11 October 2018

OneCoin - WHITE PAPER (Bạch Thư/Sách Trắng)

White Paper

TAKE CHARGE OF THE FINANCIAL REVOLUTION

Contents
“And yet, why might citizens hold virtual currencies rather than physical dollars, euros, or sterling? Because it may one day be easier and safer than obtaining paper bills, especially in remote regions. And because virtual currencies could actually become more stable... So in many ways, virtual currencies might just give existing currencies and monetary policy a run for their money. The best response by central bankers is to continue running effective monetary policy, while being open to fresh ideas and new demands, as economies evolve”

CHRISTINE LAGARDE, IMF Managing Director Bank of England conference, London, September 29, 2017, Speech “Central Banking and Fintech—A Brave New World?”


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“For now, virtual currencies such as Bitcoin pose little or no challenge to the existing order of fiat currencies and central banks. Why? Because they are too volatile, too risky, too energy intensive, and because the underlying technologies are not yet scalable. Many are too opaque for regulators; and some have been hacked. But many of these are technological challenges that could be addressed over time. Not so long ago, some experts argued that personal computers would never be adopted, and that tablets would only be used as expensive coffee trays. So I think it may not be wise to dismiss virtual currencies.”
CHRISTINE LAGARDE, IMF Managing Director Bank of England conference, London, September 29, 2017, Speech “Central Banking and Fintech—A Brave New World?” 

IMPORTANT NOTICE

The purpose of this Whitepaper is to present ONE, the OFCs and the related ONE Ecosystem to potential participants in connection with the proposed Offering. The information set forth below may not be exhaustive and does not imply any elements of a contractual relationship. Its sole purpose is to provide relevant and reasonable information to potential purchasers for them to determine whether to undertake a thorough analysis of the ONE, OFCs and the ONE Ecosystem with the intent of purchasing OFCs offered.

Please note that due to regulatory specifics the present Offering is not and will not be available and valid for the following countires: China, Bangladesh, Nepal, Macedonia, France, The United States, Bolivia, India, Pakistan, Algeria, Morocco, Germany, Mexico.

Nothing in this Whitepaper shall be deemed to constitute a prospectus of any sort or a solicitation for investment, nor does it in any way pertain to an offering or a solicitation of an offer to buy any securities in any jurisdiction. This document is not composed in accordance with, and is not subject to, laws or regulations of any jurisdiction, which are designed to protect investors. The OFC is a utility token. It is not intended to constitute securities or financial instruments in any jurisdiction.

This Whitepaper does not constitute or form part of any opinion on any advice to sell, or any solicitation of any offer by the seller of the OFCs (the “OFCs Provider”) to purchase any OFC, nor shall it, or any part of it, nor the fact of its presentation form the basis of or be relied upon in connection with any contract or investment decision. It has not been registered under the Securities Act or any other securities laws of any state of the United States or the securities laws of any other country, including the securities laws of any jurisdiction in which a potential coin holder is a resident. No regulatory authority has examined or approved of any of the information set out in this Whitepaper. No such action has been or will be taken under the laws, regulatory requirements or rules of any jurisdiction. The publication, distribution or dissemination of this Whitepaper does not imply that the applicable laws, regulatory requirements or rules have been complied with.

The OFCs cannot be used for any purposes other than those provided in this Whitepaper.

The OFCs are not intended for sale or use in any jurisdiction where sale or use of digital tokens may be prohibited.
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The OFC confers no other rights in any form, including but not limited to, any ownership, distribution (including but not limited to profit), redemption, liquidation, proprietary (including all forms of intellectual property), or other financial or legal rights, other than those specifically described in this Whitepaper. Certain statements, estimates and financial information contained in this Whitepaper constitute forward-looking statements or information. Such forward-looking statements or information involve known and unknown risks and uncertainties, which may cause actual events or results to differ materially from the estimates or the results implied or expressed in such forward-looking statements. This Whitepaper can be modified to provide more detailed information.

This English language Whitepaper is the primary official source of information about the OFCs and the present Offering. The information contained herein may from time to time be translated into other languages or used during written or verbal communications with existing and prospective customers, partners etc. During such translation or communication, some of the information contained herein may be lost, corrupted, or misrepresented. The accuracy of such alternative communications cannot be guaranteed. In the event of any conflicts or inconsistencies between such translations and communications and this official English language Whitepaper, the provisions of this English language original document shall prevail.
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MARKET ANALYSIS

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There are many reasons why cryptocurrencies could become the generally accepted payment means of the future. Paying with cryptocurrencies offers advantages to both customers and retailers, making them attractive to all parties involved in a transaction.

LOWER TRANSACTION FEES 

As opposed to credit card companies, which usually charge up to 3% in processing fees, which can add up quickly. In contrast, cryptocurrency transaction fees usually do not exceed 1%, making them desirable for retailers.

FASTER TRANSACTIONS 

New and faster blockchains are facilitating faster transactions, reaching up to 10,000 transactions per second.

PEER-TO-PEER EXCHANGES 

One of the main and most well-known benefits of cryptocurrency payments is the peer-to-peer exchange, meaning the removal of a middleman. This means that the technology is designed to facilitate (at least in theory) instantaneous, cheap and secure settlement of values without any middleman such as a bank.

SECURE TRANSACTIONS 

Another significant benefit of cryptocurrencies is their security: a blockchain is virtually impossible to be manually changed or hacked due to the different security functions such as encryption of the blockchain ledger.

REWARD INCENTIVES 

Many retailers and online platforms that accept cryptocurrencies for payment have developed incentive and reward programs for doing so. For example, customers can receive discounts, save on transaction fees or even receive additional coins. The many potential advantages of payment coins have led to the fact that there is now a large number of cryptocurrencies aiming to become generally or widely accepted payment means. Out of the total 1,910 cryptocurrencies on listed on CoinMarketCap, it is expected that about 10-20% of these coins are payment coins or payment tokens. What will differentiate these coins and ultimately lead to acceptance and usage by a large group of retailers will be the size of the partner network, the speed and consequently transaction efficiency of the blockchain, the incentives offered to retailers and consumers and the coin’s price volatility.

EXECUTIVE SUMMARY

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The ONE cryptocurrency offered to participants through the OFC bundles during the present Offering, has been designed to meet demand as its adoption grows. Scalability has proven to be a serious issue for retailers and one of their main reasons for discarding cryptocurrencies. That makes ONE a viable alternative to most cryptocurrencies currently offered on the market.

