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LEGAL · RESPONSIBILITY

Responsibility Matrix.

Defines the allocation of responsibilities between SendGlobe, counterparties, and Independent Settlement Infrastructure.

OVERVIEW

Purpose

This Responsibility Matrix defines the allocation of responsibilities between SendGlobe, counterparties, and Independent Settlement Infrastructure.

The purpose of this document is to clearly distinguish Commercial Certainty Infrastructure functions from settlement, custody, and financial services functions.

FOUNDATION

Core Principle

The counterparties define the rules.

SendGlobe applies the rules.

Independent Settlement Infrastructure operates according to those rules.

The outcome follows the agreement.

TABLE

Responsibility Allocation

Function SendGlobe Counterparties Independent Settlement Infrastructure
Commercial Readiness✓
Identity Verification✓
Sanctions Screening✓
Compliance Review✓
Eligibility Review✓
Commercial Agreement Creation✓✓
Definition of Conditions✓
Definition of Deliverables✓
Definition of Acceptance Requirements✓
Commitment Establishment✓✓
Verification Outcome Recording✓
Settlement Eligibility Determination✓
Audit Record Maintenance✓
Workflow Status Management✓
Contractual Performance✓
Delivery of Goods or Services✓
Custody of Assets✓
Maintenance of Accounts✓
Operation of Payment Rails✓
Movement of Funds✓
Settlement Execution✓
Regulatory Obligations Related to Settlement Services✓
NON-CUSTODIAL DECLARATION

Activities Not Performed By SendGlobe

SendGlobe does not:

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

Settlement Eligibility

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

Settlement Eligibility does not itself constitute:

  • —movement of funds;
  • —transfer of assets;
  • —custody of property;
  • —legal entitlement;
  • —settlement execution by SendGlobe.
SUMMARY

Summary

SendGlobe provides Commercial Certainty Infrastructure.

Commercial Certainty Infrastructure supports Commercial Readiness, Commercial Agreements, Verification Outcomes, and Settlement Eligibility.

Independent Settlement Infrastructure remains responsible for custody, payment rails, fund movement, and settlement execution.

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