terminate any account suspected of violating applicable financial regulations or these Terms.

9

Disclaimers & Limitation of Liability

While Polar Financial employs enterprise-grade infrastructure and continuous uptime monitoring, services are provided on an "as is" and "as available" basis. The Bank shall not be liable for indirect, incidental, punitive, or consequential damages arising from third-party network outages, regulatory freezes, or force majeure events.

10

Governing Law & Jurisdiction

These Terms and any disputes arising hereunder shall be governed by, interpreted, and construed exclusively in accordance with the banking and commercial laws of United States, without giving effect to conflict of law principles.

Any legal action or proceeding arising out of or related to these Terms shall be instituted exclusively in the competent courts located in United States.

11

Contact & Legal Inquiries

For official legal notices, compliance queries, or questions concerning these Terms, please contact our Legal and Compliance Office:

Institution: Polar Financial

Legal & Compliance Email: legal@polarfinancial.com

Customer Support Telephone: +1 (800) 555-0199

Registered Headquarters: 100 Financial Plaza, Suite 400, New York, NY 10005

Primary Jurisdiction: United States