Risk Disclosure — Circlworld

1. Why this document exists

1.1 The principle

Circlworld operates a non-custodial coordination protocol. The protocol is designed to make community savings observable, auditable, and credentialable. The protocol does not, however, eliminate the underlying risks of community savings participation. Those risks are real and persistent and have always been part of what makes community savings work — communities accept manageable risks together in exchange for the financial discipline and collective benefit the practice produces.

The single most important commitment Circlworld makes to its members is to be honest about these risks. Hidden risk is not managed risk. The platform's design is intended to make risk observable so that members can engage with it knowingly. This document is part of that commitment.

1.2 What this document does

This Risk Disclosure sets out, in plain terms, the risks associated with use of the Circlworld platform. It is referenced from the Terms of Service and from the specific consent flows you encounter when you create your account, when you join a circle, when you become a treasurer, when you participate in lending coordination, and when you share your trust report.

When you accept any of these consent flows, you are confirming that you have read the relevant risk disclosure and understand the risks it describes. The Platform records these confirmations in your consent log, accessible at Settings → Compliance → Consent Log.

1.3 What this document does not do

This document does not replace the Terms of Service, the Privacy Notice, or any other Circlworld policy. It does not give you legal advice, financial advice, or guidance on whether participation in any specific circle, sponsorship arrangement, or lending transaction is suitable for your personal circumstances.

The decision to use the Platform, to join any circle, to act as a treasurer, to sponsor or be sponsored, or to participate in any lending coordination layer is your decision. Circlworld provides infrastructure; the financial and personal decisions remain yours.

1.4 Terminological foundation

This document uses the defined terms from the Terms of Service. Two terms are constitutive and worth restating here:

Circlworld (with capital C and no final "e") means the operating company and the protocol — the platform you use to coordinate your savings activity.

Circle (with final "e") means a specific community savings group — a rotating savings and credit association formed by members. Circles are not legal entities created by Circlworld, and Circlworld is not a party to the agreements among a circle's members.

The distinction matters throughout this document. Circlworld provides infrastructure to circles; the financial relationships within a circle are between the circle's members.

2. The fundamental risk: this is community trust, made observable

2.1 The underlying nature of pardna

Pardna, susu, ajo, chama, tanda, hui, kye, and equivalent rotating savings practices have operated globally for centuries. They work because they are governed by community trust. Members contribute on schedule because they trust each other and because failing to do so damages their standing in a community they value. Treasurers act fiduciarily because they live among the people whose money they hold.

These practices work reliably. Default rates in well-functioning ROSCAs are typically below one percent — substantially lower than U.S. credit card default rates and many forms of formal credit.

But the trust requirement is real, and it does not go away because the platform is digital. Circlworld does not replace the trust requirement; the platform makes the trust observable. A member who participates in a Circlworld circle is participating in the same kind of community-trust arrangement that pardna has always been — with the addition that the participation is now recorded, audited, and credentialable.

2.2 What "observable" does and does not do

The Platform makes circle activity observable through five mechanisms described in the Terms of Service:

The dual-attestation contribution flow (both sender and treasurer attest)
The treasurer transparency dashboard (append-only audit log visible to all members)
The dual confirmation payout mechanism (co-approver or 24-hour delay window)
The treasurer levels and graduation system (limiting the scale of any new treasurer's authority)
The optional Circle Reserve (voluntary mutual aid)

These mechanisms make misconduct visible and create reputational consequences for dishonest behaviour. They reduce the likelihood and the scale of misconduct.

They do not, however, eliminate the underlying risks. A treasurer can still be dishonest. A member can still fail to contribute. A circle can still encounter a dispute that damages the community.

The honest framing is: the Platform makes the risks manageable; it does not make them disappear.

2.3 The architectural commitment

Circlworld is a non-custodial coordination protocol. Circlworld does not hold member funds at any point. This commitment is foundational and is why the platform requires this risk disclosure: because members and treasurers transact directly through their own bank accounts and payment rails, Circlworld cannot be the backstop for misconduct in the same way a custodial fintech could be.

This is not a limitation. It is a feature. A custodial platform that fails or is hacked takes member funds with it; a non-custodial protocol that fails leaves funds where they always were — with the members and their treasurers. But the consequence is that the risks described in this document are real risks that the Platform's design mitigates but does not eliminate.

