Redemption Policy
Revisions 12/02/2026
Eurodollar EMT Redemption Policy
1. Introduction and purpose
This Eurodollar EMT Redemption Policy (the Redemption Policy) sets out how Eurodollar ApS (Eurodollar or the Issuer) will fulfil redemption requests in respect of the EMT(s), as defined in the Eurodollar E-money Token Terms & Conditions (the Terms and Conditions).
This Redemption Policy is intended to:
describe the ordinary-course process by which holders of EMT(s) may redeem EMT(s) for the applicable anchor currency; and
explain the contingency redemption arrangements that Eurodollar will implement in the event that it is unable to continue to honour redemption requests in the ordinary course of business, including in stress or insolvency scenarios.
This Redemption Policy should be read together with, and is subject to, the Terms and Conditions and the applicable EMT whitepaper(s). Capitalised terms used but not defined in this Redemption Policy have the meaning given to them in the Terms and Conditions.
2. Scope and relationship to other documents
2.1 Scope of this Redemption Policy This Redemption Policy applies to all EMT(s) issued by Eurodollar under and in accordance with the Terms and Conditions, regardless of denomination or anchor currency.
2.2 Relationship to the Terms and Conditions The Terms and Conditions set out, among other things:
the legal nature of the EMT(s);
the rights and obligations of Customers and EMT Holders; and
the operational framework for Mint Requests and Redemption Requests.
In the event of any inconsistency between this Redemption Policy and the Terms and Conditions, the Terms and Conditions prevail. This Redemption Policy supplements, and does not limit, the rights and obligations set out in the Terms and Conditions.
2.3 Relationship to EMT whitepaper(s) The applicable EMT whitepaper(s) describe the characteristics of the EMT(s), the anchor currencies and the regulatory classification of the EMT(s) under applicable law (including Regulation (EU) 2023/1114 on markets in crypto-assets (MiCAR)). Where those documents describe a redemption plan or high-level redemption arrangements, this Redemption Policy constitutes the detailed plan referred to in such documents and should be interpreted consistently with them.
3. Key principles
Eurodollar will operate and, where relevant, activate this Redemption Policy in accordance with the following key principles:
Par value redemption – Subject to the Terms and Conditions and applicable law, EMT(s) are intended to be redeemable at par against the relevant anchor currency (i.e. one unit of the applicable anchor currency per EMT), less any fees expressly permitted under the Terms and Conditions and published Pricing.
Equitable treatment – Where this Redemption Policy is activated, Eurodollar will treat Customers and EMT Holders equitably and without undue preference between holders of the same class of EMT(s), subject always to applicable law and any mandatory creditor ranking.
Segregation and application of Reserve Assets – Reserve assets corresponding to outstanding EMT(s) (the Reserve Assets) will be held separately from Eurodollar’s own funds in accordance with applicable law and will be applied for the benefit of EMT Holders and Customers in accordance with this Redemption Policy, the Terms and Conditions and applicable law.
Transparency and communication – Eurodollar will communicate clearly, in a timely manner and through appropriate channels about the status of redemption, the activation of this Redemption Policy and any material changes to the redemption process.
Regulatory compliance – All redemption processes described in this Redemption Policy are subject to, and will be implemented in accordance with, applicable law, regulatory requirements and directions of any competent authority or insolvency practitioner.
4. Ordinary-course redemption
4.1 Right to redeem EMT(s) Subject to the Terms and Conditions, Customers have the right at any time to submit a Redemption Request for EMT(s) through their Account. EMT Holders who are not Customers must first open an Account and comply with all applicable onboarding, KYC and AML requirements before they are able to submit Redemption Requests.
4.2 How to submit a Redemption Request In the ordinary course of business:
A Customer initiates a Redemption Request through their Account, specifying:
the number of EMT(s) to be redeemed; and
the bank account details or other permitted payout details for receipt of the applicable anchor currency.
Eurodollar verifies that:
the Customer’s Account and Wallet are eligible under the Terms and Conditions;
the Redemption Request complies with applicable KYC/AML, sanctions and other compliance requirements; and
the Customer’s Wallet contains at least the number of EMT(s) specified in the Redemption Request.
