RISK DISCLOSURE

Last updated: 13 August 2026

Finance Act Limited, trading as ESCALO («ESCALO», «we», «us», or «our»), operates in an environment involving financial markets, payment infrastructure, currency exchange, P2P markets, liquidity management, transaction processing and international financial operations.

These activities involve inherent risks.

This Risk Disclosure is intended to provide a general overview of the principal risks that may arise in connection with ESCALO’s activities, technology, infrastructure and related services.

It is not intended to describe every possible risk and should not be treated as financial, investment, legal, tax or other professional advice.

Before entering into any transaction or contractual relationship, you should carefully consider the risks relevant to your particular circumstances and obtain independent professional advice where appropriate.

1. About ESCALO

Finance Act Limited
Trading as ESCALO
Company number: 16839569

Registered office:

58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

This Risk Disclosure applies to information published by ESCALO and, where relevant, to risks associated with the services and operational activities described on our website.

Specific services may be subject to additional contractual terms, risk disclosures, eligibility requirements and regulatory documentation.

2. General Risk Warning

Financial markets and payment operations are inherently uncertain.

Market conditions, exchange rates, liquidity, transaction costs, counterparty availability, banking infrastructure, payment networks, regulatory requirements and technical conditions can change rapidly.

There is no guarantee that a particular transaction, payment route, exchange opportunity, spread or market condition will remain available or executable.

Where a transaction involves financial risk, you may lose money.

You should not enter into a transaction unless you understand the relevant risks and have determined that the activity is appropriate for your circumstances.

3. No Guarantee of Profit

ESCALO does not guarantee:

• profitability;
• a particular return;
• a particular exchange rate;
• a particular spread;
• a particular transaction volume;
• execution at a particular price;
• availability of liquidity;
• availability of a counterparty;
• completion within a particular timeframe;
• uninterrupted access to a payment route;
• future market opportunities.

Historical performance, examples, illustrations or descriptions of previous market conditions do not guarantee future results.

Any reference to efficiency, optimisation, spreads, market opportunities or potential advantages should not be interpreted as a promise of financial performance.

4. Market Risk

Currency and financial markets can change rapidly.

Exchange rates may move due to:

• economic developments;
• interest-rate changes;
• monetary policy;
• inflation;
• political events;
• geopolitical developments;
• market sentiment;
• liquidity conditions;
• regulatory changes;
• unexpected market events.

A price or spread that appears available at one point in time may no longer exist when an order or transaction is executed.

Market movements can reduce or eliminate an expected economic advantage.

5. P2P Market Risk

P2P markets involve transactions between participants through connected platforms, marketplaces or payment channels.

P2P activity may be affected by:

• changes in supply and demand;
• liquidity;
• counterparty availability;
• platform rules;
• transaction limits;
• payment processing times;
• exchange rates;
• fees;
• account restrictions;
• fraud;
• compliance checks;
• technical failures.

An opportunity identified through market data may disappear before execution.

The existence of an apparent price difference does not necessarily mean that a profitable or executable transaction exists.

6. Spread Risk

A difference between buy and sell prices does not necessarily represent realised profit.

The effective economic outcome of a transaction may be affected by:

• trading fees;
• payment fees;
• exchange costs;
• settlement costs;
• conversion costs;
• network fees;
• delays;
• slippage;
• liquidity limitations;
• counterparty behaviour;
• unexpected restrictions;
• changes in market prices.

A gross spread may therefore differ significantly from the final net result.

7. Execution Risk

A transaction may not execute at the price, volume or timing initially observed.

Execution may be affected by:

• market movement;
• order-book depth;
• insufficient liquidity;
• changes in available offers;
• transaction limits;
• platform restrictions;
• technical delays;
• payment delays;
• compliance checks;
• counterparty actions.

A transaction that appears executable based on available market information may become unavailable before completion.

8. Liquidity Risk

Liquidity refers to the availability of sufficient market or payment capacity to execute a transaction.

Liquidity may change rapidly.

Insufficient liquidity may result in:

• partial execution;
• delayed execution;
• inability to complete a transaction;
• less favourable pricing;
• increased transaction costs;
• increased exposure while waiting for settlement.

Higher transaction volumes may create additional liquidity challenges.

There is no guarantee that sufficient liquidity will be available at a particular time.

9. Order Book and Market Depth Risk

Market prices may be based on available buy and sell offers at different volumes.

A quoted price may apply only to a limited amount.

Executing a larger transaction may require using multiple price levels, resulting in an average execution price that differs from the initially observed price.

Market depth may change between observation and execution.