3. Risks of using the Platform generally

3.1 Technology risks

The Platform is software, and software can fail. Specifically:

The Platform may experience outages that prevent you from accessing your account or recording contributions when you need to.
The Platform may contain bugs that affect features, displays, or calculations. Where a bug affects you, the Platform's audit log preserves the underlying events and the bug's correction is appended as a new entry rather than silently rewriting history.
The Platform's mobile applications may be unavailable on your device, may be unsupported on older operating system versions, or may behave differently from the web interface.
Internet connectivity in your location may affect your ability to use the Platform reliably.

What Circlworld does about this: Circlworld operates with redundancy, monitoring, and incident response procedures appropriate to a platform handling community-savings infrastructure. Circlworld maintains a status page (status.circlworld.com) where current Platform availability is reported. Critical bugs affecting financial records are addressed with high priority and any necessary corrections are documented in the audit log of affected circles.

What you should do: Maintain access to your contribution records outside the Platform (the Platform provides a data export feature for this purpose). If the Platform is unavailable when you need to attest a contribution, document the contribution by other means (transfer receipt, text message to treasurer, etc.) and attest in the Platform when it becomes available.

3.2 Account security risks

Your Circlworld account is protected by your password, your phone number, and (where you have enabled it) two-factor authentication. If your account is compromised:

Someone other than you may be able to make attestations in your name (potentially damaging your trust profile or causing financial loss to others who relied on the attestations)
Someone other than you may be able to view your participation records and trust profile
Someone other than you may share your trust report with parties you have not chosen

What Circlworld does about this: Two-factor authentication is mandatory at Tier 1 KYC and above. At Pro tier and above, TOTP authentication is required. At Business tier, hardware authentication keys are required. Sensitive actions (report generation, lender access approval, residence change, payment method update) require step-up authentication within 5 minutes. Recovery flows include cooldown periods (24 hours at Free tier, 72 hours plus KYC re-step-up at Pro tier, 7 days plus video verification at Business tier).

What you should do: Use a strong, unique password for your Circlworld account. Enable two-factor authentication. Use authenticator apps rather than SMS where possible. Never share your account credentials. If you believe your account has been compromised, contact security@circlworld.com immediately and use the protective steps in your Settings Panel.

3.3 Identity verification risks

To use the Services, you complete identity verification through a third-party provider (Onfido, Smile ID, Persona, or Sumsub, depending on your residence and document type). The verification process involves:

Uploading a government-issued identification document
Taking a live photograph for biometric matching
(For higher tiers) Address verification

This data is held by the identity verification provider under its own compliance regime. Circlworld receives the verification result and minimum-necessary metadata but does not store the raw documents or biometrics.

The risks:

The provider may experience a data breach that exposes your identification documents and biometric data
The provider may incorrectly reject your verification (false negative) — your account access is restricted until you successfully reverify
The provider may incorrectly accept verification using a stolen identity (false positive) — Circlworld monitors for patterns suggesting this and may suspend accounts for compliance review

What Circlworld does about this: Circlworld engages identity verification providers that are themselves regulated for data protection in their operating jurisdictions and that have established track records. Provider contracts include data processing terms aligned with UK GDPR Article 28 and equivalent Jamaican provisions. If a provider experiences a breach affecting your data, Circlworld will notify you within the timelines required by applicable law.

What you should do: Use your real identity. Provide accurate information. If verification fails and the failure was caused by image quality, document age, or similar fixable issues, retry. If verification fails repeatedly and you believe an error has occurred, contact compliance@circlworld.com.

You may choose to share your trust report with lenders, employers, landlords, or other recipients. When you share:

The recipient sees the information contained in the report at the moment of sharing
The recipient retains that information unless they delete it
The recipient may use the information in ways you did not anticipate (for example, denying you credit on grounds you cannot challenge in advance)
You can revoke the report at any time, but the recipient retains any information they already viewed

What Circlworld does about this: Every access to your trust report is logged and visible to you in your Settings Panel. Revocation is one-tap and effective immediately. The Lender API and partner integration require explicit consent for each access; you can withdraw consent at any time. Circlworld does not share your trust report with any recipient you have not chosen.