Once the Redemption Request is accepted, the EMT(s) subject to that Redemption Request will be Burned in accordance with the Terms and Conditions.
Following Burn, Eurodollar will transfer an equivalent amount of the applicable anchor currency (less any applicable fees) to the Customer’s designated bank account or other permitted payout method.
4.3 Timing Eurodollar will use reasonable endeavours to process Redemption Requests as soon as reasonably practicable, taking into account:
operational hours of Eurodollar;
banking system cut-off times and settlement cycles;
blockchain network conditions; and
any compliance reviews that must be completed.
Eurodollar does not guarantee that redemption will be instantaneous. Where material delays occur or are expected, Eurodollar will notify affected Customers through their Accounts and/or more broadly where appropriate.
4.4 Fees and charges Any fees payable in connection with Redemption Requests will be as set out in the pricing published by Eurodollar from time to time (the Pricing). Network fees (e.g. blockchain gas fees) and third-party banking or payment provider fees may also apply and are the responsibility of the Customer unless otherwise stated.
5. Contingency redemption plan
5.1 Activation events
This Section 5 describes the contingency redemption plan that Eurodollar will implement if it is not able to continue to honour Redemption Requests in the ordinary course of business. Examples of situations in which this contingency redemption plan may be activated include:
a severe or prolonged liquidity disruption impacting Eurodollar’s ability to satisfy Redemption Requests as they fall due;
an Insolvency Event (as defined in the Terms and Conditions) in respect of Eurodollar;
a requirement or direction of a competent regulatory authority or court that materially restricts or alters ordinary-course redemption; or
any other event or combination of events which, in Eurodollar’s reasonable opinion (or that of any appointed insolvency practitioner), makes activation of this Redemption Policy necessary to protect EMT Holders and Customers.
The occurrence of any of the above events does not automatically terminate the EMTs or extinguish rights of redemption, but may change the manner and timing in which redemption is conducted.
5.2 Objectives of the contingency redemption plan
Upon activation, the objectives of the contingency redemption plan are to:
apply the Reserve Assets for the benefit of EMT Holders and Customers, in accordance with applicable law;
redeem EMT(s) for the applicable anchor currency, or where permitted, for another EMT or other eligible asset, in an orderly and equitable manner; and
provide a clear, transparent process and timeframe for the implementation of redemptions.
5.3 Suspension or adjustment of ordinary Redemption Requests
Upon activation of the contingency redemption plan, Eurodollar (or any appointed insolvency practitioner or administrator, as applicable) may:
temporarily suspend the initiation or processing of new Redemption Requests;
cancel or modify pending Redemption Requests, with any EMT(s) subject to such requests being treated in accordance with the contingency plan; and
replace the ordinary Redemption Request process with the special process described in Section 5.4.
Any such measures will be communicated to Customers and EMT Holders as soon as reasonably practicable.
5.4 Special redemption process
The special redemption process may include one or more of the following steps, depending on the nature of the activation event and applicable law:
Record date and claims submission
Eurodollar (or any insolvency practitioner) will determine and announce a record date for establishing the outstanding EMT balances per Customer and EMT Holder.
Customers and EMT Holders may be required to submit claims or confirm their EMT balances and provide or update payment details within a specified period.
Verification and reconciliation
EMT balances will be verified using on-chain data, Eurodollar’s internal records and, where necessary, supporting information provided by Customers and EMT Holders.
Any disputed or unclear balances may be subject to additional review and, if unresolved, may be treated in accordance with applicable insolvency or dispute-resolution procedures.
Determination of distributable amount
The total amount of Reserve Assets (after deducting applicable costs, expenses and any amounts required to be held or applied in a particular manner under applicable law) will be determined.
If the Reserve Assets are insufficient to redeem all EMT(s) at par, the available amount will be allocated on a pro-rata basis among all eligible EMT(s), subject to applicable law and any mandatory creditor ranking.
Distribution of proceeds
Distributions will be made in the relevant anchor currency to the bank account or other permitted payout method associated with the Customer’s Account or, in the case of EMT Holders without an Account, to such payout details as may be provided and verified in accordance with instructions communicated at the time.
