1 Objective of the Protocol
1.1 This protocol defines the internal procedures of Rintral Trading S.L.U. for the classification, management, and safeguarding of unclaimed client funds. It ensures full compliance with Regulation (EU) 2023/1114 (MiCA), specifically Articles 66 and 67, concerning the protection and segregation of client assets.
1.2 Our objective is to maintain the highest level of regulatory compliance and operational integrity across all procedures related to client fund treatment. This protocol complements both the Dormant Account Policy and the Unlocated Funds Procedure.
2 Scope
2.1 This protocol applies to all client funds that are classified as unclaimed due to prolonged inactivity, unsuccessful contact attempts, or failure to complete onboarding requirements.
2.2 It does not cover funds temporarily held due to internal account restrictions (refer to the Unlocated Funds Procedure), funds frozen as part of anti-fraud or anti-money laundering investigations (refer to the Unallocated Funds Procedure), or the classification of account status, which is governed separately under the Dormant Account Policy. These distinctions are made to ensure full compliance with applicable regulatory requirements and alignment with our internal control framework.
3 Definition of Unclaimed Funds
3.1 Unclaimed funds refer to client-held assets that, despite reasonable and documented recovery efforts, cannot be returned or made accessible to the rightful owner. This may arise in the following situations:
i. Multiple unsuccessful transaction attempts (e.g., three or more consecutive declines);
ii. Extended periods of client inactivity exceeding twelve (12) consecutive months, accompanied by failure to re-establish contact;
iii. Failure to complete onboarding or required identity verification processes;
iv. Persistent inability to reach the client through any of the registered communication channels, following a documented series of contact attempts.
3.2 Note: Where communication issues are temporary or under internal review, funds may initially be held as Unlocated Funds. If no successful contact or recovery is achieved within ninety (90) calendar days from the first recovery attempt, the funds shall be reclassified as Unclaimed.
4 Fund Segregation and Safekeeping
4.1 All unclaimed funds shall be transferred to a designated Unclaimed Funds Account, where they are held securely and fully segregated from the provider’s operational assets. These funds remain individually traceable to the rightful client at all times and shall be recoverable upon request, subject to identity verification and internal due diligence procedures. These safeguards are implemented in accordance with Articles 66 and 67 of Regulation (EU) 2023/1114 (MiCA).
4.2 To ensure policy clarity and avoid overlap with other internal procedures, the following distinctions apply:
i. Unclaimed Funds: This protocol applies exclusively to funds that are formally reclassified as unclaimed due to client inactivity, failed contact attempts, or non- compliance with onboarding requirements under the conditions set out in Section 3.
ii. Unlocated Funds: Funds temporarily withheld due to internal restrictions—such as pending verification of client instructions, document review, or technical delivery failures—are not classified as unclaimed. These are managed separately under the Unlocated Funds Procedure while the client relationship remains active.
iii. Unallocated Funds: Funds frozen due to suspicion of fraudulent activity or anti- money laundering concerns fall entirely outside the scope of this protocol and are governed by the Unallocated Funds Procedure by applicable AML/CTF laws and regulatory reporting obligations.
iv. Dormant Accounts: The classification of a client account as dormant—based on prolonged inactivity—does not automatically trigger a reclassification of the associated funds as unclaimed. Account status is managed separately under the Dormant Account Policy, and any subsequent reclassification of funds shall only occur per this protocol, following failed recovery efforts and the applicable timeframes.
5 Notification Obligations
5.1 Clients shall be informed in a timely and transparent manner of any developments affecting the status of their funds. Specifically, where client funds are reclassified as unclaimed in accordance with this protocol, the client must be notified of the following:
• The effective date and reason for the reclassification of funds as unclaimed;
• The safeguarding measures applied, including the segregation of the funds from the provider’s own assets and their secure placement in a designated Unclaimed Funds Account;
• The recovery process available to the client, including the steps required to verify identity, provide any necessary documentation, and initiate a claim for the release of the funds.
5.2 Such notifications must be issued no later than ten (10) business days from the date on which the reclassification of funds as unclaimed is recorded.
5.3 All communications must be clear, documented, and traceable. Notifications shall be sent through the client’s registered communication channels (e.g., email or secure messaging), and appropriate records shall be retained in accordance with internal compliance and audit requirements.
5.4 These obligations are established under Article 62 of Regulation (EU) 2023/1114 (MiCA), which requires crypto-asset service providers to ensure accurate and timely disclosure of relevant information throughout the service relationship.
6 Administrative Charges
6.1 In accordance with the Terms and Conditions accepted by the client, a monthly maintenance fee of EUR 4 may be applied after a period of twelve (12) consecutive months of account inactivity. The fee shall be deducted directly from the available balance and will continue to apply until either the account is reactivated, or the balance is fully depleted.
6.2 The application of this fee is intended to cover administrative and operational costs associated with the ongoing maintenance of inactive accounts and the safeguarding of client funds.
6.3 Clients shall be duly informed of this fee structure in advance, as part of the pre- contractual disclosures, and again upon reclassification of funds as unclaimed, in accordance with Section 5 of this protocol.