10. Slippage Risk

Slippage occurs when the final execution price differs from the price observed or expected before execution.

Slippage may result from:

• market volatility;
• insufficient liquidity;
• rapid changes in market conditions;
• order size;
• execution delays;
• platform conditions;
• technical latency.

Slippage may reduce or eliminate an expected spread.

11. Counterparty Risk

Financial and payment operations may involve third parties.

Counterparties may include:

• financial institutions;
• payment providers;
• electronic money institutions;
• exchanges;
• marketplaces;
• liquidity providers;
• settlement providers;
• corporate customers;
• other transaction counterparties.

A counterparty may fail to perform its obligations, delay settlement, reject a transaction, restrict an account or become unavailable.

Such events may result in financial loss, delays or additional operational costs.

12. Payment Provider and Banking Risk

Payment operations may depend on banks, payment institutions, electronic money institutions and other financial infrastructure providers.

A third-party provider may:

• delay a payment;
• reject a payment;
• suspend an account;
• restrict a transaction;
• conduct additional compliance checks;
• impose transaction limits;
• experience technical disruption;
• change its services or requirements;
• terminate a relationship.

ESCALO may not have direct control over the decisions, policies or systems of third-party financial institutions.

13. Settlement Risk

A transaction may involve multiple stages between initiation and final settlement.

Risks may arise if:

• one party settles later than expected;
• a payment is delayed;
• a transaction is reversed;
• a receiving institution rejects funds;
• a payment route becomes unavailable;
• additional compliance checks are initiated;
• technical issues prevent completion.

Settlement delays may create temporary financial or operational exposure.

14. Currency Risk

Where transactions involve more than one currency, exchange-rate movements may affect the economic result.

A currency may strengthen or weaken between:

• order placement;
• execution;
• conversion;
• payment initiation;
• settlement;
• receipt of funds.

Even relatively small currency movements may materially affect the result of high-volume transactions.

15. Foreign Exchange Conversion Risk

Currency conversion involves exposure to exchange-rate differences and conversion costs.

The exchange rate available at one point may differ from the rate available later.

The final amount received may also be affected by:

• conversion fees;
• spreads;
• intermediary charges;
• payment provider fees;
• settlement costs;
• timing differences.

16. Transaction Delay Risk

Transactions may take longer than expected.

Delays may result from:

• banking processes;
• payment networks;
• compliance reviews;
• fraud controls;
• sanctions screening;
• technical failures;
• weekends or public holidays;
• third-party service availability;
• operational errors;
• regulatory requirements.

A delay may cause an expected market opportunity to change or disappear.

17. Transaction Reversal Risk

Certain payments or transactions may be reversed, rejected, recalled or otherwise adjusted.

Reasons may include:

• incorrect payment information;
• compliance requirements;
• fraud concerns;
• payment provider policies;
• technical errors;
• insufficient information;
• regulatory requirements;
• counterparty actions.

A reversal may create reconciliation issues, temporary liquidity requirements or financial exposure.

18. Fraud Risk

Financial operations may be exposed to fraud and attempted fraud.

Potential risks include:

• identity fraud;
• account takeover;
• payment fraud;
• impersonation;
• social engineering;
• fraudulent payment instructions;
• stolen credentials;
• manipulated documents;
• fraudulent counterparties.

ESCALO maintains controls designed to mitigate these risks, but no fraud prevention system can eliminate risk completely.

19. Cybersecurity and Technology Risk

ESCALO relies on software, technology, communications systems and digital infrastructure.

Technology-related risks may include:

• system failures;
• software errors;
• cybersecurity incidents;
• malware;
• unauthorised access;
• data breaches;
• infrastructure outages;
• connectivity failures;
• third-party technology failures;
• system latency;
• inaccurate or delayed data.

A technical incident may result in delays, unavailable services, incorrect information or financial loss.

20. Data and Market Information Risk

ESCALO may rely on information received from exchanges, marketplaces, financial institutions, payment providers and other sources.

Market or transaction information may be:

• delayed;
• incomplete;
• inaccurate;
• temporarily unavailable;
• affected by technical problems.

Automated systems may process information based on data received from external sources.

ESCALO seeks to maintain appropriate controls, but cannot guarantee that all third-party information will always be accurate or available.

21. Third-Party Platform Risk

Where operations involve third-party platforms, ESCALO may be exposed to changes in:

• platform rules;
• transaction limits;
• fees;
• account policies;
• verification requirements;
• availability;
• technical architecture;
• API access;
• compliance requirements.

A third-party platform may suspend, restrict or terminate access.

Such an event may affect the ability to complete or execute certain transactions.

