Circle / Banking Due Diligence Package.

Executive Overview

SendGlobe is a Commercial Certainty Infrastructure platform.

Commercial Certainty Infrastructure is a standardized framework that reduces Commercial Uncertainty by enabling counterparties to establish Commercial Readiness, define expectations, secure commitments, verify conditions, and achieve predictable commercial outcomes.

SendGlobe operates separately from settlement, custody, and payment rail functions.

Platform Functions

SendGlobe may:

• ✓support Commercial Readiness;
• ✓facilitate Commercial Agreements;
• ✓record Verification Outcomes;
• ✓determine Settlement Eligibility according to predefined workflow rules;
• ✓maintain audit records.

Non-Custodial Architecture

SendGlobe does not:

• ×hold funds;
• ×receive funds;
• ×move funds;
• ×custody assets;
• ×maintain customer accounts;
• ×operate payment rails;
• ×act as an escrow provider;
• ×act as a trustee;
• ×act as a financial institution;
• ×exercise discretionary authority over settlement decisions.

Settlement Eligibility Framework

Settlement Eligibility is a workflow status reached when predefined conditions established by counterparties have been satisfied according to applicable workflow requirements.

Settlement Eligibility is not:

• ×settlement execution;
• ×movement of funds;
• ×custody;
• ×asset transfer;
• ×dispute adjudication.

Settlement execution remains the responsibility of Independent Settlement Infrastructure.

Responsibility Allocation

Governance

SendGlobe maintains governance processes supporting:

• —compliance oversight;
• —security oversight;
• —risk management;
• —operational resilience.

Security

Security controls are designed to support:

• —platform integrity;
• —auditability;
• —operational resilience;
• —information protection.

Compliance

Commercial Readiness may include:

• —identity verification;
• —sanctions screening;
• —eligibility review;
• —compliance controls.

Core Principle