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Legal documents

Terms & Conditions

Last updated: September 1, 2025

Disclosures

Terms & Conditions

Privacy Policy

Cookies Policy

AML/CTF Policy

Prohibited Activities Policy

Licenses

Registrations

PLEASE READ CAREFULLY. By signing up for or using the Frontr online platform (operated by FrontierFi LLC, a Wyoming limited liability company, “FrontierFi,” “Frontr,” “we,” “us,” or “our”), you agree to these Terms and Conditions (the “Terms”). If you do not agree, do not use the Services. These Terms incorporate by reference our Privacy Policy and Cookies Policy, as well as any other policies we provide (e.g., AML/CTF Policy).

Frontr is a digital-only money services platform registered with FinCEN as a Money Services Business (MSB) and operating under applicable law, including the Wyoming Money Transmitter License (MTL). We primarily serve business (B2B) customers and may also serve consumers (B2C) where permitted.

“Services” means our website, mobile application, APIs, and related products.

1. Eligibility and Account Requirements

Business focus; consumers allowed where permitted.

  • Minimum Age. You must be at least 18 (or the age of majority in your jurisdiction).
  • Identity/KYC/KYB. You must complete onboarding, including KYC/KYB, and keep information accurate and current.
  • Residency/Access. You (or your business) must be in a jurisdiction where we offer Services and where use is lawful. You represent you are not subject to sanctions and are not on any prohibited list (e.g., OFAC).
  • Business Accounts. If you act for a company, you confirm authority to bind it and that it is duly organized and in good standing.
  • One Account; Accurate Info. Only one account unless we approve otherwise. No aliases or false info. We may reject or close accounts that do not meet requirements.
  • Account Security. You are responsible for safeguarding credentials, MFA, API keys, and devices. Notify us immediately of suspected unauthorized access.
  • Electronic Communications. You consent to receive communications electronically (email, in-app, web). Electronic communications satisfy “in writing” requirements. Retain copies for your records.

2. Description of Services

Frontr provides online payments and exchange facilitation involving fiat currency and supported digital assets, including:

  • Fiat-to-Fiat international transfers;
  • Crypto-to-Fiat transfers (you provide supported crypto; a designated recipient receives fiat);
  • Fiat–Crypto–Fiat conversion for cross-currency settlement;
  • Fiat< – >Crypto exchange (subject to availability, limits, and compliance).

Facilitator only; non-custodial for fiat. We facilitate transactions via regulated banking, liquidity, and payment partners. Frontr does not hold customer fiat funds. We are not your broker, agent, or fiduciary unless we expressly agree in writing.

Availability. Features may vary by user, location, partner, or regulatory considerations. We may add, change, or discontinue Services (with notice where required). We may refuse or cancel transactions for fraud, illegality, policy breaches, compliance, technical error, or events beyond our control. Where a transaction is refused/reversed, we will, if appropriate, refund amounts you paid net of applicable fees.

3. Permitted Uses & Prohibited Activities

You may only use the Services for lawful purposes and in accordance with these Terms. Use of the Services is further subject to our Prohibited Activities Policy, which is incorporated into these Terms by reference and updated from time to time.

By using the Services, you agree not to engage in or facilitate any prohibited activity described in that Policy. We and our service providers may monitor for compliance and may block, reverse, freeze, suspend, report, or close accounts and transactions where we suspect violations. We are not liable for resulting losses where we act in good faith to comply with law or regulatory obligations.

4. Fees, Rates, and Payment Terms

  • Disclosure. We disclose fees before you commit (UI, fee schedule, or order ticket). You agree to pay all fees, taxes, and government levies.
  • Third-Party Fees. Intermediary banks, card networks, and blockchain networks may charge their own fees (e.g., wire fees, card processing, network/miner fees). These are outside our control.
  • Payment Methods. By submitting a transaction, you authorize charges to your linked method(s). If a method fails, you remain responsible for funding and any related fees.
  • No Refunds After Completion. Once executed/settled, fees are non-refundable except as required by law or expressly stated.
  • Exchange Rates & Spreads. We determine quotes based on market data from our partners and may apply a spread. We do not promise the best available rate. Quotes may be time-limited; if you miss the window or if compliance/intermediary delays occur, you may receive a new quote. We will show the source amount, applicable rate, and converted amount before you commit.

5. Compliance with KYC/AML and Legal Requirements

You must comply with all applicable anti-money laundering (AML), counter-terrorism financing (CTF), and related financial regulations when using our Services. By using the Services, you agree to cooperate with our compliance efforts, including providing accurate information and completing required verification.

For full details of our compliance obligations and your responsibilities, please review our AML/CTF Policy, which is incorporated into these Terms by reference and updated from time to time.