22. Regulatory and Legal Risk

Financial markets and payment services operate within changing legal and regulatory environments.

Changes in law or regulation may affect:

• permitted activities;
• customer eligibility;
• transaction requirements;
• reporting obligations;
• KYC requirements;
• AML controls;
• sanctions;
• payment routes;
• market access;
• tax treatment.

Regulatory changes may increase operational costs or restrict certain activities.

ESCALO may modify, restrict or discontinue activities where required by applicable law or regulation.

23. Compliance Risk

Transactions may be subject to:

• KYC checks;
• AML checks;
• sanctions screening;
• fraud screening;
• transaction monitoring;
• source-of-funds checks;
• source-of-wealth checks;
• additional verification.

A transaction may be delayed or rejected as a result.

In some circumstances, ESCALO may be legally unable to provide detailed information about the reason for a compliance decision.

24. Sanctions Risk

Transactions involving certain persons, organisations or jurisdictions may be subject to sanctions restrictions.

Sanctions regimes may change rapidly.

A transaction may therefore become restricted or prohibited after an initial assessment.

ESCALO may suspend or reject activity where required by applicable sanctions laws.

25. Counterparty Concentration Risk

Where a significant proportion of activity depends on a limited number of counterparties, providers or financial institutions, the failure or restriction of one provider may have a greater impact.

Concentration may increase operational and settlement risk.

ESCALO seeks to manage relevant dependencies through appropriate operational and risk-management processes.

26. Operational Risk

Operational risk may arise from:

• human error;
• process failures;
• incorrect instructions;
• communication failures;
• reconciliation errors;
• inadequate controls;
• system failures;
• third-party failures;
• unexpected operational events.

Operational controls are designed to reduce these risks, but operational errors cannot be eliminated entirely.

27. Liquidity and Funding Risk

Financial operations may require sufficient liquidity to support transactions and settlement obligations.

Liquidity may become temporarily unavailable due to:

• delayed settlement;
• payment restrictions;
• unexpected transaction volumes;
• counterparty failure;
• market disruption;
• banking restrictions;
• compliance actions.

A liquidity shortage may result in delayed or reduced transaction capacity.

28. Geographic and Jurisdictional Risk

International operations may involve multiple jurisdictions.

Different jurisdictions may have different:

• laws;
• regulatory requirements;
• sanctions;
• payment infrastructure;
• banking systems;
• currencies;
• settlement procedures;
• compliance standards.

A transaction may be affected by requirements applicable in one or more jurisdictions.

29. Business Continuity Risk

ESCALO’s operations may depend on technology, personnel, communications and third-party infrastructure.

Events such as:

• natural disasters;
• cyber incidents;
• infrastructure failures;
• telecommunications outages;
• power failures;
• geopolitical events;
• regulatory intervention;
• third-party failures

may affect service availability.

ESCALO maintains business continuity and operational resilience measures appropriate to its activities, but continuity cannot be guaranteed in every circumstance.

30. Legal Documentation Risk

Specific ESCALO services may be subject to separate contractual agreements.

Those agreements may contain provisions concerning:

• fees;
• settlement;
• liability;
• transaction execution;
• eligibility;
• termination;
• dispute resolution;
• risk allocation.

You should review the applicable agreement carefully before entering into a contractual relationship.

Where there is a conflict between this Risk Disclosure and a specific contractual agreement, the applicable agreement will govern the relevant relationship to the extent permitted by law.

31. Tax Risk

Transactions involving currencies, financial instruments, payments or other assets may have tax implications.

Tax treatment depends on factors including:

• jurisdiction;
• legal structure;
• transaction type;
• nature of the activity;
• individual circumstances;
• applicable tax rules.

ESCALO does not provide tax advice.

You are responsible for determining your own tax obligations and obtaining independent professional advice where appropriate.

32. Accounting and Reporting Risk

Financial transactions may require appropriate accounting and reporting.

The accounting treatment of a transaction may depend on:

• transaction structure;
• jurisdiction;
• legal entity;
• accounting standards;
• currency;
• timing;
• contractual terms.

ESCALO does not guarantee that information provided through its systems will satisfy your accounting or reporting requirements.

33. Information and Communication Risk

Information provided through ESCALO’s website, systems, communications or materials may be subject to change.

You should not rely solely on general website information when making a material financial decision.

Specific transaction information should be confirmed through the applicable operational or contractual process.

34. Cyber and Credential Risk

Users are responsible for maintaining the security of their own credentials and devices.

You should:

• use appropriate security controls;
• protect passwords and authentication information;
• avoid sharing credentials;
• verify payment instructions;
• report suspected compromise promptly;
• maintain appropriate device security.

