Access Denial Policy

When an address is frozen, it can no longer send or receive USDtb and all of the USDtb controlled by that address is blocked and cannot be transferred on-chain. It is not possible to freeze individual USDtb tokens. This Policy sets forth Pallas’s policy on freezing individual addresses.

1. Purpose. The purpose of this Policy is to (i) comply with relevant laws and regulations, (ii) specify under what circumstances Pallas would freeze USDtb addresses, (iii) protect the integrity of our network, and (iv) specify the consequences that may flow from this Policy.

2. Policy Statement. Pallas will not freeze individual addresses, other than in circumstances that strictly conform to the requirements set forth under Part 3, Policy Exceptions.

3. Policy Exceptions

A. Pallas will accept and consider a request for an exception to its policy against freezing where Pallas determines, in its sole discretion, that failure to grant a freeze request presents a threat to the security, integrity, or reliability of the USDtb network; for example, security breaches that compromise USDtb privileged keys (e.g., minter private key) and result in unauthorized USDtb being issued from such compromise.

B. Pallas will freeze individual addresses in order to comply with a law, regulation, or legal order from a duly recognized governmental authorized authority, court of competent jurisdiction, or other governmental authority with jurisdiction over Pallas. To the extent an order requires freezing an address with commingled funds of a platform (or similar) and Pallas reasonably determines that such freezing presents a threat to USDtb, Pallas reserves all rights to object to the order. In the event Pallas freezes any address pursuant to this Policy, Pallas shall take all appropriate action with respect to the USDtb tokens in frozen addresses in compliance with applicable legal and regulatory requirements.

4. Reversals. Pallas may un-freeze an individual address upon formal confirmation from such duly recognized governmental authorized authority, court of competent jurisdiction, or other governmental authority with jurisdiction over Pallas that the legal obligation or court order (per Part 3, Policy Exceptions above) is lifted or no longer applicable, or that a security incident no longer requires such intervention.

5. Governance. To ensure effective Pallas oversight of this Policy, Pallas will regularly report publicly the most up-to-date list of access denied addresses, amount of USDtb tokens frozen, and corresponding backing that has been segregated.