The fact that cryptocurrencies are not yet mainstream can be linked to factors such as scalability issues, lack of understanding of the concept of cryptocurrencies by mass users, volatility and safety issues, and the risks related to them. The fact that cryptocurrencies operate in a highly unregulated industry and have a reputation of being “risky”, “pyramids” or “bubbles” presents a serious barrier for their mass scale adoption by most users and retailers.

The present Offering aims to give access to the blockchain-based cryptocurrency OneCoin to a wider audience. Used by over 3 million people globally, the coin (ONE) has clear advantages for mass users and retailers that would prefer an alternative to emerging coins, which has improved accessibility, security and efficiency. The KYC/KYB and AML compliance procedures as well as the ability of the system to make instant, low cost and secure transfers make the coin reliable, safe and AML compliant.

During the Offering, AHS Latam S. A. gives access to OFC bundles as well as added incentives described in Chapter 4 (“Token Model”) of the Whitepaper. After January 7th, 2019, the OFC bundles will no longer be available, and participants will be able to convert their accumulated OFCs into ONEs in accordance with the Release Strategy and Mandatory Discount Period described in Chapter 6 and in the Coin Offering Terms & Conditions.

Based on transparency, usability and a truly global reach, the coin has the chance to become the preferred payment tool by retailers. The present Offering can be considered as the next step of the adoption of ONE on a much bigger scale.

To connect as many retailers as possible worldwide and make it more convenient for them to use a single cross-border transaction tool will be the next big milestone for the OneCoin cryptocurrency. The company has already created its own blockchain to support such a move and a platform called DealShaker, gathering sellers and buyers together in one place of commerce.

INDUSTRY OVERVIEW

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The blockchain market is characterized by intensely competitive conditions with players ranging from a growing number of start-ups to established companies. Most of the big corporations, holding over 45% of the global market, focus on acquisitions to expand their customer base.

Blockchain-based cryptocurrency start-ups offer innovative solutions and revolutionize the way traditional financial institutions have been doing business, especially with regards to payment processing and exchange trading.

Companies offering cryptocurrencies operate in a relatively unregulated environment, since the industry is new and influenced by constant changes in existing legal framework as response to the various risks and challenges related to its usage, exchange and trading. However, definite steps have been taken toward implementing a legal framework that is expected to influence the usage and exchange of cryptocurrencies.

For example, the EU legal and regulatory framework is mainly focused on preventing the funding of terrorist activities using cryptocurrencies. Therefore, its “Action Plan for Strengthening the Fight Against Terrorist Financing” (2016) provides a set of strict rules on cryptocurrency regulation within the expanded framework of the EU’s AML directive that guarantees tighter regulations on digital currency platforms. On the other hand, the US Government acknowledges digital currency trading as electronic money transfer and requires cryptocurrency exchanges to follow Anti-Money Laundering (AML) laws, imposed by the organizations in charge of enforcing the policies and regulations for financial companies operating within the US borders - the U.S. Treasury Department and the FinCEN (Financial Crimes Enforcement Network).

The focus of the governmental organizations and central banks is set on designing rules that require compliance systems to guarantee the transparency and safety of payments and transactions. This is also evident from the most recent legal and regulatory changes on key cryptocurrency markets like China and Japan.

Regulators have acknowledged the significance of blockchain technology for solving complex problems in various industries. A report by World Economic Forum, “Deep Shift Technology Tipping Points and Societal Impact,” presented results from a survey where respondents shared their views on “21 “tipping points” – moments when specific technological shifts hit mainstream society.” Eight hundred (800) executives and experts from the information and communications technology sectors said they expected 10% of the GDP to be stored on blockchain or blockchain-related technology by 2025. The results show that an increasing number of organizations and professionals understand the importance of blockchain technology and the expected impact it could have on various industries.

Blockchain-based cryptocurrencies eliminate the need for third-party middlemen, making payments and transactions with cryptocurrencies more global, faster and cheaper. OneCoin has offered the biggest, mass cryptocurrency to the retail market, based on transparency, usability and a truly global reach. With its over 3 million users, the coin has the chance to become the preferred payment tool by retailers and mass users. The KYC/KYB and AML compliance procedures, along with the ability of the system to make instant transfers make the coin reliable, safe and compliant.
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Convenience of Payments and Transactions with Cryptocurrencies 

One of the biggest challenges for decentralized cryptocurrencies has been the issue of scalability - their inability to meet demand as they grow. Why? Because the more wallets are added to any given cryptocurrency, the slower every verification becomes, because it must be processed from every wallet on the net. An example of the scalability issue is the one-megabyte size limitation of the block in the Bitcoin blockchain that resulted in increasing transaction fees and delayed transaction processing.

The scalability challenge points to another issue – cryptocurrencies are not yet mainstream-friendly despite their advantages for mass users. One reason is that mass users lack understanding of the concept of cryptocurrencies to be able and willing to use it. Another is that cryptocurrencies are known to be volatile, unsafe and risky, being a serious barrier for mass scale adoption by the majority of users and merchants.

OneCoin is focused on providing a blockchain-based cryptocurrency that improves accessibility, safety and efficiency, therefore offering instant, low cost, convenient and secure transactions to retailers and mass users.

The present Offering gives access to the blockchain-based cryptocurrency ONE with AN ACTUAL USER BASE OF OVER 3 MILLION USERS WORLDWIDE.

A Coin for the Mass User and the Retail Market 

Designed for the retail market and mass consumers, the ONE has entered its next growth stage, with the present Offering aimed to make the coin widely accessible to the open public. The Offering gives access to OFC “tokens” and the chance to convert OFCs into ONEs on January 8, 2019 according to the Release Strategy. Now that scalability has proven to be a serious issue for retailers and the main reason for them to discard other cryptocurrencies because of their limitations, ONE has proven to be truly global, easy to use and capable of making instant transfers. On DealShaker, the global e-commerce platform, ONE is used to utilize daily discount deals by both sellers and buyers. So far, the coin was accessible only to an exclusive community of users. It has been used and tested with various products and services. Now, the present Offering is the first step to the public adoption of the coin.