6.4 This practice is implemented in line with the principles of cost transparency and fair service conditions set out in Article 63 of Regulation (EU) 2023/1114 (MiCA). All charges must be clearly disclosed, reasonable, and contractually agreed, and the application of such fees shall be subject to internal compliance monitoring.
7 Recovery Procedure
7.1 Clients retain the right to reclaim their unclaimed funds at any time. To initiate recovery, the client must submit a formal recovery request through the designated communication channel, accompanied by valid identification and any documentation required to verify entitlement in accordance with internal due diligence procedures.
7.2 Upon receipt of a recovery request, the Compliance and Operations teams shall initiate the verification process without undue delay. The identity and status of the claimant shall be verified in line with onboarding and KYC standards, including source of entitlement checks where appropriate. Where additional information is required, the client shall be notified promptly.
7.3 The recovery process shall be completed within a maximum of fifteen (15) business days from the date of receipt of all required supporting documentation, provided that the verification process does not raise any material concerns or red flags.
7.4 All recovery activities—including the date of request, verification steps, internal approvals, and fund disbursement—shall be documented in full and logged in internal systems. A complete audit trail must be maintained for each recovery case, in accordance with internal recordkeeping protocols and the requirements of Regulation (EU) 2023/1114 (MiCA). Recovery logs must be made available upon request to internal audit functions or competent supervisory authorities.
7.5 Where a recovery request trigger concerns regarding potentially fraudulent activity or AML/CTF risks, the matter shall be escalated immediately to the Internal Control Body (ICB) for further assessment, in accordance with the Protocol for the Prevention of Money Laundering and Terrorism Financing.
8 Internal Recordkeeping and Controls
8.1 All movements of funds to and from Unclaimed Funds Accounts must be recorded in a comprehensive and traceable manner. Each action—whether related to fund classification, internal transfers, recovery requests, or disbursements—must be logged with a full audit trail, including the date, time, responsible personnel, and supporting documentation.
8.2 These records must be maintained in accordance with internal control procedures and retained for a minimum period of five (5) years, or longer if required by applicable laws or supervisory authorities. Access to these records shall be restricted to authorized personnel and made available upon request to internal audit, compliance, or competent supervisory authorities.
8.3 Regular internal reviews must be conducted by the Compliance and Finance teams to ensure that fund treatment and account segregation procedures are being properly followed. Any deviation or exception from this protocol shall be documented, assessed, and, where necessary, escalated to the Internal Control Body (ICB).
8.4 Where applicable, this recordkeeping framework is also integrated into broader operational resilience and business continuity protocols, in line with the requirements of Regulation (EU) 2022/2554 (DORA).
9 Relationship with Other Policies
9.1 This protocol is designed to operate in conjunction with the broader internal control framework and must be read in alignment with the following complementary policies and procedures:
• The Dormant Account Policy, which governs the classification of dormant account status and defines reactivation procedures following periods of client inactivity.
• The Unlocated Funds Procedure, which addresses the internal handling of funds that are temporarily restricted or withheld due to pending documentation, client instruction verification, or operational constraints, while the client relationship remains active.
• The Unallocated Funds Procedure, which governs the treatment of funds frozen in the context of suspected fraudulent activity or anti-money laundering concerns, in accordance with the obligations set out under Spanish Law 10/2010 on the Prevention of Money Laundering and Terrorist Financing.
9.2 These procedures form part of an integrated compliance framework. Appropriate cross-references between them ensure a clear delineation of responsibilities, prevent procedural overlap, and support consistent application of internal controls and regulatory requirements.
10 Governance and Ownership
10.1 This protocol is owned and maintained by the Compliance Department, in coordination with the Finance and Operations teams, who are jointly responsible for its implementation and ongoing adherence across relevant business processes.
10.2 The protocol shall be reviewed at least annually, or sooner if required due to changes in regulatory requirements, supervisory expectations, or internal operational needs. Any material amendments must be approved by the Internal Control Body (ICB) and recorded in the protocol’s version control history.
10.3 Any incidents of deviation from this protocol, or cases requiring interpretive clarification, must be reported to the Compliance Department and, where applicable, escalated to the ICB.
10.4 The latest approved version of this document shall be made available to all relevant teams and retained in the central compliance documentation repository.
11 Governing Law and Jurisdiction
11.1 This protocol shall be interpreted and applied per the provisions of Regulation (EU) 2023/1114 (MiCA), where applicable, and the internal policies and legal framework of Rintral, operating under the jurisdiction of Spanish law.
11.2 Any matters not expressly regulated by MiCA shall be governed by the applicable provisions of Spanish national law, including but not limited to obligations under Law 10/2010 on the Prevention of Money Laundering and Terrorist Financing, as well as any other relevant sectoral or supervisory regulations.
11.3 In the event of any conflict or interpretive ambiguity, this protocol shall be applied in a manner that ensures compliance with prevailing regulatory requirements and supervisory expectations. Any disputes arising from the interpretation or application of this protocol shall fall under the jurisdiction of the competent courts in Barcelona, Spain, unless otherwise agreed in writing.
12 Document Control and Approvals
12.1 This protocol shall be reviewed at least annually or upon any material change in the applicable regulatory framework. Any updates must be submitted to the ICB for review and formal approval. The latest version shall be recorded in the compliance documentation register and made available to relevant teams.