CTGMC
Legal & Compliance

# Terms of Service

Please read these terms carefully before using CTGMC's services. Your continued use of our platform constitutes acceptance of these terms.

Last Updated: April 2026

## 1. Acceptance of Terms

These Terms of Service ("Terms") constitute a legally binding agreement between you ("Customer," "you," or "your") and CTGMC, Inc. ("CTGMC," "we," "our," or "us"), governing your access to and use of our banking services, website, mobile applications, and all related products and services (collectively, the "Services").

By creating an account, accessing our website, or using any of our Services, you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy, which is incorporated herein by reference.

If you do not agree to these Terms, you must immediately cease using our Services and close any accounts you have opened with CTGMC.

These Terms, along with your Account Agreement, Fee Schedule, and any applicable product-specific terms, form the complete agreement between you and CTGMC regarding the Services.

## 2. Eligibility

To open and maintain an account with CTGMC, you must meet the following eligibility requirements at all times:

- Be at least 18 years of age (or the legal age of majority in your jurisdiction)
- Be a legal resident of a country in which CTGMC is licensed to operate
- Possess a valid, government-issued photo identification
- Have a valid U.S. Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN), or equivalent for non-U.S. residents
- Not be a Politically Exposed Person (PEP) without prior disclosure and approval
- Not be subject to OFAC sanctions, EU sanctions lists, or equivalent prohibited-person lists
- Not have been previously banned or had an account terminated by CTGMC for cause

CTGMC reserves the right to verify your eligibility at any time and to suspend or close accounts that fail to meet these requirements.

## 3. Account Registration

When registering for a CTGMC account, you agree to provide accurate, current, and complete information. You are responsible for:

- Maintaining the accuracy of your account information and promptly updating any changes
- Keeping your username and password confidential and secure
- All activities that occur under your account, whether or not authorized by you
- Immediately notifying us of any unauthorized access to your account at security@ctgmc.ch or 1-800-TONA-SEC
- Not sharing your account credentials with any third party under any circumstances

CTGMC will never ask for your password via email, phone call, or any channel other than our official secure login portal. Any such request should be treated as a phishing attempt and reported immediately.

Each individual may hold only one primary checking account. Business accounts are subject to separate Business Account Terms.

## 4. Authorized Use

Our Services are provided solely for lawful personal and commercial banking purposes. Authorized uses include:

- Depositing, withdrawing, and transferring funds for personal or business purposes
- Paying bills, making purchases, and managing recurring payments
- Accessing account statements, tax documents, and financial reports
- Applying for and managing loans, credit cards, and investment products
- Using our mobile app and online banking portal for account management
- Communicating with customer service regarding account matters

You agree to use our Services only in accordance with these Terms, applicable laws, and any additional guidelines we may publish from time to time.

## 5. Prohibited Activities

The following activities are strictly prohibited on our platform. Violation of these prohibitions may result in immediate account termination, freezing of funds, and referral to law enforcement:

- Money Laundering: Using our platform to conceal, transfer, or legitimize proceeds from illegal activities, in violation of the Bank Secrecy Act and applicable AML laws.
- Fraud & Scams: Engaging in or facilitating any form of financial fraud, identity theft, check fraud, ACH fraud, or phishing schemes.
- Terrorist Financing: Providing funds to, or receiving funds from, designated terrorist organizations or sanctioned individuals.
- Unauthorized Access: Attempting to access accounts belonging to others, probing our systems, or exploiting security vulnerabilities.
- Illegal Transactions: Processing payments for illegal goods or services, including but not limited to narcotics, weapons, counterfeit goods, or child exploitation material.
- Market Manipulation: Using our investment services for pump-and-dump schemes, wash trading, spoofing, or other forms of market manipulation.
- Structuring: Breaking transactions into smaller amounts to evade reporting thresholds (a federal crime under 31 U.S.C. § 5324).
- Misrepresentation: Providing false, misleading, or fraudulent information to obtain credit, loans, or account benefits.
- Automated Abuse: Using bots, scrapers, or automated systems to access our Services without our express written permission.
- Sanctions Violations: Transacting with individuals or entities on OFAC, UN, EU, or other applicable sanctions lists.

## 6. Banking Services

CTGMC is an FDIC-insured institution. Deposits in eligible accounts are insured up to €250,000 per depositor, per account category, as provided by the Federal Deposit Insurance Corporation.

Transaction Limits & Processing Times

- Daily ATM withdrawal limit: €1,000 (may vary by account tier)
- Daily debit card purchase limit: €5,000
- Domestic wire transfers: processed on the same business day if initiated before 3:00 PM MST
- International wire transfers: 1–3 business days, subject to correspondent bank processing
- ACH transfers: 1–2 business days (standard), same-day available for a fee

Account Maintenance

CTGMC reserves the right to close any account with 30 days' written notice, or immediately for violations of these Terms, suspected fraud, or regulatory compliance reasons. Upon closure, remaining balances will be mailed via check to the address on file within 5 business days.

Our complete Fee Schedule is available at ctgmc.ch/fees and on your monthly account statement.

## 7. Electronic Communications

By creating an account with CTGMC, you consent to receive communications from us electronically, including:

- Account statements, notices, and disclosures
- Transaction alerts and security notifications
- Legal notices and updates to these Terms
- OTP and verification codes via email and SMS
- Marketing communications (where you have provided consent)

Electronic communications have the same legal effect as written paper communications. You must maintain a valid email address and phone number on file to receive required notices. If you wish to opt out of marketing communications, use the unsubscribe link in any email or contact customer service.