ABOUT ONE

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Key Features of the Coin ONE 

is cryptographically secure, peer-to - peer cryptocurrency that allows instant and cost saving payments. Its global accessibility and finite number of 120 billion ONEs make the coin one of the biggest reserve currencies worldwide.

GLOBAL ACCESS 

OneCoin users can make instant payments and cross-border money transfers 

UNIQUE ECOSYSTEM 

OneCoin is dedicated to establishing a coin suitable for mass market usage, globally. 

STABLE 

The coin has low volatility and is not affected by inflation. 

TRANSPARENT 

OneCoin is transparent and secure, maintaining a continuously updating digital ledger of all transactions. 
The blockchain systems resemble tamper-proof ledgers of transactions, guaranteed by the merkle tree roots attached to each block of transactions. In this regard the OneCoin system provides the opportunity to users to access the digital ledger with all the blocks and transactions in it. What is a Merkle tree? Merkle tree is a tree in which every leaf node is labeled with a data block and every non-leaf node is labeled with the cryptographic hash of the labels of its child nodes. Hash trees allow efficient and secure verification of the contents of large data structures. Merkle trees are a generalization of hash list of the transactions in the current block. This means that if one of the transactions is modified or if the order of any of the transactions is changed, the merkle tree will also change. If one of the previous block merkle root is changed, this means its hash will change too and so will all the next blocks hashes.

INSTANT TRANSACTIONS 

In line with its vision, OneCoin offers cross-border payments and remittances at a low cost thus increasing financial inclusion and transparency. 
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SAFE 

Based on cryptography, OneCoin cryptocurrency is safe and difficult to counterfeit. The ongoing data- backups performed by the company guarantee that there is low risk of stolen coins.
OneCoin blockchain use proof-of-work (POW) that involves scanning for a value. When hashed, such as with SHA-256, the hash begins with a needed target (for example a number of zero bits). The proof-of-work is implemented by incrementing a nonce in the block until a value is found that gives the block’s hash the required target. Once the CPU effort has been expended to make it satisfy the POW, the block cannot be changed without redoing the work. As later blocks are chained after it, the work to change the block would include redoing all the blocks after it.

SCALABLE 

The OneCoin blockchain can handle millions of user accounts. It has the capacity to process cross- border global payments and the capability to make unbounded transaction processing. The private management of the blockchain keeps the storage costs under control and prevents possible scalability issues that usually pertain to public blockchain.
Since the OneCoin blockchain is centralized, the system uses one copy of blockchain data for several wallets. That means that if there are 4 or more wallets in a decentralized cryptocurrency, then there must be the same number of copies of the blockchain data. In the case of a centralized blockchain, however, it would be necessary to have, for example, only 2 copies of the data, so 3 wallets would be able to work with one copy, and other wallets with other copy. In this case, instead of performing a 4-times verification, only 2-times verification on 2 nodes is enough and will still be as true as 4 times verification of 4 different nodes. The OneCoin Blockchain can handle millions of user accounts on standard high-spec hardware (e.g. equivalent to current AWS 2xlarge instances) and this can be scaled up by upgrading to more powerful hardware (e.g. equivalent to AWS 4xlarge, 8xlarge, 16xlarge instances or higher) as required.

SECURE 

Because the company performs ongoing data-backups, there is a low risk of lost coins due to, for example, malfunction of the user’s hardware or theft of coins. Except live monitoring of the system and regular ongoing of backups of the whole system, the OneCoin blockchain implements DRP (Disaster Recovery Plan) to be able to respond adequately and in time when a disaster such as natural, environmental or man-made occurs (for example, an act of attack). DRP is a set of procedures to recover and protect a business IT infrastructure in the event of a disaster.
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KYC & AML COMPLIANT 

The OneCoin blockchain does not allow anonymous transactions. The KYC (know-your-customer) information of users is stored directly in the blockchain. The KYC process provides additional monitoring on possible violations of the AML and CFT regulations. 

All of the collected data is encrypted and time-stamped in the blockchain. This provides the opportunity to create а KYC Register that meets the need for an efficient platform for managing KYC data and that could be used as necessary. The implemented KYC policy is an important step, helping companies to prevent identity theft, financial fraud, money laundering and terrorist financing. 

MERCHANT APPROPRIATED 

With its low volatility, global access, cost efficiency and mass market suitability, ONE is uniquely suited for merchants willing to use safe and stable cryptocurrency. ONE is not a pre-mined cryptocurrency. By mining the coin, transactions are added and recorded in the OneCoin blockchain. The blockchain processes 50 000 solutions per block and runs every single minute allowing users to make instant transactions. The algorithm of OneCoin provides for a finite number of 120 billion coins to be mined. 

The blockchain resembles a ledger, i.e. a chain of blocks, that confirms that a certain number of transactions have been recorded and verified. Based on protocols that authenticate, validate and store information in consistent, and unbroken sequences, the blockchain makes the system safer by eliminating any attempts of fraud, duplicity and/or forgery. 

With the launch of DealShaker in 2017, the coin was utilized by merchants to enable deep discounts for buyers that joined the platform. Now the present Offering gives access to a more advanced coin contrary to the majority of new coins offered on the market.

The OneCoin Ecosystem 

To ensure its global usage, OneCoin continues to develop its ecosystem of products and services, utilizing the coin for both users and merchants. For example, DealShaker serves as an advertising platform for merchants offering products and services worldwide to all people using the coin currently. DealShaker establishes business-to-business, consumer-to-consumer and business-to-consumer deal promotions in price combinations of ONE and cash. DealShaker merchants receive at least 50% of the price in ONE. Merchants can also accept their full coupon price in ONE.

TOKEN MODEL

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Offering Structure 

The Offering process is structured in 3 rounds offer OFC bundles as well as incentives to all participants. It starts on October 8th, 2018 and ends on January 7th, 2019. The first phase, which starts September 8th, 2018 and ends October 7th, 2018 is only informational. The OFC bundles will be available from October 8th, 2018 until the end of round Four - January 7th, 2019. 

Both, companies and individuals can participate and acquire bundles containing OFCs. After January 7, 2019, the bundles will no longer be available, and participants will be able to convert OFCs into ONEs based on the rules described in the Mandatory Discount Period and Release Strategy Chapter. 

