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Risk Disclosure

Last updated: April 2026

Working draft — pending legal review

This is a substantive draft that will be reviewed and ratified by qualified Jamaican fintech counsel before launch.

1. About this disclosure

This document describes the risks of using Circl ("the platform"). You should read it in full before joining a circle, applying for a loan, or making any contribution. Your acknowledgment is recorded permanently in our audit trail.

2. What Circl is — and is not

Circl is a financial coordination protocol. It provides software that allows groups to organise rotating savings, voting, and dispute resolution. Circl is not a bank, savings institution, or licensed financial services provider. Circl does not hold your funds, guarantee any returns, or insure deposits.

3. Member-led decisions

All financial decisions in your circle (payouts, loans, rule changes, member admission, dispute outcomes) are made by member vote. Circl does not approve, reject, override, or guarantee any decision your circle makes. You are entrusting your funds and outcomes to your fellow members.

4. Specific risks of joining a circle

  • Non-payment by members: Other members may fail to contribute on schedule. This may delay your payout, reduce your eventual receipt, or cause the circle to dissolve.
  • Group dependency: Your outcome depends on the collective behaviour of the group. Early exits, defaults, or disputes can affect everyone.
  • No guaranteed returns: A savings circle is not an investment product. There is no interest, no guaranteed return, and no compensation if a circle fails.
  • No deposit insurance: Funds are not protected by deposit insurance schemes.

5. Multi-signature custody

Funds are held in a multi-signature wallet controlled by circle members, not by Circl. We never hold private keys. This means: (a) we cannot access your funds, (b) we cannot recover funds if member signatures are lost, and (c) the security of funds depends on members protecting their own keys.

6. Risks of borrowing

When the lending feature is active, members may apply for loans from circle pools. Loan terms (interest, repayment) are set by member vote, not by Circl. Failure to repay damages your trust score, may trigger removal from the circle through governance, and may have legal consequences depending on the loan agreement and jurisdiction.

7. Trust scores

Your trust score is informational. Circl never uses it to block or restrict your action. However, other circles and members can see it and may use it to decide whether to admit you. A low score may limit your ability to join certain circles.

8. Cross-border participation

Diaspora circles involve members in multiple countries and currencies. This introduces additional risks: foreign exchange fluctuations, regulatory variation by jurisdiction, settlement timing, and tax obligations that vary by country. You are responsible for understanding the obligations in your jurisdiction.

9. Platform overrides

Circl reserves a limited override capability for compliance with anti-money-laundering regulations, court orders, fraud investigations, or KYC failures. Every override is permanently audit-logged with a reason and is visible to affected members.

10. Acknowledgment

By proceeding to join a circle or apply for a loan, you confirm that you have read and understood the risks above. Your acknowledgment is recorded with a timestamp in our audit trail.

This Risk Disclosure was prepared in alignment with general financial regulatory standards and the published expectations of the Bank of Jamaica. Final wording will be ratified by qualified Jamaican counsel.