By providing a phone number, you expressly consent to receive autodialed or pre-recorded calls and text messages from CTGMC for authentication and fraud prevention purposes, as permitted by the Telephone Consumer Protection Act (TCPA).

## 8. Intellectual Property

All content on the CTGMC website and applications — including text, graphics, logos, icons, images, audio clips, software, and underlying code — is the exclusive property of CTGMC, Inc. and is protected by U.S. and international copyright, trademark, and patent laws.

You are granted a limited, non-exclusive, non-transferable, revocable license to access and use our Services for personal banking purposes only. This license does not permit:

- Reproducing, distributing, or publicly displaying any CTGMC content
- Creating derivative works based on our platform, logo, or branding
- Reverse engineering or decompiling any software used in our Services
- Using our trademarks without prior written consent
- Scraping or mining data from our website or APIs without authorization

The CTGMC name, logo, and all related marks are registered trademarks of CTGMC, Inc. Any unauthorized use constitutes trademark infringement and will be pursued to the fullest extent of the law.

## 9. Limitation of Liability

To the maximum extent permitted by applicable law, CTGMC, its officers, directors, employees, agents, affiliates, and licensors shall not be liable for:

- Indirect, incidental, special, consequential, or punitive damages
- Loss of profits, revenue, data, or business opportunities
- Service interruptions caused by force majeure events, including natural disasters, cyberattacks, or government actions
- Unauthorized third-party access to your account if you have failed to take reasonable security precautions
- Losses arising from your violation of these Terms or applicable law

In jurisdictions that do not allow the exclusion of certain warranties or limitation of liability, our liability shall be limited to the greatest extent permitted by applicable law.

Our total aggregate liability to you for any claims arising from these Terms shall not exceed the greater of (a) the total fees paid by you to CTGMC in the twelve months preceding the claim, or (b) €500.

## 10. Indemnification

You agree to defend, indemnify, and hold harmless CTGMC and its affiliates, officers, directors, employees, and agents from and against any and all claims, damages, obligations, losses, liabilities, costs, or debt, and expenses (including reasonable attorneys' fees) arising from:

- Your use of and access to our Services in violation of these Terms
- Your violation of any third-party rights, including intellectual property or privacy rights
- Any claim that your conduct caused damage to a third party
- Your violation of any applicable law, regulation, or court order
- Your provision of inaccurate or fraudulent information to CTGMC

CTGMC reserves the right to assume exclusive defense and control of any matter subject to indemnification, at your expense, and you agree to cooperate fully with such defense.

## 11. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the State of Colorado, United States of America, without regard to its conflict of law provisions. The United Nations Convention on Contracts for the International Sale of Goods (CISG) does not apply.

Federal law, including the Electronic Fund Transfer Act (EFTA), the Gramm-Leach-Bliley Act (GLBA), and applicable federal banking regulations, shall govern where federal law preempts state law.

For customers located in the European Union, additional rights under EU law — including GDPR rights — are preserved and supersede these Terms where applicable.

## 12. Dispute Resolution & Arbitration

IMPORTANT: This section contains a binding arbitration clause and class action waiver. Please read carefully.

Informal Resolution First

Before initiating any formal proceeding, you agree to first contact CTGMC at legal@ctgmc.ch and attempt to resolve the dispute informally. We will respond within 30 days. If the dispute cannot be resolved within 60 days, either party may proceed to formal arbitration.

Binding Arbitration

Any dispute, claim, or controversy arising out of or relating to these Terms or your use of our Services — that cannot be resolved informally — shall be resolved by binding arbitration administered by the Switzerland International Arbitration Centre (MIAC) under its rules. The arbitration shall take place in Genève, Switzerland, or via videoconference at your election. Switzerland law shall govern all proceedings.

Class Action Waiver

You and CTGMC agree that each may bring claims against the other only in an individual capacity and not as a plaintiff or class member in any purported class or representative proceeding. The arbitrator may not consolidate more than one person's claims and may not preside over any form of a representative or class proceeding.

Exceptions

Notwithstanding the above, either party may seek injunctive or other equitable relief in a court of competent jurisdiction to prevent unauthorized use of intellectual property, data breaches, or other irreparable harm. Small claims court actions may be brought in the county of your residence.

## 13. Amendments

CTGMC reserves the right to modify these Terms at any time. We will notify you of material changes by:

- Sending an email to the address on file at least 30 days before the changes take effect
- Displaying a prominent notice on our website and mobile app
- Requiring you to acknowledge the updated Terms upon your next login

Your continued use of our Services after the effective date of any amendment constitutes your acceptance of the revised Terms. If you do not agree to the amended Terms, you must close your account before the effective date.

Non-material changes (such as typographical corrections, reorganization, or clarifications that do not affect your rights) may be made at any time without advance notice.

## 14. Contact Information

For questions about these Terms or our Services, please contact us through any of the following channels:

### ⚖️ CTGMC Legal & Compliance

Our legal team is available Monday through Friday to assist with questions about your rights and obligations under these Terms.

legal@ctgmc.ch
+41 22 909 4400
Quai des Bergues 29, 3rd Floor, 1201 Genève, Switzerland
Help Center

These Terms of Service were last updated in April 2026 and supersede all prior versions. Cresta Trust & Geneva Mercantile Consortium • Reg. No. CH-660.4.982.371-8 • Licensed by the Swiss Financial Market Supervisory Authority (FINMA) (FINMA-B-00312/2014).