The concept of creation a coin suitable for mass market usage, its user base of over 3 million users, its vision to provide financial services for everyone and the fact that its ecosystem is centred around the coin, aligns with the goal of the present Offering - to provide access to a coin that is actually in use and has been developed consistently over the time of its lifespan. 

The present Offering aims to give access to every interested party to the ONE cryptocurrency and make it public. Also, the Offering can be considered the next step of the adoption of ONE on a much bigger scale. 

To connect as many retailers as possible worldwide and make it more convenient for them to use ONE, a cross-border transaction tool will be the next big milestone for the ONE cryptocurrency. 

Roadmap and Details 

Participants become part of the coin offering by acquiring an OFC bundle that contains a precise number of OFCs. Companies and individuals can choose between four bundles based on price and number of OFCs. There are no limitations related to the number of bundles that can be purchased.

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AUGUST, 2018 

Informational period (September 8– October 7, 2018) 
Conducting an information campaign aimed at fully informing the participants about the project. 

OCTOBER, 2018 

SALE OF PACKAGES 
Round 1 (October 8 – November 7, 2018) 
Round 2 (November 8 – December 7, 2018) 
Round 3 (December 8 – January 7, 2019) 
During this period, the OFC bundles will be available under the terms of the current round. 

Mandatory Discount Period (MDP) and Release Strategy

JANUARY, 2019 

STAGE 1 of the MDP (January 8 – July 7, 2019) 

Since January 7, participants will be able to convert their accumulated OFCs into ONEs. 20% of all acquired coins are released. 

Mandatory Discount Period of the start-up will refer to the 80% of the total number of coins acquired by participants after the conversion from OFC to ONE. These 80% of the total number of coins will be held for 6 months and will receive 5% more coins. 

JULY, 2019 

STAGE 2 of the MDP (July 8 – October 7, 2019) 

On July 8, 2019, 30% of the coins will be released. The remaining 50% of the coins will receive 10% more coins and will be held for the next 3 months. 

OCTOBER, 2019 

STAGE 3 of the MDP (October 8 – January 7, 2020) 

On October 8, 2019, the next 30% of the coins will be released. The remaining 20% of them will be held for additional 3 months and will receive 15% more coins. 

JANUARY, 2020 

STAGE 4 of the MDP (January 8, 2020) 

All coins acquired by participants will be available to them lately, on January 8, 2020, at the output of the project at full capacity. Depending on the round in which participants acquire their OFC bundle, they receive added OFC incentives. With each new period, the OFC incentives decrease.
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INCENTIVE TABLE

+ 50% OFC     + 40% OFC     + 30% OFC
The Offering process is structured in 3 rounds that offer bundles containing a specific number of OFCs. With each round, the number of OFCs in the bundles will decrease.

BUNDLES TABLE

To purchase a bundle, companies and individuals should first register for the coin offering on www.onecoinico.io. The payment methods allowed are displayed in the user Accounts of all registered participants. 

OFC Tokens 

The OFC tokens offered with the bundles are neither shares nor represent ownership interests, nor grant ownership, control or voting rights, as well as not granting any rights to receive a share. OFCs are neither money nor investment securities and participants should be aware that the pursuit of profit or participation with investment or speculation intent should not be the incentive for taking a part in the Offering.

Registration 

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Participants register for the Offering on www.onecoinico.io by either clicking on “Participate” to start the registration process. Depending on the choice of participating as a company or an individual, participants will be asked to submit the relevant KYC/KYB information. The registration process includes 7 steps for both Individuals and Entities: 

REGISTRATION TABLE


  1. General Information 
  2. Company or Individual 
  3. User Information 
  4. Personal Information 
  5. Upload KYC/KYB Documentation 
  6. Preview & Confirm 
  7. Thank You!

Companies will have to provide personal information as well as company information and documents related to the KYC/KYB process. The persons filling in company information should be aware that they will have to point out their relationship with the company as its representative, e.g. UBO (Ultimate Beneficiary Owner), Legal Representative or Registered Secretary. 

Upon registration, Companies and Individuals create an Account. To enter this Account, users will have to login to www.onecoin.eu, where they will be able to check their KYC/KYB status, payments history, update the information provided, etc. 

Please read the Terms and Conditions and FAQ for more information. 
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MANDATORY DISCOUNT PERIOD AND RELEASE STRATEGY

The Mandatory Discount Period (MDP) and the Release Strategy (RS) are interconnected and pertain to the way participants will receive their coins MDP and release strategy starts on January 8, 2019. 

Mandatory Discount Period The MDP is a time frame during which a specific percentage of the OFCs received by participants are withheld against additional discount, namely receiving additional quantities of coins as discount (which indirectly reduces the pricing). 

The MDP will refer to the 80% of the total number of coins acquired by participants after the conversion from OFC to ONE. 

These 80% of the total number of coins will be held for 6 months and will receive 5% more coins. On July 8, 2019 30% of the coins will be released. The remaining 50% will receive 10% more coins and will be held for the next 3 months. On October 8, 2019 the next 30% of the coins will be released. The remaining 20% will be held for additional 3 months and will receive 15% more coins. All acquired coins by participants will be available to them latest on January 8, 2020. 

The MDP has been designed to serve the purpose of creating an OFC with 

MANDATORY DISCOUNT PERIOD TABLE


preventive and protective character. By its nature it is preventive and protective also because the participants will be granted additional number of coins on the one hand and on the other - the gradual release of coins, implemented in the strategy, will prevent potential market flood and price volatility.

Release Strategy 

The release strategy related to the coins commences on January 8, 2019 and is as follows: 20% of the total number of coins are released immediately after the OFC to ONE conversion. The rest of the amount, 80% of the coins receive 5% more coins and will be held for the next 6 months. On July 8, 2019 the next 30% of the coins will be released. The remaining 50% will receive 10% more coins and will be held for the next 3 months. On October 8, 2019 the next 30% of the coins will be released. The remaining 20% will be held for additional 3 months and will receive 15% more coins. All coins will be available latest on January 8, 2020. 

RELEASE STRATEGY TABLE

All titles and names given are for orientation, avoidance of confusion and explanatory purposes only. Nothing in the offering and/or the discount within the offering is not and shall not be interpreted and understood as investment, legal or financial advice or any other type of financial and/ or investment activity.

