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Draft — not in force

This document is a working draft. It has not been reviewed by Montenegrin counsel and does not yet bind either party. It is published here so that the structure and the substantive restrictions can be reviewed, not so that it can be relied upon.

Our legal documents are published in English. A reviewed translation will follow once the authoritative text is settled with counsel. If anything here is unclear, please ask us before you proceed.

Terms of service

Version 0.1-draft · P2P Broker

1. Who we are, and what we do

P2P Broker is a platform that connects people who want to exchange euro and crypto-assets with each other. The website is operated by Paxa Media j.d.o.o., an IT company, of [Street and number], [Postcode] [City], Montenegro (registration number [CRPS number]). It runs the software and holds your details; it is not a party to any exchange, does not quote you a price, and never handles money or crypto-assets.

The introductions themselves — verifying who people are and deciding whether to connect them — are made by Luka Rukavina and Lazar Barjaktarović. Neither of them is a registered crypto-asset service provider. A dedicated Montenegrin company holding its own registration is intended; we will say so here when it takes over.

We connect people. We do not execute transactions. We take your request, carry out due diligence, and then do one of two things:

  • Peer to peer.We introduce you to another individual whose identity we have verified to the same standard as yours, and you settle directly with each other. We are not a party to that transaction, we do not guarantee it, and we do not hold either side’s funds while it happens.
  • Through a licensed provider. We introduce you to the registered crypto-asset service provider, registered with the Capital Market Authority of Montenegro. That provider executes and settles the transaction and is the party you contract with in respect of it.

We tell you in writing which of the two applies, and who your counterparty is, before anything moves.

The rate shown on this website is indicative.It is the market reference rate with your counterparty’s margin applied — not a charge from us — and the market moves continuously. The rate that applies to your transaction is the one confirmed at the point of settlement, not the one displayed when you made your request. Where the rate has moved materially against you in the meantime, you will be told before anything is settled.

2. We do not hold client money or crypto-assets

We do not receive, hold, control, safeguard or transmit your money or your crypto-assets at any time, for any period, in any amount, and for any client. We do not operate a trading platform and we do not provide custody, wallet, staking, lending or investment services.

We do not act as escrow.In a peer-to-peer exchange we do not hold either side’s funds while the other performs. Doing so would be custody, and custody is the line that separates us from a licensed provider. Where a transaction needs an escrow arrangement, it goes through the registered provider instead.

We will never ask you to send money or crypto-assets to us, and we will never request identity documents by email or messaging application. If you receive such a request purporting to come from us, it does not come from us. Please contact us using the telephone number published on this website.

3. Eligibility, and the exclusion of EU and EEA residents

Our services are available only to persons who are resident in, and physically present in, Montenegro, and who are at least 18 years old.

We do not accept, and do not offer or market our services to, any person resident in a member state of the European Union or in the European Economic Area. This exclusion applies regardless of your nationality and regardless of where you access this website from. It reflects the fact that the European Union’s transitional arrangements for crypto-asset service providers ended on 1 July 2026, and that providing crypto-asset services to a person resident in the EU without authorisation under that framework is a breach irrespective of where the provider is established.

We restrict access to this website by location, ask you to declare your country of residence, and verify residence against documents during onboarding. Making a false declaration of residence is a breach of these terms. Where we discover one, we will withdraw any introduction and end the relationship, and we may be required to make a report.

We also do not accept any person resident in, a national of, or materially connected to a jurisdiction subject to a Financial Action Task Force call for action, or to comprehensive international sanctions.

4. Due diligence, and our right to refuse

We verify the identity of every client for every transaction, at every amount, and we screen every client against sanctions, politically exposed person and adverse media sources. Where crypto-assets are involved we screen the wallet addresses concerned. Above €15,000 we require documented evidence of the source of the funds.

We may decline an enquiry, refuse to make an introduction, or end a relationship at any time and without giving reasons. In some circumstances we are prohibited by law from telling you why, and from telling you that a report has been made or is contemplated. Where we decline without explanation, no inference should be drawn from our silence in either direction.

The registered provider carries out its own checks and reaches its own decision. It may decline you after we have accepted you. We have no control over that decision.

5. No advice

Nothing on this website and nothing said by us constitutes investment, tax, accounting or legal advice, or a personal recommendation. We are not authorised to provide investment advice and we do not do so. We take no position in any market and have no financial interest in the movement of any price. You are responsible for your own decisions and for your own tax position.

6. What this costs you

P2P Broker does not charge you a fee. There is no platform fee, no commission and no subscription. Using the site, being verified and being introduced cost you nothing.

The rate shown on the calculator is the market reference rate with a small floating margin applied. That margin belongs to your counterparty — the individual you are matched with, or the registered provider where one executes the transaction — and it is how they are compensated for taking the other side. It is currently around 3%, it moves, and it is already included in the figures shown, so nothing is added afterwards. The exact figure is confirmed to you before anything is settled.

The margin covers the cost of operating the service. Until our licensed Montenegrin company is incorporated, the service is operated on a non-profit basis and no profit is taken from it. We will say so here when that changes.

Outstanding, and this clause must be settled before launch. It has to state WHO charges the margin: if the registered provider quotes the price and this service is paid an introduction fee out of it, that is a different arrangement from the one the sentence above describes, and the website would be misrepresenting who sets the price. Whatever the introducer agreement actually says must be reflected both here and in src/config/pricing.ts.

7. Complaints

Outstanding. To set out how a complaint is made, who handles it, the response deadline, and what recourse a client has afterwards. Counsel to confirm whether any statutory complaints or ADR route applies to an unregistered introducer in Montenegro.

8. Liability

Outstanding, and to be drafted by Montenegrin counsel rather than adapted from another jurisdiction. Any limitation must be tested against Montenegrin consumer protection law, which is likely to restrict what can be excluded against a consumer.

9. Governing law, jurisdiction and language

Outstanding. To specify Montenegrin law and the competent court, and to state which language version of these terms governs — noting that a governing-language clause may have limited effect against a consumer resident in Montenegro. See the note in the source of this section.