ESCALO will not normally be responsible for losses resulting solely from a user’s failure to maintain appropriate security, subject to applicable law and any contractual obligations.

35. Third-Party Service Changes

ESCALO may rely on external providers whose services, policies or availability may change.

A provider may:

• increase fees;
• change transaction limits;
• change technical requirements;
• modify APIs;
• introduce new verification procedures;
• restrict certain jurisdictions;
• suspend services;
• terminate access.

Such changes may affect operational processes or transaction availability.

36. Market Disruption

Exceptional market conditions may materially affect financial operations.

Examples may include:

• extreme volatility;
• market closures;
• liquidity shortages;
• sudden currency movements;
• geopolitical events;
• banking crises;
• regulatory intervention;
• payment network disruption.

Under such conditions, normal execution assumptions may no longer apply.

Transactions may become more expensive, slower or unavailable.

37. No Reliance on Historical Opportunities

Examples of historical spreads, market opportunities or operational outcomes are provided only to illustrate how financial markets or systems may operate.

They should not be interpreted as evidence that the same opportunity will exist in the future.

Past opportunities do not guarantee future opportunities.

38. No Investment Advice

Information published by ESCALO is not intended to constitute:

• investment advice;
• financial advice;
• trading advice;
• legal advice;
• tax advice;
• accounting advice.

ESCALO does not assess whether a particular transaction or financial activity is suitable for your individual circumstances unless expressly agreed under a separate regulated advisory service.

39. Professional Advice

Before entering into a material financial or commercial transaction, you should consider obtaining independent professional advice.

This may include advice from:

• financial advisers;
• lawyers;
• accountants;
• tax advisers;
• compliance professionals;
• other appropriately qualified professionals.

The decision to enter into a transaction remains your responsibility unless otherwise expressly agreed.

40. No Compensation Guarantee

Unless expressly stated in applicable contractual or regulatory documentation, you should not assume that your transactions, balances or losses are protected by any compensation scheme.

Whether any compensation or protection applies depends on:

• the nature of the service;
• the relevant legal entity;
• the applicable regulatory framework;
• the relevant jurisdiction;
• the contractual arrangements.

You should not assume that the Financial Services Compensation Scheme («FSCS») or any other compensation scheme applies to a particular ESCALO service unless this is expressly confirmed in the relevant documentation.

41. No Deposit Guarantee

ESCALO does not represent that funds associated with any particular service constitute protected bank deposits.

The legal and operational treatment of funds depends on the specific service, relevant financial institution, contractual structure and applicable law.

You should review the relevant service documentation before relying on any particular protection.

42. Professional and Institutional Users

Some ESCALO services may be intended primarily for businesses, professional counterparties or institutional users.

Such users may have different levels of experience, resources and risk tolerance.

Professional or institutional status does not eliminate financial or operational risk.

Users remain responsible for evaluating whether a particular service is appropriate for their circumstances.

43. Retail Customer Risk

Where a service is made available to retail customers, additional legal and regulatory requirements may apply.

The risks associated with financial products or services may be significant for retail customers, particularly where transactions involve market exposure, leverage, complex structures or volatile assets.

ESCALO will apply applicable customer protection and financial promotion requirements where relevant to the service and jurisdiction.

44. Cryptoasset Risk

Where any ESCALO activity involves cryptoassets, additional risks may apply.

These may include:

• extreme price volatility;
• loss of value;
• liquidity risk;
• custody risk;
• wallet and private-key risk;
• cyberattacks;
• fraud;
• blockchain or network failures;
• transaction irreversibility;
• regulatory uncertainty;
• sanctions exposure;
• loss of access;
• counterparty failure.

Cryptoassets can be highly volatile and may result in the loss of some or all of the money invested.

Where ESCALO communicates a financial promotion relating to qualifying cryptoassets to UK consumers, additional UK financial promotion requirements may apply. The FCA states that qualifying cryptoasset promotions must comply with the applicable financial promotions regime and that consumers should be clearly informed of the risks.

Any cryptoasset-specific communication should therefore be reviewed separately before publication.

45. High-Risk Activities

Some financial activities may carry a higher level of risk than others.

You should not assume that:

• a regulated or established platform is risk-free;
• a payment route is guaranteed to remain available;
• a market spread represents guaranteed profit;
• historical performance will continue;
• technology eliminates financial risk;
• diversification eliminates all risk.

Risk should be evaluated in the context of the specific activity.

46. Changes in Risk

The risks described in this document are not static.