What you should do: Share your trust report only with recipients you have evaluated and chosen. Read any privacy notice the recipient provides about how they will use the information. If a recipient declines an application based in part on your trust report, you have rights under applicable consumer credit law in their jurisdiction (UK Consumer Credit Act 1974, Equality Act 2010, equivalent Jamaican provisions) to understand the basis for the decision and to challenge it.

3.5 Platform availability risks

Circlworld is committed to operating the Platform reliably for the foreseeable future. However:

Circlworld is a private company. Like any private company, Circlworld could in principle face financial difficulty, regulatory action, or other circumstances affecting its operations.
The Platform depends on third-party infrastructure providers (cloud hosting, email infrastructure, identity verification providers). Failure of these providers could affect the Platform.
Regulatory changes could affect the services Circlworld can offer in a particular jurisdiction.

What Circlworld does about this: Appendix D of the Circlworld Protocol white paper describes Circlworld's continuity and exit framework. The key points: member funds are not at risk in any Platform-failure scenario because the Platform never custodied them. Trust credentials remain cryptographically verifiable using open standards even if Circlworld ceases operations. Member rights to data export and rectification are preserved through any operating company transition.

What you should do: Take periodic data exports of your account (Settings → Compliance → Data Export). Maintain external records of your contributions and trust profile, especially for circles where the financial stakes are significant.

4. Risks of joining a circle

4.1 The member-to-member custody model (Category A default)

When you join a Category A circle operating on the member-to-member custody model — which is most circles operating now — each member contributes through their own bank account directly to whichever member is due that round's payout. The treasurer governs the rotation and records each contribution but does NOT hold funds in their own account. Funds are held by the members themselves, in a dedicated Circle account, or by a partner institution — never by Circlworld and never by the Treasurer's personal account. This is the foundational risk allocation to understand.

The risks are:

Member non-payment. A contributing member could fail to send their contribution to the receiving member on schedule. The treasurer's role is to record the failure and trigger the dispute / hardship procedures in the Bylaws.
Coordination failure. A treasurer could record a contribution incorrectly, miss a rotation step, or fail to confirm a payout. The platform's audit trail and dual-confirmation flow are the structural protections.
Treasurer incapacity. A treasurer could die, become seriously ill, or face circumstances that prevent them from coordinating the rotation. The Bylaws provide a successor-election procedure.
Disputes over routing details. A member could send a contribution to incorrect bank details. The treasurer's published routing record and the platform's tap-to-copy fields are the protections against this risk.

Circlworld does not insure, guarantee, or otherwise underwrite these risks. The risks are borne by the members of the circle, including you, in the same way they have always been borne by members of any traditional pardna.

What Circlworld does about this:

Treasurer levels and graduation. New treasurers are limited to Level 1: one circle of up to 6 members. Members joining a Level 1 treasurer's circle are explicitly informed of the treasurer's new status. Higher levels (more circles, larger circles) require completed cycles, peer endorsements, and dispute-free service. This limits the blast radius of any new treasurer's potential mistakes.
Treasurer transparency dashboard. Every event affecting the circle is recorded in an append-only audit log visible in real time to all members. The treasurer cannot edit or delete past entries; corrections are appended as new entries that reference the original. Members see the complete history.
Dual confirmation payout. Payouts require treasurer initiation plus either a co-approver's independent approval or a 24-hour delay window during which any circle member can pause for review.
Dispute resolution. If a treasurer fails to deliver a payout or other expected outcome, the affected member can open a dispute through the Platform. Disputes follow a structured resolution process that involves the circle and produces a recorded outcome.
Trust profile consequences. A treasurer whose conduct results in dispute resolutions against them accumulates a record on their trust profile that materially affects their future ability to serve as treasurer or to access the broader benefits of the Platform.

These mitigations reduce the likelihood and the scale of treasurer misconduct. They do not eliminate it. A determined dishonest treasurer can still defraud their circle in the same ways they could in a traditional pardna. The Platform makes such conduct visible and consequential; it does not make it impossible.

What you should do:

Before joining a treasurer-led circle, review the treasurer's performance metrics on their trust profile (visible in the join flow): treasurer level, completed cycles, on-time payout rate, peer endorsements, disputes filed against them.
For your first circles, consider joining circles led by treasurers you know personally or who have been endorsed by members you know.
Do not contribute amounts to a single circle that you cannot afford to lose if the treasurer turns out to be dishonest.
Participate in the audit log review — open the transparency dashboard from time to time and verify that the recorded contributions match what you sent.
Where the circle has elected a co-approver, take that role seriously if you are elected. Where the circle uses the 24-hour delay window, monitor scheduled payouts and use the pause-for-review mechanism if anything seems wrong.