6. AML/CTF Policy

Your use of the Services is subject to our AML/CTF Policy, which describes the procedures we apply for customer due diligence, transaction monitoring, reporting obligations, and cooperation with regulators and law enforcement.

Failure to comply with the AML/CTF Policy may result in account suspension, refusal of Services, reporting to regulators, or termination of your account.

7. Privacy & Cookies

Your use of the Services is subject to our Privacy Policy (how we collect/use/share data and your rights) and Cookies Policy (how we use cookies and similar tech). Please review those documents. Blocking certain cookies may impair security features (e.g., MFA) or functionality.

8. Intellectual Property; API Terms; Feedback

  • Ownership. The Services, software, content, brand elements, and documentation are owned by FrontierFi or its licensors.
  • License. We grant you a limited, non-exclusive, non-transferable, revocable license to use the Services for your internal purposes as intended. No reverse engineering, resale, scraping, or removal of notices.
  • API Terms. If you use our APIs: (i) protect keys; (ii) comply with rate limits; (iii) no benchmarking or competitive analysis publication without consent; (iv) we may revoke access at any time; (v) uptime is not guaranteed.
  • Feedback. You grant us a perpetual, royalty-free license to use suggestions or feedback.

9. Electronic Communications & E-SIGN (Consumers)

  • For consumers where applicable: by using the Services, you consent to receive legally-required disclosures electronically. You confirm you have access to email and a modern browser to view, save, and print documents. You may withdraw consent by contacting legal@frontrpay.com; withdrawal may limit or end your access to the Services where paper delivery is impracticable. You may request paper copies (fees may apply where permitted).

10. Consumer Disclosures (Where Applicable)

If you use the Services as a consumer (not on behalf of a business), the following may apply:

  • Electronic Fund Transfers (Reg E). Certain consumer transactions may be covered by the Electronic Fund Transfer Act and its implementing Regulation E, including error-resolution rights and timelines. Where Reg E applies, we will provide required disclosures and handle errors in accordance with law.
  • Remittance Transfers (Reg E Subpart B). For eligible consumer cross-border transfers, we will provide pre-payment disclosures and receipts, and honor applicable cancellation, refund, and error-resolution rights.
  • Card/ACH Rules. If you fund via card or ACH, you agree to applicable network/NACHA rules. You must only use accounts you are authorized to use.

These consumer protections do not apply to business use.

11. Dispute Resolution & Arbitration Agreement

PLEASE READ—AFFECTS YOUR RIGHTS. Except for small-claims and certain IP/injunctive matters: all disputesarising out of or relating to the Services or these Terms will be resolved by binding arbitration on an individual basisunder the U.S. Federal Arbitration Act (FAA).

  • Informal Resolution First. Email legal@frontrpay.com with a written description; we’ll try to resolve within 30 days.
  • Administrator & Rules. Arbitration will be administered by the American Arbitration Association (AAA) under the Consumer Arbitration Rules (for consumer claims) or the Commercial Arbitration Rules (for business claims), as applicable.
  • Venue & Law. The arbitrator applies Wyoming law (conflict rules excluded). The venue will be reasonably convenient (e.g., your Wyoming county, remote, or as the arbitrator directs).
  • No Class Actions. Claims must be brought individually; no class/collective/representative proceedings.
  • Fees. We will reimburse consumer filing fees for claims under $10,000 unless the arbitrator finds the claim frivolous. Each party bears its own attorneys’ fees unless law provides otherwise.
  • Opt-Out. You may opt out of arbitration within 30 days of first accepting these Terms by sending notice via email to legal@frontrpay.com. Include your name, address, account email, and a clear statement opting out of arbitration.
  • Severability. If the class waiver is unenforceable, this arbitration clause is void; disputes then proceed in court as per Governing Law & Jurisdiction.

NOTICE: BY AGREEING TO ARBITRATE, YOU WAIVE THE RIGHT TO JURY TRIAL (EXCEPT AS ALLOWED ABOVE).

12. Disclaimers

The Services are provided “AS IS” and “AS AVAILABLE.” To the maximum extent permitted by law, we disclaim all warranties, express or implied, including merchantability, fitness for a particular purpose, non-infringement, accuracy, uninterrupted availability, and security.

Without limiting the foregoing:

  • Market/Rate Info. Quotes, rates, and market data may be delayed, interrupted, or inaccurate; we do not guarantee best rates.
  • Third-Party Dependencies. Banks, payment processors, liquidity providers, blockchain networks, and telecom/hosting providers may experience outages or congestion.
  • No Advice. We do not provide financial, investment, tax, or legal advice.