COMPLIANCE PROGRAM

To prevent individuals from engaging in unwanted behavior, compliance procedures aligned with legal developments in the industry have been put in place. For example, to prevent money laundering, identity theft, financial fraud and terrorist financing, KYC (know-your-customer) rules disrupt any possible misconduct by participants. 

Therefore, the implemented measures include procedures such as AML/ CFT and DD and KYC/KYB checks, following carefully due diligence regulations based on good practices.

The DD Compliance Procedure 

The DD (Due Diligence) procedures are performed to assess the risks to which an entity may be exposed, particularly the risk of money laundering and terrorist financing. The main point of the DD analysis is to identify and verify the customer based on account information provided to the company. When conducting DD, it is important to consider factors such as: 

  • the type of customer – individual or business 
  • the type of products/services/transactions the customer is using or conducting 
  • the geographical areas of the customers’ operations 
  • the amounts of the customers’ operations 

Identification and verification of the customer is being completed before establishing a business relationship. For higher risk customers it is important to perform further enhanced due diligence (EDD). 

The EDD Compliance Procedure 

Enhanced Due Diligence (EDD) compliance measures include obtaining further information about higher risk customers, including additional evidence of identity as documents provision, checks in an available software, politically exposed persons, individuals in trusts and fiduciary relationships or if a customer comes from a jurisdiction considered to be a high risk. 

EDD compliance is also performed in cases when there is a suspicion of money laundering or terrorist financing. The company conducts retrospective due diligence periodically on all existing customers.

KYC Procedures 

Since global business opportunities demand a sophisticated international customer identification and verification solution, the KYC policy adopted by OneCoin includes identifying the user and verifying the identity by examining reliable and independent documents. 

Know Your Customer (KYC), Know your Business (KYB) and Know Your Customers’ Customer (KYCC) analyses are made in order to assess the extent to which the customer exposes the organization to a range of risks. KYCC analysis is important, because a company should know who their third party customers’ business dealings are with, their sources of funds and legitimacy, and whether the risks for these third parties may be related to money laundering, fraud, terrorist financing, etc.

All submitted documents of identity remain confidential. Each user must go through a verification procedure every time his or hers identity information is changed, thus confirming that each payment is not anonymous.

AML/CFT and CDD and KYC/KYB 

Compliance Standard due diligence procedures require customers’ identification as well as verification of the customer’s identity. In addition, the company ensures gathering of information for the purpose of understanding the customers’ intention of the business relationship with the company. All collected data give evidence of the customers’ aim and the objectives of the products and services application, to ensure they are not being used for money laundering or for any kind of other criminal activity.

Documentation of identity must be supplemented with additional identification such as a recent utility bill or a bank statement, which is less than 3 months’ old and showing the customer’s name and address.

KYC Compliance procedure 

List of documentation the company requests:

KYB Compliance Procedure 

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KYB procedure includes the assessment of the high-risk activities/ businesses, taking into consideration factors such as:

  • The customers’ occupation; 
  • The type of transaction the customer is using or conducting; 
  • The geographical areas of the customer’s operations - Furthermore, collection of some entity documents will be required in order for the company to fulfill the requirements of its KYB (CDD) procedure. - The following documentation may be requested and provided by the business entity on demand (certified copy of the documents and also official translation): 
  • Certified true copy of Business Registration Certificate or corresponding commercial register extract (Certificate of Incorporation), including one for any shareholding companies for the customers’ company. 
  • If there are shareholding companies - Business Ownership Chart

(SHAREHOLDERS’ ORGANISATION CHART) 
Board resolution Identity documents and proof of residency of the shareholders holding more than 10 per cent of the paid up share capital and/or key functionalities are required 
Copy of Tax registration certification (if any)
Photocopy of Business Registration License (if any)
Fiduciary agreement (if any)
Annual financial statement at least for the previous year

All the information and documents collected are recorded in a secured database. Any change of the information and/or documents is recorded and kept for 5 years dating from the end of the relationship of the company with the customer.

The COMPANY, under the protection of the safe harbor from liability, may voluntarily receive or otherwise share information with any of the other financial or governmental institution regarding individuals, entities or other organizations for purposes of identifying and when needed reporting activities, that may involve possible terrorist or money laundering activities.
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LEGAL CONSIDERATIONS AND RISKS

Legal Considerations 

Coin Offerings are a relatively new mechanisms, typical for blockchain companies. Currently, there is no unified, commonly accepted legal definition for the Coin Offering process. The participants in such projects refer to the distribution of tokens in various ways.

Risks 

The purchase of the OFC involves a high degree of risk, including but not limited to the risks described below. Before acquiring the OFC, it is recommended that each participant carefully weighs all the information and risks detailed in this Whitepaper, and, specifically, the following risk factors. Please further note that the ONE Ecosystem may be subject to other risks not foreseen

Market volatility risk 

– cryptocurrency markets, since their appearance, have been characterized by high degree of uncertainty and volatility. In addition, having in mind the relatively recent rise of this market, the unpredictability of the future economic conditions may have significant impact on the success of any such offerings in general;

Cyber security risk

– the company may be a target of malicious attacks aimed to find and exploit weaknesses in the software, which may potentially result in loss and/or theft of tokens. In addition, there is an ongoing risk of system failures, that may result is service interruptions and/or other negative consequences;

Industry/competition risk 

– companies engaged in the high-technology business sphere face significant competition, due to the high-speed development of the technologies and amortization of the currently exploited systems, software etc.; Risks can be related to larger client base, name recognition, bad commercial practices and implementation of practices in violation of the common competition rules;

Media risk 

– as usual, development of technologies is related to increasing media interest, where the sector is tide by high level of confidentiality, commercial and trade secrets. In this case excessive media interest may seriously harm the business, as for example activating other risks as the above described “competition risk” or via negative publications to affect client base etc.;
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Regulatory & compliance risk 

– because of the “cutting edge” status of the sector, regulations are following the practical implementation of cryptocurrency and blockchain technologies. The rapidly developing sector may suddenly become a subject to statutory and regulatory requirements, which may potentially alter the business;

Dependence on Computer Infrastructure 

– The ONE Ecosystem depends on the functioning of the software applications, computer hardware, and the internet. This implies that no assurances can be given that a system failure would not adversely affect the use of the OFC. Despite the intended implementation of all reasonable network security measures, the processing center servers are vulnerable to computer viruses, physical or electronic break-ins or other disruptions of a similar nature. Computer viruses, break-ins or other disruptions caused by third parties may result in interruption, delay or suspension of services, which would limit the use of the OFC.