4.2 The escrow-mediated custody model (Phase 2, future)

When Phase 2 of the custody framework becomes available, circles may elect to use a regulated third-party escrow service to hold contributed funds between collection and payout. Under this model, the escrow service (not the treasurer) is the custodian. The treasurer custody risks described in Clause 4.1 are substantially reduced because the treasurer no longer holds the funds.

However, escrow-mediated custody introduces different risks:

Escrow service failure. A regulated escrow service is more reliable than an individual treasurer in most respects but is not invulnerable. Regulated escrow services operate under their own regulatory supervision in their jurisdiction; that supervision provides protection but not absolute guarantee.
Escrow service fees. Regulated escrow service involves fees that the circle pays. These fees may be modest but they are not zero.
Operational complexity. The escrow flow involves more steps than the direct member-to-treasurer flow. Members must direct their contributions to the escrow service rather than to the treasurer.

What Circlworld does about this: Circlworld will partner only with escrow services that are appropriately regulated in their jurisdiction and that meet Circlworld's vendor risk management standards. The specific provider and the terms applicable to escrow-mediated circles will be documented in additional disclosures published at the time Phase 2 launches.

What you should do: When Phase 2 launches, evaluate whether the escrow-mediated model is appropriate for your circle. The decision depends on factors including: the level of trust the circle's members have in their treasurer, the scale of contributions, the cross-border or cross-community nature of the circle, and the fee tolerance of the membership.

4.3 Member non-performance

Even with a reliable treasurer, a circle depends on every member contributing on schedule. If a member fails to contribute:

The treasurer may need to advance funds to maintain the rotation (if the treasurer chooses to do so)
The payouts scheduled for later in the cycle may be reduced or delayed
The circle may need to vote to remove the non-performing member or to wind down the cycle

What Circlworld does about this:

KYC verification of all members. Every member of a Tier 2 circle is identity-verified; no anonymous joining.
Contribution reminders. The Platform sends reminders before contribution due dates and follows up on late attestations.
Late attestation pathway. A member who missed a deadline can late-attest, with their on-time rate updated accordingly. This encourages members to record actual behaviour rather than disappear after a missed deadline.
Trust profile consequences. A member whose contributions are repeatedly late or missed accumulates a record on their trust profile that affects their future ability to join circles, access cross-border features, or receive credit through the Lender API.
Optional Circle Reserve. A circle electing to maintain a mutual-aid reserve (Clause 4.5 below) can use the reserve to cover short-term gaps from member non-performance.

What you should do: Before joining a circle, confirm that the contribution amount and schedule are sustainable for your circumstances. Do not commit to amounts you may not be able to deliver. If your circumstances change during a cycle, communicate with your treasurer and the circle as early as possible.

4.4 Disputes within a circle

Circles encounter disputes. A treasurer and a member may disagree about whether a contribution was received. Members may disagree about a governance decision. A late contribution may be contested between the sender and the treasurer.

What Circlworld does about this: The dispute flow described in the Terms of Service provides a structured process: both parties submit attestations and (where required) supporting evidence; the treasurer mediates where appropriate; the circle may be brought in for collective resolution where the dispute is structural rather than between two specific parties; the outcome is recorded in the audit log and (where appropriate) in the trust profiles of the parties.

What you should do: Participate constructively in dispute resolution. Keep evidence of your transactions (transfer receipts, text exchanges with the treasurer, etc.). Engage with the dispute process rather than withdrawing — the Platform's dispute mediation is more likely to produce a fair outcome than walking away.

4.5 The optional Circle Reserve

A circle may elect to maintain a Circle Reserve — an additional voluntary contribution to a pool that the circle can draw on by vote for member emergencies, late-contribution coverage, or community projects within the circle.

Important framing: The Circle Reserve is mutual aid, not insurance. There is no guarantee of coverage for any individual member's needs; drawdowns are by circle vote. The Reserve is held within the circle's existing custodial arrangement (with the treasurer in Phase 1, with the escrow service in Phase 2) and shares those custody risks.