Risk levels may change due to:

• market conditions;
• regulatory developments;
• technology;
• geopolitical events;
• counterparty changes;
• liquidity conditions;
• customer behaviour;
• payment infrastructure;
• new financial crime threats.

ESCALO may update its risk controls and operational procedures as circumstances change.

47. Risk Management Does Not Eliminate Risk

ESCALO uses operational, technological, compliance and risk-management controls intended to identify and mitigate relevant risks.

These may include:

• transaction monitoring;
• liquidity checks;
• market monitoring;
• counterparty assessment;
• compliance screening;
• operational controls;
• reconciliation;
• system monitoring;
• access controls;
• incident management;
• business continuity procedures.

These measures are intended to reduce risk but cannot eliminate it.

48. Responsibility of the User

You are responsible for understanding the risks relevant to your own activities.

Before using a financial service or entering into a transaction, you should consider:

• the potential for loss;
• your liquidity requirements;
• your financial position;
• your risk tolerance;
• your experience;
• applicable legal and tax requirements;
• the possibility that funds may be delayed or unavailable;
• the possibility that market conditions may change.

You should not commit funds that you cannot afford to lose where the relevant activity involves material financial risk.

49. Conflicts of Interest

Financial and payment operations may involve circumstances in which different parties have competing interests.

ESCALO maintains appropriate procedures for identifying and managing relevant conflicts of interest where applicable.

Where a conflict cannot be adequately managed, ESCALO may restrict or decline the relevant activity.

50. Third-Party Counterparty Decisions

ESCALO cannot guarantee the decisions of banks, exchanges, payment providers, marketplaces or other counterparties.

A third party may independently decide to:

• approve or reject a transaction;
• conduct additional verification;
• restrict an account;
• delay settlement;
• modify transaction limits;
• suspend services.

Such decisions may affect transaction execution or availability.

51. Operational and Human Error

Financial operations can be affected by human error.

Examples include:

• incorrect account information;
• incorrect transaction instructions;
• incorrect currency selection;
• incorrect amounts;
• communication errors;
• reconciliation errors;
• operational delays.

Appropriate controls may reduce these risks, but they cannot be eliminated completely.

52. Changes to This Risk Disclosure

ESCALO may update this Risk Disclosure from time to time.

Updates may be made to reflect:

• changes in services;
• changes in business activities;
• new risks;
• regulatory developments;
• technological developments;
• changes in market conditions;
• improvements to risk management.

The «Last updated» date indicates when this document was most recently revised.

53. Relationship With Other Documents

This Risk Disclosure should be read together with:

• Terms & Conditions / Terms of Use;
• Privacy Policy;
• Cookie Policy;
• AML / KYC Policy;
• applicable customer agreements;
• service-specific terms;
• applicable regulatory disclosures.

Where a specific service has its own risk disclosure, that document will provide additional information relevant to the service.

54. Regulatory Status

This Risk Disclosure does not constitute a representation that Finance Act Limited is authorised or regulated by the Financial Conduct Authority or any other regulator for a particular regulated activity.

Where a particular ESCALO service is subject to regulatory authorisation, registration or another regulatory status, that status will be stated in the applicable documentation.

Nothing on the ESCALO website should be interpreted as granting a regulatory status that has not been expressly confirmed.

55. No Waiver of Legal Rights

Nothing in this Risk Disclosure is intended to exclude, restrict or waive any legal right or protection that cannot lawfully be excluded, restricted or waived.

Nothing in this document limits any liability that cannot lawfully be limited or excluded.

56. Contact

For questions concerning this Risk Disclosure or the risks associated with a specific ESCALO service, contact:

Finance Act Limited trading as ESCALO

Company number: 16839569

Registered office:
58 Oswald Terrace
Sunderland
England
SR2 9RP

Email:
support@escalo.uk

57. Final Risk Statement

Financial markets, P2P transactions, currency exchange, payment operations and related financial infrastructure involve risk.

Market conditions can change rapidly. Liquidity can disappear. Transactions can be delayed or rejected. Counterparties can fail. Payment providers can restrict activity. Technology can fail. Regulations can change. Financial losses can occur.

No technology, process or risk-management framework can eliminate these risks entirely.

You should carefully consider the nature of the relevant activity, understand the applicable contractual terms and obtain independent professional advice where appropriate before entering into a material financial relationship or transaction.

If you do not understand the risks associated with a particular service or transaction, you should not proceed until you have obtained sufficient information to make an informed decision.

Finance Act Limited trading as ESCALO
Company number: 16839569
58 Oswald Terrace, Sunderland, England, SR2 9RP

support@escalo.uk

Last updated: 13 August 2026