Smart Contract Limitations 

– Smart contract technology is still in its early stages of development, and its application is of an experimental nature. This may carry significant operational, technological, regulatory, financial and reputation risks. Consequently, it cannot be ensured that smart contracts to the extent used will properly work, or that they contain no flaws, vulnerabilities or issues which could cause technical problems and, thereby, cause damages.

Taxes 

– Holders of the OFC may be required to pay taxes associated with the transactions contemplated herein. It will be a sole responsibility of OFC holders to comply with the tax laws of the jurisdictions applicable to them and pay all relevant taxes.

Force Majeure 

– The performances under the ONE Ecosystem may be interrupted, suspended or delayed due to force majeure circumstances. For the purposes of this Whitepaper, force majeure shall mean extraordinary events and circumstances which could not be prevented and shall include acts of nature, wars, armed conflicts, mass civil disorders, industrial actions, epidemics, lockouts, slowdowns, prolonged shortage or other failures of energy supplies or communication service, acts of municipal, state or federal governmental agencies, other circumstances beyond control, which were not in existence at the time of Whitepaper release.

Disclosure of Information 

– Personal information received from holders of the OFC, the information about the number of coins owned, the wallet addresses used, and any other relevant information may be disclosed to law enforcement, government officials, and other third parties when required to disclose such information by law, subpoena, or court order. AHS Latam S. A. shall at no time be held responsible for such information disclosure.
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Value of the OFC 

- Once purchased, the value of the OFC may significantly fluctuate due to various reasons. The purchase of OFC can even lead into a total loss.

Bitcoin and Ethereum Volatility 

- The ONE may be significantly influenced by digital currency market trends and the OFC value may be severely depreciated due to non- OFC related events in the digital currency markets. Cryptocurrencies exchange rate volatility may impact the company's ability to provide services at the indicated prices. Assumptions with respect to the foregoing involve, among other things, judgments about the future economic, competitive and market conditions and business decisions, most of which are beyond the control of the ONE team and are therefore difficult or impossible to accurately predict.

Liquidity Risk 

– The present Offering may not reach the target sale amount and may not have sufficient funds to execute its business plan. Furthermore, the Offering teams may not succeed in creating the necessary momentum and acceptance for the OFC, which may result in low liquidity and depletion of trades. The positions and plans outlined in this Whitepaper may be altered as the project progresses.

Delayed Projects & Competition 

- Although the OFC team believes that its assumptions underlying its forward-looking statements are reasonable, any of these may prove to be inaccurate. As a result, assurances that the forward-looking statements contained in this Whitepaper will prove to be accurate can not be provided.

In light of the significant uncertainties inherent in the forward-looking statements contained herein, the inclusion of such information may not be interpreted as a warranty that the objectives and plans of the Offering project will be successfully achieved.

Competition may introduce the same or better prediction market solutions and cause loss of market share and eventually failure to deliver the declared business goals.
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DISCLAIMER

PLEASE READ THIS SECTION AND THE FOLLOWING SECTIONS ENTITLED “DISCLAIMER OF LIABILITY”, “NO REPRESENTATIONS AND WARRANTIES”, “REPRESENTATIONS AND WARRANTIES BY YOU”, “CAUTIONARY NOTE ON FORWARD-LOOKING STATEMENTS”, “MARKET AND INDUSTRY IN-FORMATION AND NO CONSENT OF OTHER PERSONS”, “NO ADVICE”, “NO FURTHER INFORMATION OR UPDATE”, “RESTRICTIONS ON DISTRIBUTION AND DISSEMINATION”, “NO OFFER OF SECURITIES OR REGISTRATION” AND “RISKS AND UNCERTAINTIES” CAREFULLY. IF YOU ARE IN ANY DOUBT AS TO THE ACTION YOU SHOULD TAKE, YOU SHOULD CONSULT YOUR LEGAL, FINANCIAL, TAX OR OTHER PROFESSIONAL ADVISOR(S).

The OFC is not intended to constitute securities or financial instruments in any jurisdiction.

This Whitepaper does not constitute a prospectus or offer document of any sort and is not intended to constitute an offer of securities or a solicitation for investment in securities in any jurisdiction. This Whitepaper does not constitute or form part of any opinion on any advice to sell, or any solicitation of any offer by the seller of the OFC (the “Token Provider”) to purchase any OFC nor shall it or any part of it nor the fact of its presentation form the basis of, or be relied upon in connection with, any contract or investment decision.

The OFC provider will be AHS Latam S. A. and will deploy all proceeds of sale of the OFC to fund the herein described cryptocurrency project, businesses and operations. No person is bound to enter into any contract or binding legal commitment in relation to the sale and purchase of the OFC and no cryptocurrency or other form of OFC is to be accepted on the basis of this Whitepaper.

Any agreement as between the Token Provider and potential participant, and in relation to any sale and purchase, of the OFC (as referred to in this Whitepaper) is to be governed by only a separate document setting out the terms and conditions (the “T&Cs”) of such agreement. In the event of any inconsistencies between the T&Cs and this Whitepaper, the former shall prevail.

No regulatory authority has examined or approved of any of the information set out in this White-paper. No such action has been or will be taken under the laws, regulatory requirements or rules of any jurisdiction. The publication, distribution or dissemination of this Whitepaper does not imply that the applicable laws, regulatory requirements or rules have been complied with.

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There are risks and uncertainties associated with the OFC and the different elements of the ONE Ecosystem and their respective services, businesses and operations (each as referred to in this Whitepaper). This Whitepaper, any part thereof and any copy thereof must not be taken or transmitted to any country where distribution or dissemination of this Whitepaper is prohibited or restricted. No part of this Whitepaper is to be reproduced, distributed or disseminated without including this section and the following sections entitled “Disclaimer of Liability”, “No Representations and Warranties”, “Representations and Warranties By You”, “Cautionary Note On Forward-Looking Statements”, “Market and Industry Information and No Consent of Other Persons”, “Terms Used”, “No Advice”, “No Further Information or Update”, “Restrictions On Distribution and Dissemination”, “No Offer of Securities Or Registration” and “Risks and Uncertainties”.