What Circlworld does about this: The Reserve operates through the Platform's voting infrastructure with full audit logging. Every contribution to the Reserve, every drawdown vote, every disbursement is recorded.

What you should do: Before contributing to a Circle Reserve, understand that you are making a mutual-aid commitment, not paying for insurance. You may benefit from the Reserve if the circle votes to support you; you have no entitlement to a specific outcome.

5. Risks of acting as a treasurer

If you act as a treasurer of a circle, the responsibilities and risks of the role apply to you in addition to the general risks of circle membership. This is the most significant role in any circle and is what the Platform's treasurer levels system specifically governs.

5.1 Fiduciary responsibility to circle members

As a treasurer in the member-to-member custody model (Category A default), you do not hold member funds in your personal account. Your fiduciary duty runs to the circle members in respect of the COORDINATION and the RECORD — the rotation, the contribution attestation, the dispute triage, and the audit trail. Specifically:

You must publish accurate routing details to members so contributions reach the correct receiving member each round
You must record each contribution promptly and accurately on the platform
You must confirm each payout and record any failures
You must respond to member enquiries about contributions and disbursements promptly
You must mediate disputes fairly
You must NEVER take temporary custody of cycle contributions in your personal account, even for convenience

Failure to discharge these responsibilities can result in:

Civil liability to circle members under contract law and (in some jurisdictions) under specific fiduciary frameworks
Criminal liability in cases of dishonest misappropriation (theft, fraud) under the laws of your jurisdiction
Recording of the failure in your trust profile, affecting your future ability to serve as a treasurer or access Platform features
Suspension or termination of your Circlworld account under the Acceptable Use Policy

What Circlworld does about this: The Platform requires treasurer fiduciary acknowledgment at circle creation (you affirmatively acknowledge that the fiduciary responsibility runs to the other members, not to Circlworld). The Platform's audit log makes your conduct as treasurer observable to all members in real time. The dual confirmation payout mechanism reduces the scope for unilateral mistakes.

What you should do: Take the role seriously. Use a separate bank account or sub-account for circle funds. Disburse payouts on schedule. If you are facing personal financial difficulty that affects your ability to discharge the role, communicate with your circle and arrange a handover before any payout becomes affected. Maintain your own records of every contribution received and payout disbursed.

5.2 Tax considerations

In some jurisdictions, the treasurer's handling of contributed funds may have tax implications. Specifically:

The treasurer is not the beneficial owner of the contributed funds (the funds belong to the circle's members until disbursed), but the funds may transit through the treasurer's bank account in ways that affect their bank statements
Some jurisdictions treat community savings activity in specific ways under tax law; you should understand the position in yours
Where the treasurer earns any fee for the role (uncommon in traditional pardna; sometimes applicable in Business-tier treasurer-as-a-service arrangements), the fee is income to the treasurer

What Circlworld does about this: Circlworld provides general information about the tax treatment of community savings in the AI treasurer guidance, but Circlworld does not give tax advice.

What you should do: If you are uncertain about the tax implications of acting as a treasurer in your jurisdiction, consult a qualified tax advisor. In Jamaica, this typically means a chartered accountant; in the United Kingdom, a chartered accountant or tax adviser.

5.3 AML/CFT obligations

As a treasurer, you may receive funds from multiple members and disburse to multiple members through your own bank account. This activity could in principle be of interest under anti-money-laundering rules in your jurisdiction.

What Circlworld does about this: All circle members are KYC-verified at the level appropriate to the activity. The Platform's audit log provides a record of every contribution and disbursement, available to you and to your bank if requested. Continuous sanctions monitoring is in place.

What you should do: If your bank inquires about the pattern of deposits and withdrawals on your account, be prepared to explain the circle's operation and to provide your Circlworld audit log as supporting evidence. Do not conceal the circle activity from your bank — banks understand pardna and pardna-equivalent practices and are unlikely to be concerned, but unexplained transaction patterns can trigger their own AML processes.

5.4 Capacity limits

You may serve as treasurer at the level appropriate to your treasurer level. Level 1 permits one circle of up to 6 members; Level 2, three circles of up to 12 members; Level 3, ten circles of any size; Level 4, unlimited (Business tier only).

Why these limits exist: They limit the blast radius of any single treasurer's potential failure and protect both you and your circles from over-commitment.

