By accessing or using Sterlyn Capital's platform, services, or infrastructure, you agree to be bound by these Terms of Service. If you do not agree, you must not access or use our services.
1. Services Overview
Sterlyn Capital provides institutional digital asset prime brokerage services, including but not limited to liquidity routing, OTC block trading, treasury operations, custody coordination, and institutional execution infrastructure. Our services are made available exclusively to verified institutional clients and qualified investors who have completed the mandatory onboarding and compliance review process.
2. Eligibility & Account Requirements
Access to Sterlyn Capital's platform requires:
- Completion of the institutional onboarding process including AML/KYC verification
- Meeting the minimum portfolio qualification threshold for the applicable account tier
- Provision of accurate, complete, and current information during registration
- Compliance with all applicable laws and regulations in your jurisdiction of residence or incorporation
- Ongoing maintenance of the minimum portfolio balance as specified for your account tier
3. Account Tiers & Withdrawal Structure
Client accounts are classified into four tiers (T1 Retail Professional, T2 Strategic Capital, T3 Elite Prime, T4 Prime Institutional). Each tier carries distinct withdrawal limits, settlement windows, and liquidity access terms. Tier classification is subject to review and may be adjusted based on portfolio performance, compliance standing, and Sterlyn Capital's operational discretion.
Withdrawal requests are subject to AML review, minimum balance requirements, and settlement windows specific to the client's account tier. Large-volume withdrawals at T4 level require treasury coordination and enhanced verification.
4. Prohibited Activities
Clients must not use Sterlyn Capital's platform to:
- Engage in money laundering, terrorist financing, or any other illegal financial activity
- Circumvent or attempt to circumvent AML/KYC controls
- Conduct transactions involving sanctioned individuals, entities, or jurisdictions
- Misrepresent the source, ownership, or nature of funds
- Engage in market manipulation or fraudulent trading activity
- Access or attempt to access other clients' accounts or data
5. Fees & Charges
Sterlyn Capital reserves the right to charge fees for services rendered, including but not limited to execution spreads, settlement fees, treasury coordination fees, and OTC block trading commissions. Fee schedules are disclosed to clients during onboarding and may be updated with notice.
6. Limitation of Liability
Sterlyn Capital shall not be liable for any direct, indirect, incidental, special, or consequential damages arising from the use of or inability to use the platform, including but not limited to losses resulting from market volatility, system downtime, or force majeure events. Total liability shall not exceed the fees paid by the client in the preceding three-month period.
7. Termination
Sterlyn Capital reserves the right to suspend or terminate any client account at its sole discretion, including but not limited to cases of compliance breach, failure to maintain minimum balances, or suspicious activity. Clients may request account closure in writing, subject to the settlement of all outstanding obligations.
8. Governing Law
These Terms shall be governed by and construed in accordance with applicable laws. Any disputes arising under these Terms shall be subject to binding arbitration in the jurisdiction agreed upon during client onboarding.
9. Amendments
Sterlyn Capital reserves the right to amend these Terms at any time. Clients will be notified of material changes via their registered contact information. Continued use of the platform following notification constitutes acceptance of the amended Terms.
Sterlyn Capital is committed to protecting the privacy and confidentiality of all client information. This policy outlines how we collect, use, store, and protect personal and institutional data.
1. Information We Collect
We collect the following categories of information during onboarding and throughout the client relationship:
- Identity information: full legal name, date of birth, government-issued identification
- Contact information: email address, telephone number, registered address
- Financial information: source of funds, portfolio composition, transaction history
- Entity information (where applicable): certificate of incorporation, beneficial ownership, director identification
- Technical information: IP addresses, device identifiers, platform usage data
- Communication records: correspondence with relationship managers and the treasury desk
2. How We Use Your Information
Client information is used exclusively for the following purposes:
- Verification of identity and compliance with AML/KYC obligations
- Processing transactions, withdrawals, and treasury coordination requests
- Providing relationship management and client support services
- Monitoring for suspicious activity and regulatory compliance
- Improving our platform infrastructure and service quality
- Meeting legal and regulatory obligations in applicable jurisdictions
3. Data Sharing & Third Parties
Sterlyn Capital does not sell client data to third parties. Information may be shared with:
- Regulatory authorities and law enforcement agencies when legally required
- Compliance and AML verification service providers under strict confidentiality agreements
- Custodians and settlement counterparties as required for transaction processing
- Professional advisors bound by confidentiality obligations
4. Data Retention
Client data is retained for a minimum of five (5) years following account closure, or longer where required by applicable law. Transaction records and compliance documentation may be retained for up to ten (10) years in accordance with AML regulatory requirements.
5. Data Security
Sterlyn Capital employs industry-standard security measures including 256-bit encryption, multi-factor authentication, access controls, and regular security audits to protect client data from unauthorized access, disclosure, or loss.
6. Client Rights
Clients have the right to request access to their personal data, request corrections of inaccurate information, and request deletion of data where legally permissible. Requests should be directed to your assigned relationship manager or the compliance desk.
7. Cookies & Technical Data
Our platform uses session cookies for authentication and security purposes only. We do not use tracking cookies for advertising or behavioural profiling. Technical usage data is collected solely for platform performance monitoring and security purposes.
Important: Digital asset investments carry substantial risk of loss. You should not invest funds you cannot afford to lose entirely. Please read this disclosure carefully before using any of Sterlyn Capital's services.