DISCLAIMER OF LIABILITY 

To the maximum extent permitted by the applicable laws, regulations and rules, AHS Latam S. A. or any entity or person being a part of the ONE Ecosystem shall not be liable for any indirect, special, incidental, consequential or other losses of any kind, in tort, contract or otherwise (including but not limited to loss of revenue, income or profits, and loss of use or data), arising out of or in connection with any acceptance of or reliance on this Whitepaper or any part thereof by the participants.

NO REPRESENTATIONS AND WARRANTIES 

The Token Provider and any entity or person being a part of the ONE Ecosystem does not make or purport to make, and hereby disclaims, any representation, warranty or undertaking in any form whatsoever to any entity or person, including any representation, warranty or undertaking in relation to the truth, accuracy and completeness of any of the information set out in this Whitepaper.

REPRESENTATIONS AND WARRANTIES BY YOU 

By accessing and/or accepting possession of any information in this Whitepaper or such part thereof (as the case may be), participants represent and warrant to the Token Provider or any entity or person being a part of the ONE Ecosystem that they agree on following: 
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(a) participants agree and acknowledge that the OFC does not constitute securities in any form in any jurisdiction;

(b) participants agree and acknowledge that this Whitepaper does not constitute a prospectus or offer document of any sort and is not intended to constitute an offer of securities in any jurisdiction or a solicitation for investment in securities and participants are not bound to enter into any contract or binding legal commitment and no cryptocurrency or other form of payment have to be accepted on the basis of this Whitepaper; 

(c) participants agree and acknowledge that no regulatory authority has examined or approved of the information set out in this Whitepaper, no action has been or will be taken under the laws, regulatory requirements or rules of any jurisdiction and the publication, distribution or dissemination of this Whitepaper to participants does not imply that the applicable laws, regulatory requirements or rules have been complied with; 

(d) participants agree and acknowledge that this Whitepaper, the undertaking and/or the completion of the Offering of the OFC, or future trading of the OFC on any cryptocurrency exchange, shall not be construed, interpreted or deemed by them as an indication of the merits of AHS Latam S. A. or any entity or person being a part of the ONE Ecosystem; 

(e) the distribution or dissemination of this Whitepaper, any part thereof or any copy thereof, or acceptance of the same is not prohibited or restricted by the applicable laws, regulations or rules in participants jurisdiction, and where any restrictions in relation to possession are applicable, participants have observed and complied with all such restrictions at their own expense and without liability to AHS Latam S. A. or any entity or person being a part of the ONE Ecosystem;

(f) participants agree and acknowledge that in the case where participants wish to purchase any OFC, the OFC is not to be construed, interpreted, classified or treated as: 
  • any kind of currency other than cryptocurrency; 
  • debentures, stocks or shares issued by any person or entity 
  • rights, options or derivatives in respect of such debentures, stocks or shares; 
  • units in a collective investment scheme; 
  • units in a business trust; 
  • derivatives of units in a business trust; or 
  • any other security or class of securities. 
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Participants have a basic degree of understanding of the operation, functionality, usage, storage, transmission mechanisms and other material characteristics of cryptocurrencies, block-chain-based software systems, cryptocurrency wallets or other related token storage mechanisms, blockchain technology and smart contract technology; 

participants are fully aware and understand that in the case where you wish to purchase any OFC, there are risks associated with the OFC and the ONE Ecosystem and their respective services, business and operations; 

participants agree and acknowledge that neither AHS Latam S. A. nor any entity or person being a part of the ONE Ecosystem is liable for any indirect, special, incidental, consequential or other losses of any kind, in tort, contract or otherwise (including but not limited to loss of revenue, income or profits, and loss of use or data), arising out of or in connection with any acceptance of or reliance on this Whitepaper or any part thereof by you; and rights under a contract for differences or under any other contract the purpose or pretended purpose of which is to secure a profit or avoid a loss; 

all of the above representations and warranties are true, complete, accurate and non-misleading from the time of participants access to and/or acceptance of possession this Whitepaper or such part thereof (as the case may be).

CAUTIONARY NOTE ON FORWARD-LOOKING STATEMENTS 

All statements contained in this Whitepaper, statements made in press releases or in any place accessible by the public and oral statements that may be made by AHS Latam S. A. and/or any entity or person being a part of the ONE Ecosystem, including their respective directors, executive officers or employees acting on behalf of them that are not statements of historical fact, constitute “forward-looking statements”. Some of these statements can be identified by forward-looking terms such as “aim”, “target”, “anticipate”, “believe”, “could”, “estimate”, “expect”, “if”, “intend”, “may”, “plan”, “possible”, “probable”, “project”, “should”, “would”, “will” or other similar terms. However, these terms are not the exclusive means of identifying forward-looking statements. All statements regarding financial position, business strategies, plans and prospects and the future prospects of the industry which AHS Latam S. A. and/or any other entity or person being a part of the ONE Ecosystem is in are forward-looking statements. These forward-looking statements, including but not limited to statements about revenue and profitability, prospects, future plans, other expected industry trends and other matters discussed in this Whitepaper are matters that are not historical facts, but only predictions. These forward-looking statements involve known and unknown risks, uncertainties and other factors that may cause the actual future results, performance or achievements to be materially different from any future results, performance or achievements expected, expressed or implied by such forward-looking statements. These factors include, amongst others:
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(a) changes in political, social, economic and stock or cryptocurrency market conditions, and the regulatory environment in the countries in which AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem conducts its respective businesses and operations; 

(b) the risk that AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem may be unable or execute or implement their respective business strategies and future plans; 

(c) changes in interest rates and exchange rates of fiat currencies and cryptocurrencies; 

(d) changes in the anticipated growth strategies and expected internal growth of AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem; 

(e) changes in the availability and fees of AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem in connection with their respective businesses and operations; 

(f) changes in the availability and salaries of employees who are required by AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem to operate their respective businesses and operations; 

(g) changes in preferences of customers of the AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem; 

(h) changes in competitive conditions under which AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem operate, and the ability of AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem to compete under such conditions; 

(i) changes in the future capital needs of AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem and the availability of financing and capital to fund such needs; 

(j) war or acts of international or domestic terrorism; 

(k) occurrences of catastrophic events, natural disasters and acts of God that affect the businesses and/or operations of AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem; 

(l) other factors beyond the control of AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem; and 

(m) any risk and uncertainties associated with AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem and their businesses and operations, the OFC, the OFFERING, and the OFC eWallet (each as referred to in the Whitepaper). 