What you should do: Stay within your level's limits. The Platform will not allow you to create a circle that exceeds them. As your record builds, you graduate to higher levels automatically; do not seek to circumvent the limits.

6. Risks of sponsorship

Sponsorship is a Pro-tier feature that allows one member to pay for another member's contributions to a circle.

If you sponsor another member:

Your payment method (card, bank account) will be charged on the contribution schedule. If your payment method fails, the sponsorship may be interrupted, potentially leaving the recipient with an unmet contribution obligation.
The recipient retains the participation rights and the payout from the circle. You do not receive the recipient's payout.
The recipient may end the sponsorship at any time, with effect on future contributions.
The recipient's trust profile (not yours) accumulates the trust score from the sponsored participation; you accumulate a separate supporter reputation.
The sponsorship is between you and the recipient; if the circle encounters difficulty, you are exposed to the contribution costs you have committed but cannot directly affect the circle's outcome.

What Circlworld does about this: Sponsorship requires Tier 2 KYC on both parties. Sponsorship is revocable by either party. Each charge is receipted to the sponsor.

What you should do: Sponsor only people you know and trust. Be honest with yourself about whether the sponsorship is something you can sustain across the full cycle. If your circumstances change, end the sponsorship; don't let payment failures cause harm to the recipient.

6.2 Risks for the recipient

If you accept sponsorship from another member:

The sponsor may end the sponsorship at any time. If the sponsorship ends mid-cycle, you become responsible for covering future contributions yourself (or finding a replacement sponsor, or exiting the circle in accordance with the circle's exit procedures).
The sponsorship arrangement is visible to the other circle members in the audit log (the fact of sponsorship, not necessarily the financial terms). This may affect your standing in the circle in ways you should consider.
The sponsor's expectations of you may not be financial but social — sponsorship within community contexts often carries reciprocal obligations that the Platform does not enforce but that you may experience.

What Circlworld does about this: Sponsorship terms are recorded transparently. Either party can end the sponsorship.

What you should do: Accept sponsorship from people you trust. Be clear with yourself and with the sponsor about expectations. Maintain your own capacity to contribute if the sponsorship ends.

7. Risks of lending coordination

The Platform coordinates lending activity through three layers: the Local Lending Pool (LLP), the Central Lending Pool (CLP), and the third-party regulated lender pathway. Each has distinct risks.

7.1 Risks of the Local Lending Pool

LLP transactions are community-internal mutual aid lending within a single circle.

Risks for the borrower:

The loan is a contract between you and the contributing members of your circle. Failure to repay damages your relationship with those members and your trust profile across the Platform.
The loan terms are governed by the standard-form documentation Circlworld provides plus any specific terms the circle has voted to apply. You should understand both before accepting funds.

Risks for the lender (contributing members):

The borrower may default. Circlworld is not a party to the loan and does not guarantee repayment.
Recovery, in the event of default, is a matter for the circle to manage among its members (typically through dispute resolution).

What Circlworld does about this: The standard-form documentation, the voting infrastructure, the trust-profile visibility, and the dispute mechanism are all in place. Circlworld is not a party to the loan but provides the coordination infrastructure.

What you should do:

As a borrower: borrow only what you can realistically repay. Be transparent about your circumstances. Honour the agreed schedule.
As a lender: lend only what you can afford to lose if the borrower defaults. Read the borrower's trust profile before voting to support the loan. Understand that you are extending community mutual aid, not making a guaranteed-return investment.

7.2 Risks of the Central Lending Pool

CLP transactions are cross-circle peer lending coordinated through the Platform.

Risks for the borrowing circle:

The terms of the loan are governed by the standard-form documentation Circlworld provides plus the specific terms the lending circles have voted to apply. Your circle is collectively responsible for repayment.
Default damages the trust profile of the borrowing circle, with cascading consequences for individual members.

Risks for the lending circles:

The borrowing circle may default. Circlworld is not a party to the loan; the loan is a contract between the borrowing circle and the lending circles.
Recovery is a matter for the lending circles to pursue against the borrowing circle, with assistance from the Platform's dispute mediation.

What Circlworld does about this: Trust-report-based transparency between borrowing and lending circles. Standard-form documentation appropriate to the jurisdiction. Voting infrastructure for both sides. Dispute mediation for repayment issues.

