Regulatory Status

BitLease Technologies Ltd. A subsidiary of 49G Holding Ltd. Incorporated in Abu Dhabi Global Market (ADGM) Registered Address: Unit PC-1, Level 7, Al Maryah Tower, Abu Dhabi Global Market Square, Abu Dhabi, Al Maryah Island, United Arab Emirates

ADGM Registration No.: 34619

Last Updated: 21 March 2026

Effective Date: 21 March 2026

Version: 1.0

1. Corporate Identity

1.1 The Company

BitLease Technologies Ltd. (“BitLease”) is a technology company incorporated in Abu Dhabi Global Market (ADGM), United Arab Emirates, and a wholly owned subsidiary of 49G Holding.

BitLease operates a structured digital asset financing platform under the Lease-to-Own (LTO) model, a contractual installment-based framework enabling users to acquire the Economic Utility of a digital asset from day one, with Formal On-Chain Ownership retained by BitLease in MPC-secured escrow (Fireblocks) and transferred to the user upon completion of all payment obligations. All contracts are denominated in stablecoins.

1.2 The Parent Company

49G Holding is BitLease’s parent company, responsible for technology development, risk management infrastructure, quantitative modeling, and the proprietary HyperHedge™ solvency engine.

2. What BitLease Is

BitLease is a structured digital asset leasing platform. The service it provides is the contractual acquisition of digital assets through a payment-based, non-collateralized installment arrangement that mirrors traditional leasing and hire-purchase models.

Within this framework:

1. Users (Clients) enter into bilateral LTO Contracts (Contract A, Ownership Contract) with BitLease to acquire digital assets through scheduled stablecoin payments;
2. Institutional Capital Providers (Lessors) enter into separate bilateral Investment Contracts (Contract B, Yield Contract) with BitLease to deploy capital in exchange for a fixed-rate, contractual yield.
3. BitLease acts as the Direct Counterparty to both sides. Clients and Lessors have no relationship with each other. BitLease absorbs all market and counterparty risk between the two sides through the HyperHedge™ solvency program.
4. Each digital asset under LTO is separated into two layers: Economic Utility (granted to the Client from day one) and Formal On-Chain Ownership (retained by BitLease in escrow until full payment).
5. Contract continuity is 100% payment-based. No liquidation, no margin calls, no collateral. All contracts are non-recourse, meaning the Client’s maximum loss is limited to payments made.

3. What BitLease Is Not

BitLease has established clear boundaries around its operations and regulatory classification. The following table sets out what BitLease is not, the basis for each distinction, and the regulatory consequence.

4. Regulatory Licensing Status

4.1 Current Status

BitLease is actively pursuing regulatory licenses and registrations in the following jurisdictions: As of the effective date, no license has been granted.

4.2 Implications of Licensing Status

1. Service availability: The availability of BitLease’s services in any jurisdiction is contingent upon obtaining the necessary regulatory approvals. Services may be restricted, modified, or unavailable in jurisdictions where regulatory requirements have not been met.
2. No regulatory endorsement: The fact that BitLease has applied for licenses does not constitute regulatory approval, endorsement, or recommendation by any authority. Pending applications may be denied.
3. Compliance regardless of licensing: BitLease maintains its AML/CFT program, consumer protection measures, data protection compliance, custody standards, and solvency framework regardless of licensing status. These measures are implemented as a matter of institutional policy, not solely in response to licensing conditions.
4. Regulatory classification may vary: The LTO model may be classified differently by different regulators. BitLease engages with each authority to ensure appropriate compliance within their framework, and will adapt its operational and compliance structure as required.
5. Wind-down provisions: If a license application is denied or a jurisdiction becomes legally unfeasible, BitLease will wind down affected operations in an orderly manner, ensuring that active LTO Contracts are settled with full Client protections (Buyout, surplus value, non-recourse) preserved.

4.3 Jurisdictional Restrictions

BitLease does not provide services to:

1. Citizens, nationals, residents, or tax residents of the United States of America. US persons are prohibited from accessing or using the Platform in any capacity. This restriction reflects the complexity and uncertainty of the US regulatory environment for digital asset services, and BitLease’s determination that it cannot currently ensure compliance with all applicable US federal and state regulations.
2. Persons located in Restricted Jurisdictions. The current list is maintained on the Platform and includes jurisdictions subject to comprehensive international sanctions and jurisdictions where BitLease has determined it cannot comply with local law.
3. Sanctioned persons and entities. Persons listed on any applicable sanctions list (OFAC SDN, EU, UN, UK, UAE) are prohibited from using the Platform.

These restrictions are enforced through identity verification (KYC/KYB), jurisdiction declarations, IP-based geolocation screening, ongoing monitoring, and contractual prohibitions in the Terms of Service.