All forward-looking statements are expressly qualified in their entirety by such factors. 
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Given that risks and uncertainties that may cause the actual future results, performance or achievements to be materially different from that expected, expressed or implied by the forward-looking statements in this Whitepaper, undue reliance must not be placed on these statements. These forward-looking statements are applicable only as of the date of this Whitepaper. 

The actual results, performance or achievements may differ materially from those anticipated in these forward- looking statements. Nothing contained in this Whitepaper is or may be relied upon as a promise, representation or undertaking as to the future performance or policies. Further, AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem disclaim any responsibility to update any of those forward- looking statements or publicly announce any revisions to those for-ward-looking statements to reflect future developments, events or circumstances, even if new in-formation becomes available or other events occur in the future.

MARKET AND INDUSTRY INFORMATION AND NO CONSENT OF OTHER PERSONS 

This Whitepaper includes market and industry information and forecasts that have been obtained from internal surveys, reports and studies, where appropriate, as well as market research, publicly available information and industry publications. Such surveys, reports, studies, market research, publicly available information and publications generally state that the information that they contain has been obtained from sources believed to be reliable, but there can be no assurance as to the accuracy or completeness of such included information. 

Save for AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem and their respective directors, executive officers and employees, no person has provided his or her consent to the inclusion of his or her name and/or other information attributed or perceived to be attributed to such person in connection therewith in this Whitepaper and no representation, warranty or undertaking is or purported to be provided as to the accuracy or completeness of such information by such person and such persons shall not be obliged to provide any updates on the same. 

While AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem have taken reasonable actions to ensure that the information is extracted accurately and in its proper context, AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem have not conducted any independent review of the information extracted from third party sources, verified the accuracy or completeness of such information or ascertained the underlying economic assumptions relied upon therein. Consequently, neither AHS Latam S.A. and/or any other entity being a part of the ONE Ecosystem, nor their respective directors, executive officers and employees acting on their behalf makes any representation or warranty as to the accuracy or completeness of such information and shall not be obliged to provide any updates on the same.
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TERMS USED 

To facilitate a better understanding of the OFC being offered, and the businesses and operations of ONE, certain technical terms and abbreviations, as well as, in certain instances, their descriptions, have been used in this Whitepaper. These descriptions and assigned meanings should not be treated as being definitive of their meanings and may not correspond to standard industry meanings or usage. Words importing the singular shall, where applicable, include the plural and vice versa and words importing the masculine gender shall, where applicable, include the feminine and neuter genders and vice versa. References to persons shall include corporations. 

NO ADVICE 

No information in this Whitepaper should be considered to be business, legal, financial or tax advice regarding OFC, the present OFFERING and the OFC eWallet (each as referred to in the Whitepaper). You should consult your own legal, financial, tax or other professional adviser regarding the OFC, the present OFFERING, and the OFC eWallet (each as referred to in the Whitepaper). You should be aware that you may be required to bear the financial risk of any purchase of OFC for an indefinite period of time.

NO FURTHER INFORMATION OR UPDATE 

No person has been or is authorized to give any information or representation not contained in this Whitepaper in connection with the OFC, the present OFFERING and the OFC (each as referred to in the Whitepaper) and, if given, such information or representation must not be relied upon as having been authorized by or on behalf of AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem. The OFC and the present OFFERING (as referred to in the Whitepaper) shall not, under any circumstances, constitute a continuing representation or create any suggestion or implication that there has been no change, or development reasonably likely to involve a material change in the affairs, conditions and prospects of AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem or in any statement of fact or information contained in this Whitepaper since the date hereof. 
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RESTRICTIONS ON DISTRIBUTION AND DISSEMINATION 

The distribution or dissemination of this Whitepaper or any part thereof may be prohibited or restricted by the laws, regulatory requirements and rules of any jurisdiction. In the case where any restriction applies, you are to inform yourself about, and to observe, any restrictions which are applicable to your possession of this Whitepaper or such part thereof (as the case may be) at your own expense and without liability to AHS Latam S. A. and/or any other entity being a part of the ONE Ecosystem. Persons to whom a copy of this Whitepaper has been distributed or disseminated, provided access to or who otherwise have the Whitepaper in their possession shall not circulate it to any other persons, reproduce or other-wise distribute this Whitepaper or any information contained herein for any purpose whatsoever nor permit or cause the same to occur. 

NO OFFER OF SECURITIES OR REGISTRATION 

This Whitepaper does not constitute a prospectus or offer document of any sort and is not intended to constitute an offer of securities or a solicitation for investment in securities in any jurisdiction. 

No person is bound to enter into any contract or binding legal commitment and no cryptocurrency or other form of payment is to be accepted on the basis of this Whitepaper. Any agreement in relation to any sale and purchase of OFC (as referred to in this Whitepaper) is to be governed by only the T&Cs of such agreement and no other document. In the event of any inconsistencies between the T&Cs and this Whitepaper, the former shall prevail. 

No regulatory authority has examined or approved of any of the information set out in this Whitepaper. No such action has been or will be taken under the laws, regulatory requirements or rules of any jurisdiction. The publication, distribution or dissemination of this Whitepaper does not imply that the applicable laws, regulatory requirements or rules have been complied with.

RISKS AND UNCERTAINTIES 

Prospective purchasers of OFC (as referred to in this Whitepaper) should carefully consider and evaluate all risks and uncertainties associated with SILO and/or any other entity being a part of the ONE Ecosystem and their respective businesses and operations, the OFC, the present OFFERING and the OFC (each as referred to in the Whitepaper), all information set out in this Whitepaper and the T&Cs prior to any purchase of OFC. If any of such risks and uncertainties develops into actual events, the business, financial condition, results of operations and prospects could be materially and adversely affected. In such cases, participants may lose all or part of the value of the OFC. 

JURISDICTION AND GOVERNING LAW 

The present Offering, any related material and especially the content of this Whitepaper, the Whitepaper itself and any associated documents and material and any conflict arising from it or in relation to it shall be exclusively governed by the laws of Republic of Panama. The courts of Republic of Panama shall have the whole and exclusive jurisdiction.
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