What you should do:

As a member of a borrowing circle: participate actively in the decision to borrow. Understand the obligation your circle is collectively taking on. If your circle defaults, your individual trust profile is affected.
As a member of a lending circle: participate actively in the vote to extend support. Read the borrowing circle's trust report and the trust reports of its individual members where relevant. Understand that the contribution is community mutual aid at scale, not a guaranteed-return investment.

7.3 Risks of the third-party regulated lender pathway

If you are introduced through the Platform to a regulated lending partner:

The loan, if extended, is a contract between you and the lending partner. Circlworld is not a party to the loan.
The lending partner is regulated in its jurisdiction and bears the regulatory burden of the credit decision. Circlworld's role is limited to the introduction and the consent-bridged sharing of your trust report.
The lending partner's terms (interest rate, fees, repayment schedule, collateral requirements where applicable) are theirs, not Circlworld's. Circlworld does not warrant the terms.
Default of the loan has the consequences applicable under the lending partner's terms and the consumer credit law of their jurisdiction.

What Circlworld does about this: Lending partners are subject to Circlworld's vendor due diligence and contractual standards. The introduction includes consent-bridged sharing of your trust report; the lender's processing is governed by their own privacy notice provided to you.

What you should do: Treat the lending partner as you would any regulated lender — read their terms, understand the costs, consider whether the credit is suitable for your circumstances. If you have a complaint about the lender, the lender's own complaints process and your right to escalate to the relevant supervisory authority (FCA Financial Ombudsman in the UK, Bank of Jamaica supervision in Jamaica) applies.

8. Cross-border risks

Cross-border activity (sponsoring across jurisdictions, participating in circles whose primary jurisdiction differs from your residence) introduces additional risks.

8.1 Currency and exchange rate risks

When funds move between currencies, exchange rates vary. The amount the treasurer receives may differ from the amount the sender intended to send, due to:

The exchange rate at the time of transfer
The transfer fees charged by the rail (Wise, Revolut, Western Union, MoneyGram, Remitly, etc.)
The receiving bank's intermediary fees

What Circlworld does about this: The Platform allows the sender to attest the amount sent and the rail used; the treasurer attests the amount received. Where amounts diverge significantly, the dispute flow opens.

What you should do: Understand the rail you are using and its fee and exchange rate structure. Communicate with your treasurer about the expected amount and any conversion expected.

8.2 Regulatory variation

Different jurisdictions regulate cross-border money movement differently. Your contribution may be subject to:

AML/KYC requirements applied by the payment rail
Reporting thresholds (above certain amounts, the rail may apply additional scrutiny)
Specific country-pair restrictions where applicable

What Circlworld does about this: The Platform's cross-border tier (Pro) requires Tier 2 KYC on both parties, which most rails will recognise. Continuous monitoring catches sanctions-related issues.

What you should do: Use established, reputable rails. Be aware of the legitimate sources of your funds and be prepared to document them if the rail asks. If a rail declines your transaction, consider whether an alternative is available or whether you need to provide additional documentation.

8.3 Tax considerations across borders

Cross-border money movement may have tax implications in either jurisdiction. Sponsorship in particular is a gift or transfer that, depending on amount and frequency, may attract reporting obligations in either jurisdiction.

What Circlworld does about this: Circlworld does not give tax advice and does not report your activity to tax authorities except as required by law (which is rarely the case for the kinds of amounts involved in typical pardna activity).

What you should do: If your cross-border activity is substantial or sustained, consult a qualified tax advisor in the relevant jurisdiction(s).

9. What Circlworld is not liable for

For clarity, the following matters are not within Circlworld's liability under the Terms of Service:

(a) The conduct of any other member, treasurer, sponsor, co-approver, or lending counterparty.

(b) The conduct or solvency of any payment rail (Wise, Revolut, Western Union, MoneyGram, Remitly, JN Money Services, bank transfer providers, card processors), identity verification provider, hosting provider, or other third party referenced in this disclosure.

(c) The accuracy of trust scores or trust profiles as a predictor of any specific outcome — trust scores describe past behaviour and do not guarantee future behaviour.

(d) The decisions of any banking partner, lending partner, employer, landlord, or other recipient with whom you have chosen to share your trust report.

(e) The terms or outcome of any credit, sponsorship, insurance, or other arrangement entered into through the Platform's introduction or coordination.