Where permitted and practicable, Eurodollar (or any insolvency practitioner) may offer holders the ability to receive redemption proceeds, in whole or in part, in another EMT or in another form of consideration, provided that this is consistent with applicable law and does not put any holder at an unfair disadvantage.
5.5 Treatment of different series or classes of EMT(s)
If there are multiple series or classes of EMT(s) outstanding, the contingency redemption plan may provide for:
separate pools of Reserve Assets for each series or class; and/or
separate pro-rata calculations per series or class.
Any such treatment will be described in the relevant EMT whitepaper(s) or other product-specific documentation, and will be implemented consistently with those documents and applicable law.
5.6 Governance and oversight
Where an Insolvency Event has occurred, this Redemption Policy will be implemented subject to the control and supervision of the relevant insolvency practitioner, court and/or competent regulatory authority. In all cases, Eurodollar will cooperate with such authorities and practitioners and will provide them with relevant information and assistance to enable an orderly implementation of this Redemption Policy.
6. Communication and information
6.1 Communication channels
Eurodollar will communicate with Customers primarily through their Accounts and, where appropriate, through the Eurodollar website, email and other communication channels specified in the Terms and Conditions.
Eurodollar will communicate with EMT Holders who are not Customers via:
public notices on the Eurodollar website;
updates to the applicable EMT whitepaper(s); and
any other means reasonably designed to reach EMT Holders, taking into account applicable law and practical constraints.
6.2 Notices relating to this Redemption Policy
In particular, Eurodollar (or any insolvency practitioner, as applicable) will:
give notice of the activation of the contingency redemption plan described in Section 5;
provide regular updates on the status of redemption, including expected timelines and any changes to process; and
publish or otherwise make available details of any special claim submission or verification process that EMT Holders and Customers must follow.
7. Risk factors and limitations
7.1 Regulatory and legal constraints
The implementation of this Redemption Policy may be constrained or varied by:
applicable law, including insolvency, payments, consumer protection and anti-money laundering laws;
directions, orders or guidance from competent authorities or courts; and
contractual arrangements with third-party service providers (such as banks, custodians and payment service providers).
Where such constraints require deviations from this Redemption Policy, Eurodollar (or any insolvency practitioner) will act reasonably, in good faith and with a view to treating EMT Holders and Customers equitably, while complying with applicable law.
7.2 Operational risks
Redemption processes may be affected by operational risks, including:
failures or delays in banking or payment systems;
disruptions or congestion in blockchain networks;
cybersecurity incidents; or
failures, outages or errors at third-party service providers.
Eurodollar will use reasonable endeavours to mitigate such risks but cannot guarantee that redemption will always be available without interruption or delay.
7.3 No guarantee beyond Reserve Assets and applicable law
The ability to redeem EMT(s) ultimately depends on the availability and realisation of the Reserve Assets and on the application of applicable law in any stress or insolvency scenario. This Redemption Policy does not constitute a guarantee by Eurodollar or any affiliate that EMT(s) will always be redeemable at par in all circumstances.
8. Amendments
Eurodollar may amend this Redemption Policy from time to time, including to:
reflect changes in applicable law or regulatory guidance;
reflect changes in Eurodollar’s business model, risk management framework or operational capabilities; or
clarify or improve the description of existing practices.
Unless otherwise required by applicable law or a competent authority, amendments to this Redemption Policy will take effect:
in the ordinary course, on the date specified in the updated version published on Eurodollar’s website or communicated through the Services, but not earlier than the date required under the Terms and Conditions (if any); and
immediately, where the amendment does not constitute a material change or is beneficial to Customers and EMT Holders, or where immediate effect is required to comply with applicable law or a direction from a competent authority.
Where required by the Terms and Conditions or applicable law, Eurodollar will provide advance notice of material changes to this Redemption Policy and Customers’ rights to terminate their relationship with Eurodollar if they do not agree with such changes.
9. Governing law and jurisdiction
This Redemption Policy, and any non-contractual obligations arising out of or in connection with it, is governed by and shall be construed in accordance with the laws specified in the Terms and Conditions as the governing law of the relationship between Eurodollar and its Customers in respect of the EMT(s).
Any disputes arising out of or in connection with this Redemption Policy shall be resolved in accordance with the dispute resolution and jurisdiction provisions set out in the Terms and Conditions.
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