5. Compliance Framework

5.1 Overview

BitLease operates under a compliance-first framework that is intentionally designed to meet or exceed the standards expected of regulated financial institutions, even where such standards are not yet legally mandated for the Company’s specific activity classification. This approach reflects BitLease’s belief that institutional-grade compliance is a prerequisite for the trust that the LTO model requires.

5.2 Compliance Domains

5.3 Voluntary Adoption of Higher Standards

In several areas, BitLease voluntarily adopts standards beyond what is currently required of its activity classification:

6. Platform Reference Pricing: Regulatory Context

6.1 Pricing Methodology

BitLease is not an exchange and does not facilitate price discovery. The digital asset prices displayed on the Platform (“Platform Reference Prices”) are BitLease’s proprietary reference prices, which are derived using BitLease’s internal pricing methodology. This methodology collects institutional market data and incorporates execution spreads, timing of trades, and certain market liquidity adjustments.

6.2 Price Disclaimer

Please note that prices in Platform Reference Prices may differ from real-time spot market prices on cryptocurrency exchanges, and such differences may be material.

This is one of the characteristics of the non-exchange nature of the BitLease Platform. BitLease does not provide an order book, and the supply and demand are not matched. The Platform Reference Price serves as an internal valuation rate for the purpose of LTO Contract calculation and is not a market price.

6.3 Regulatory Implication

Because BitLease is not an exchange:

(a) Best-execution obligations applicable to exchanges and brokers do not apply;

(b) Market data regulations applicable to trading venues do not apply;

(c) Pre-trade and post-trade transparency requirements applicable to trading venues do not apply;

(d) The Platform Reference Price methodology is disclosed to users in the Terms of Service and Contract Summary, consistent with transparency obligations applicable to structured finance.

7. Stablecoin Denomination: Regulatory Context

7.1 Payment Medium

All LTO Contracts, payments, and settlements are denominated in stablecoins. Fiat currency is not accepted on the Platform unless explicitly stated for specific jurisdictions.

7.2 Regulatory Classification

Stablecoins are subject to evolving regulatory classification across jurisdictions:

(a) EU (MiCA): Stablecoins may be classified as “asset-referenced tokens” or “e-money tokens” under MiCA, each with specific regulatory requirements for issuers and service providers;

(b) UAE/ADGM: ADGM FSRA has issued guidance on fiat-referenced tokens and their treatment.

(c) UK: HM Treasury and the FCA are developing a regulatory framework for stablecoins.

(d) Singapore: MAS regulates stablecoins under the Payment Services Act.

BitLease does not issue stablecoins. BitLease accepts stablecoins as the payment medium for LTO Contracts. The regulatory classification of the stablecoins accepted on the Platform may affect the regulatory treatment of BitLease’s services in certain jurisdictions.

7.3 Stablecoin Risk Disclosure

Stablecoins are not guaranteed by any government, deposit insurance scheme, or central bank. They may lose their peg, become illiquid, or be subject to regulatory action. BitLease does not guarantee the solvency or stability of any stablecoin issuer. Full risks are disclosed in the Risk Disclosure Statement.

8. Custody: Regulatory Context

8.1 Custody Arrangement

All digital assets under LTO Contracts are held in MPC-secured custody provided by Fireblocks, segregated from BitLease operational assets, and not subject to rehypothecation, lending, or third-party use.

8.2 Regulatory Treatment

The custody of digital assets is a regulated activity in several jurisdictions where BitLease operates or plans to operate:

1. ADGM: The FSRA regulates the custody of virtual assets under its Virtual Asset Framework;
2. EU (MiCA): The custody and administration of crypto-assets on behalf of clients is a regulated crypto-asset service under MiCA;
3. UK: The FCA requires registration for firms involved in crypto-asset custody;
4. Singapore: Custody of digital payment tokens may fall within MAS regulatory scope.

BitLease’s licensing applications encompass custody-related activities to the extent required by each jurisdiction’s framework. BitLease’s custody standards are designed to meet or exceed the requirements of all target jurisdictions.

8.3 Fireblocks Partnership

BitLease’s custody partnership with Fireblocks, a leading institutional digital asset security platform, ensures MPC technology with distributed key shares, no single point of compromise, insurance coverage for custodied assets, SOC 2 Type II certified infrastructure, and compliance with institutional custody standards expected by regulators.

9. Third-Party Verification and Transparency

9.1 Chainlink Proof of Reserve

BitLease plans to integrate Chainlink Proof of Reserve to provide independent, on-chain, publicly verifiable attestation of the HyperHedge™ solvency invariant (TAV + HPNL ≥ Total Lessor Debt).

This integration is planned and not yet operational as of the effective date.

Upon activation:

1. Any party, whether users, regulators, institutions, or the public, will be able to independently verify BitLease’s solvency at any time;
2. Verification will be on-chain and tamper-proof;
3. This represents a transparency standard that exceeds what is currently required of any regulated financial institution.