(f) Currency exchange rates, transfer fees, or the operations of any cross-border money movement service.

(g) Changes in tax, regulatory, or other legal frameworks that affect the value or character of activity on the Platform.

The above is not exhaustive. The Terms of Service Clause 15 sets out Circlworld's overall limitation of liability.

10. Where to get help

If you have concerns about specific risks or specific situations:

General questions: hello@circlworld.com
Compliance and regulatory questions: compliance@circlworld.com
Data protection questions: dpo@circlworld.com
Account security: security@circlworld.com
Disputes: open through the Platform's in-circle dispute mechanism, or contact complaints@circlworld.com if the dispute concerns Circlworld rather than another member
Accessibility issues: accessibility@circlworld.com

If you believe you have suffered loss due to misconduct by another Member, a Treasurer, or a third party referenced in this disclosure, your remedies depend on the nature of the loss:

For loss caused by another Member or Treasurer, your remedies are typically against that person under contract law, and (in cases of dishonest misappropriation) potentially through criminal proceedings under the laws of your jurisdiction. The Platform's audit log and trust profile records may be evidence in such proceedings.
For loss caused by a payment rail, identity verification provider, or other third party, your remedies are typically against that provider under their own terms and the consumer protection law of the relevant jurisdiction.
For loss caused by Circlworld itself, your remedies are governed by the Terms of Service and the laws of the applicable jurisdiction. The Complaints Handling Policy describes the escalation procedure.

Schedule 1 — Acknowledgment Points

The Platform requires you to acknowledge specific portions of this Risk Disclosure at specific points in your account lifecycle. The acknowledgments are recorded in your consent log.

| Acknowledgment | When required | Clauses referenced | |----------------|---------------|---------------------| | Account creation acknowledgment | At signup | Clauses 1, 2, 3 (general risks) | | Member-to-member circle joining acknowledgment | When joining a Phase 1 circle | Clauses 4.1, 4.3, 4.4 | | Escrow-mediated circle joining acknowledgment | When joining a Phase 2 circle (future) | Clause 4.2 | | Treasurer fiduciary acknowledgment | At circle creation as treasurer | Clause 5 | | Sponsorship acknowledgment (sponsor side) | At offering sponsorship | Clause 6.1 | | Sponsorship acknowledgment (recipient side) | At accepting sponsorship | Clause 6.2 | | LLP acknowledgment | At entering an LLP transaction | Clause 7.1 | | CLP acknowledgment | At entering a CLP transaction | Clause 7.2 | | Third-party lender acknowledgment | At engaging with a regulated lending partner | Clause 7.3 | | Cross-border acknowledgment | At first cross-border action | Clause 8 | | Custody model migration acknowledgment | When migrating a circle from Phase 1 to Phase 2 (future) | Clauses 4.1, 4.2 |

The acknowledgment language presented at each point is derived from the relevant clauses in plain summary form. Your acknowledgment confirms that you have read the relevant clauses and understand the risks they describe.

Schedule 2 — Items Pending Finalisation

The following items in this Risk Disclosure are placeholders and must be resolved before publication:

| Item | Location | Pending Decision | |------|----------|------------------| | Effective date | Header | Set at publication | | Last updated date | Header | Set at publication | | Version number | Header | Confirm 1.0 at publication | | Status page URL | Clause 3.1 | Confirm status.circlworld.com is live | | Identity verification provider list | Clause 3.3 | Confirm Onfido, Smile ID, Persona, Sumsub agreements in place | | Escrow provider details (when applicable) | Clause 4.2 | Defer until Phase 2 partner selected | | Treasurer level capacity numbers | Clause 5.4 | Confirm 1/3/10/unlimited still current | | Recipient consumer credit law references | Clause 3.4 | Verify current statute references | | Acknowledgment language for each point in Schedule 1 | Schedule 1 | Confirm language matches Platform implementation |

This schedule should be reviewed by qualified counsel in each jurisdiction and any additional items added before publication.

End of Risk Disclosure draft.

Document prepared: May 2026 Prepared by: Drafted with AI assistance; requires professional legal review in both jurisdictions before publication Next step: Review by Drew St'Clair in dual capacity as Barrister of England & Wales and Attorney-at-Law of Jamaica; subsequent review by external counsel; verification that acknowledgment language matches the Platform's actual consent flow implementation