1. Market Risk
Digital assets including Bitcoin (BTC) and Ethereum (ETH) are subject to extreme price volatility. The value of digital assets can decrease substantially or reach zero in a short period of time. Past performance is not indicative of future results. Sterlyn Capital does not guarantee returns, portfolio growth, or the preservation of capital.
2. Liquidity Risk
Digital asset markets may experience periods of reduced liquidity, making it difficult or impossible to execute trades at desired prices. Large-volume positions may not be exitable at prevailing market prices. OTC and block execution services are subject to counterparty availability and market conditions.
3. Counterparty Risk
Transactions executed through Sterlyn Capital's infrastructure involve counterparty risk. While we maintain relationships with institutional-grade counterparties, there is no guarantee against counterparty default, failure, or insolvency.
4. Regulatory Risk
The regulatory environment for digital assets is evolving rapidly and varies significantly across jurisdictions. Changes in law or regulation may materially impact the value of digital assets, the availability of services, or a client's ability to access funds. Clients are solely responsible for understanding and complying with applicable regulations in their jurisdiction.
5. Custody Risk
Despite employing multi-layer custody infrastructure, digital asset custody carries inherent risks including but not limited to: technical failures, cybersecurity incidents, private key compromise, and smart contract vulnerabilities. Unlike traditional bank deposits, digital asset holdings are not covered by government deposit insurance schemes.
6. Operational Risk
Platform downtime, system failures, network congestion, and other operational disruptions may temporarily impair access to accounts or delay transaction processing. Sterlyn Capital maintains business continuity procedures but cannot guarantee uninterrupted service.
7. Concentration Risk
Clients with portfolios heavily concentrated in one or a small number of digital assets face amplified exposure to asset-specific risks. Sterlyn Capital does not provide investment advice and does not recommend specific portfolio allocations.
8. No Investment Advice
Nothing on the Sterlyn Capital platform, in communications from our team, or in any documentation constitutes investment advice, financial advice, or a recommendation to buy, sell, or hold any digital asset. All investment decisions are made solely by the client at their own risk and discretion.
9. Acknowledgement
By using Sterlyn Capital's services, you acknowledge that you have read, understood, and accept all risks described in this disclosure, and that you are financially and technically capable of bearing the risks associated with digital asset investment and trading.
Sterlyn Capital maintains a zero-tolerance policy toward money laundering, terrorist financing, and financial crime. All clients are subject to comprehensive AML/KYC verification before account activation and on an ongoing basis throughout the client relationship.
1. Policy Overview
Sterlyn Capital's AML/KYC policy is designed to prevent the use of our platform for money laundering, terrorist financing, sanctions evasion, and other financial crimes. This policy complies with applicable AML regulations and international standards including FATF recommendations.
2. Customer Due Diligence (CDD)
All clients must complete Customer Due Diligence before account activation, which includes:
- Verification of identity using government-issued photo identification
- Proof of address documentation dated within the last three months
- Source of funds and source of wealth declaration
- Tax identification number and tax residency confirmation
- Sanctions screening against international watchlists
- Politically Exposed Person (PEP) screening
3. Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied to higher-risk clients and situations, including:
- T4 Prime Institutional clients and all cross-border settlement requests
- Clients identified as Politically Exposed Persons (PEPs)
- Clients from higher-risk jurisdictions as defined by FATF
- High-volume withdrawal requests and large liquidity events
- Any transaction or behaviour flagged by our automated monitoring systems
4. Know Your Business (KYB)
For institutional clients, funds, and corporate entities, KYB requirements include:
- Certificate of incorporation and corporate structure documentation
- Beneficial ownership register identifying all owners holding 10% or more
- Director and officer identification verification
- Corporate bank statements and financial statements where applicable
- Operating agreements, partnership deeds, or trust documentation
5. Ongoing Monitoring
Sterlyn Capital conducts continuous transaction monitoring to detect unusual or suspicious activity. Our monitoring systems are calibrated to identify patterns inconsistent with a client's stated business purpose, risk profile, and account history. All clients are subject to periodic KYC refresh reviews.
6. Suspicious Activity Reporting
Where Sterlyn Capital has reasonable grounds to suspect money laundering or terrorist financing, we are legally obligated to file Suspicious Activity Reports (SARs) with the relevant regulatory authorities. Clients are advised that we cannot disclose whether a SAR has been filed, as doing so constitutes "tipping off" under applicable law.
7. Sanctions Compliance
Sterlyn Capital screens all clients, counterparties, and transactions against international sanctions lists including OFAC, UN, EU, and UK sanctions. Accounts or transactions associated with sanctioned individuals, entities, or jurisdictions will be blocked and reported to the appropriate authorities.
8. Record Keeping
All KYC documentation, transaction records, and compliance correspondence are retained for a minimum of five (5) years following the termination of the client relationship, or longer where required by applicable law.
9. Training & Compliance Culture
All Sterlyn Capital personnel receive regular AML/KYC training. Our compliance function operates independently and is empowered to escalate concerns, pause transactions, or terminate client relationships where compliance obligations require it.
10. Contact
For AML/KYC inquiries, document submissions, or compliance-related matters, please contact your assigned relationship manager or direct your inquiry to the Sterlyn Capital compliance desk through the institutional contact channel.