13. Limitation of Liability

To the fullest extent permitted by law, FrontierFi and its affiliates, officers, directors, employees, and agents are not liablefor indirect, incidental, consequential, special, exemplary, or punitive damages, or lost profits, revenue, goodwill, or data, arising out of or related to the Services or these Terms, even if advised of the possibility.

If liability cannot be disclaimed, our aggregate liability is limited to the greater of:
(a) the total fees (excluding principal amounts transacted) you paid to FrontierFi in the three (3) months before the event giving rise to the claim; or (b) USD $100.

We are not responsible for: (i) failed, delayed, blocked, or misrouted transactions; (ii) re-quotes or FX slippage; (iii) unauthorized access not caused by our gross negligence; (iv) acts/omissions of banks, partners, networks, or regulators; (v) force majeure (including cyberattacks, network congestion, natural disasters, war, pandemic, or government actions).

Your sole remedy for dissatisfaction is to stop using the Services.

14. Suspension, Termination, and Account Closure

You may stop using the Services at any time and request closure of your account (subject to resolution of pending items). We may suspend, limit, or terminate access at our discretion and without liability where permitted by law, including for suspected violations, incomplete KYC/KYB, sanctions matches, fraud risk, security threats, or regulatory orders.

Because Frontr does not hold customer fiat funds, any post-termination refunds or reversals occur through your linked payment methods or applicable partner institutions, subject to law and our compliance obligations.

15. Governing Law & Jurisdiction

These Terms are governed by the laws of the State of Wyoming, and applicable U.S. federal law, without regard to conflict-of-law rules. For disputes not subject to arbitration or small claims, the parties submit to the exclusive jurisdiction of the state or federal courts in Wyoming and waive objections to venue or forum non conveniens. The U.N. Convention on Contracts for the International Sale of Goods does not apply.

16. Miscellaneous

  • Entire Agreement. These Terms (plus incorporated policies) are the entire agreement and supersede prior understandings.
  • Amendments. We may update Terms; material changes will be communicated (email or in-product notice). Continued use after the effective date = acceptance.
  • No Waiver. A failure to enforce is not a waiver.
  • Severability. If a term is unenforceable, the remainder stays in effect; modify the term to the minimum necessary to be enforceable.
  • Assignment. You may not assign without our consent; we may assign to an affiliate or successor (e.g., merger, asset sale).
  • Taxes & Withholding. You are responsible for all applicable taxes; we may withhold where required by law.
  • Force Majeure. We are excused for delays/failures due to causes beyond reasonable control, including partner/bank outages and blockchain congestion.
  • Beta/Preview Features. May be modified or withdrawn at any time and are provided AS IS.

17. Contact & Notices

If you have questions, concerns, or legal notices related to these Terms, contact us at: legal@frontrpay.com

We will send official notices to the email address associated with your account. It is your responsibility to keep your contact information accurate and up to date.

Acknowledgment. By using the Services, you confirm that you have read, understood, and agree to these Terms.

Table of contents

  1. Eligibility and Account Requirements
  2. Description of Services
  3. Permitted Uses & Prohibited Activities
  4. Fees, Rates, and Payment Terms
  5. Compliance with KYC/AML/CTF and Legal Requirements
  6. AML/CTF Policy
  7. Privacy & Cookies
  8. Intellectual Property; API Terms; Feedback
  9. Electronic Communications & E-SIGN (Consumers)
  10. Consumer Disclosures (Where Applicable)
  11. Dispute Resolution & Arbitration Agreement
  12. Disclaimers
  13. Limitation of Liability
  14. Suspension, Termination, and Account Closure
  15. Governing Law & Jurisdiction
  16. Miscellaneous
  17. Contact & Notices

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This material is for informational purposes only and is not intended to provide accounting, legal, tax advice, or investment recommendations. Any services made available in the future will be subject to and made on the terms of the legal agreements relating thereto.

FrontierFi LLC d/b/a Frontr is registered as an MSB with FinCEN (MSB Registration Number: 31000294166109) and is in the process of obtaining a Money Transmitter License in the State of Wyoming (MTL Number: xxxxxxx).

For legal reasons, including adherence to OFAC sanctions compliance, we do not service individuals, corporations and institutions located/established in or residents of the following countries: Afghanistan, Belarus, Burma (Myanmar), Côte D'Ivoire (Ivory Coast), Central African Republic, The Democratic Republic of the Congo, Cuba, Iran, Iraq, Liberia, Libya, North Korea (DPRK), Gaza Strip, Russian Federation, Somalia, South Sudan, Sudan, Syria, Ukraine, Venezuela,Yemen, Zimbabwe.

© 2025 FrontierFi LLC d/b/a Frontr. All rights reserved.

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