9.2 Current Transparency Measures

Until Chainlink integration is operational, BitLease provides the following: HyperHedge™ solvency metrics on the Platform (currently labeled as SIMULATED PREVIEW pre-launch, transitioning to live data at platform launch), a platform metrics dashboard (metrics activate at launch and are displayed as “—” pre-launch), annual external financial audit, regulatory reporting as required by each jurisdiction, and institutional Lessor reporting packages with aggregated solvency data.

10. Interaction with Specific Regulatory Frameworks

10.1 ADGM FSRA: Virtual Asset Framework

We note that BitLease is an operating entity incorporated in ADGM, and the licence application to the FSRA is to carry on the Virtual Asset business from ADGM. The Application addresses a range of matters, including the regulation of virtual asset business in ADGM, the custody of virtual assets, Anti Money Laundering/Counter Financing of Terrorism (“AML/CFT”) under the regulatory framework of ADGM, technology governance and operational resilience, as well as consumer protection and conduct of business.

10.2 VARA: Dubai Virtual Asset Regulations

We engage with VARA (Virtual Assets & Regulations Authority) to ensure adherence to any VARA regulations applicable to our services, such as virtual asset management and investment services (where applicable), digital custody services, compliance and risk management, as well as consumer protection. VARA is an independent regulatory body that regulates Virtual Asset Service Providers (VASPs) undertaking Virtual Asset activities in or from Dubai (excluding ADGM and DIFC).

10.3 MiCA: Markets in Crypto-Assets Regulation (EU)

MiCA regulation provides a regulatory framework for crypto-asset service providers at the EU level. For BitLease, relevant parts include authorization as a Crypto-Asset Service Provider (CASP), conduct of business rules, Anti Money Laundering and Combating the Financing of Terrorism (AML/CFT) as per EU AMLD, consumer protection rules, custody and administration rules, governance and capital requirements, and rules regarding accepted payment stablecoins.

10.4 FCA: United Kingdom

The FCA’s crypto-asset policy paper also applies to BitLease’s activities in relation to business carried out from or which otherwise relates to the UK. The matters we are considering include: The need for a firm carrying on crypto-asset activities to be registered under the Money Laundering Regulations, the regulation of financial promotions of crypto-assets and the Consumer Duty in relation to crypto-assets; the need for authorisation under a new regime as we move towards a more comprehensive authorisation regime for crypto-asset businesses; and issues in relation to the custody and safeguarding of crypto-assets.

10.5 MAS: Monetary Authority of Singapore

We are currently regulated by the Monetary Authority of Singapore (MAS) under the Payment Services Act, and fall under categories that include licensing as a digital payment token service provider, MAS Notices for Anti Money Laundering/COUNTER Terrorism Financing (AML/CFT), MAS TRM Guidelines for technology risk management, as well as guidelines for business conduct and consumer protection.

11. Important Disclaimers

11.1 No Regulatory Endorsement

Nothing in this document, on the Platform, or in any BitLease communication constitutes or implies:

1. Regulatory approval, endorsement, or recommendation of BitLease, its products, or its services by any regulatory authority;
2. That any regulatory authority has verified the accuracy or adequacy of BitLease’s disclosures;
3. That licensing applications will be granted;
4. That regulatory classification of the LTO model has been definitively determined by any authority.

11.2 No Regulated Financial Service Unless Stated

Nothing on the Platform shall be construed as a regulated financial service, including banking, lending, credit, brokerage, investment advice, portfolio management, derivatives, or insurance, unless:

1. Explicitly stated in connection with a specific jurisdiction where BitLease has obtained the relevant license; and
2. The specific license and regulatory reference are cited.

11.3 Evolving Regulatory Landscape

The regulation of digital assets is evolving rapidly. Regulatory frameworks may change in ways that affect the classification of BitLease’s services, the licensing requirements applicable to BitLease, the availability of services in specific jurisdictions, the operational structure of the Platform, and the terms of LTO Contracts.

BitLease monitors regulatory developments continuously and will adapt its operations as required. Material changes affecting users will be communicated in accordance with the Terms of Service.

11.4 Independent Advice

BitLease does not provide legal, financial, investment, or tax advice. Users are advised to seek independent professional advice regarding the regulatory status of BitLease’s services in their jurisdiction, the legal characterization of LTO Contracts under their local law, the tax treatment of LTO Contracts, payments, Buyout proceeds, and staking rewards, and whether the LTO model is appropriate for their financial circumstances.

12. Contact

For regulatory inquiries:

BitLease Technologies Ltd. A subsidiary of 49G Holding Ltd. Incorporated in Abu Dhabi Global Market (ADGM) Registered Address: Unit PC-1, Level 7, Al Maryah Tower, Abu Dhabi Global Market Square, Abu Dhabi, Al Maryah Island, United Arab Emirates

ADGM Registration No.: 34619

Last Updated: 21 March 2026

Website: www.bitlease.com