ESP-Level Compliance Enforcement

What compliance practices Exchange Service Providers may apply, and the limits of Husher's involvement

Exchange Service Providers (ESPs) are independent third parties responsible for execution and settlement. Depending on jurisdiction and risk profile, ESP compliance practices may include the following:

Practice	Description
Transaction monitoring	Automated screening of incoming funds for suspicious activity
Risk-based AML checks	Assessment of transaction risk prior to execution
Manual review or holds	Temporary pauses on high-risk or flagged transactions
Reporting obligations	Filings with relevant authorities under applicable law

Husher does not control, direct, or override ESP compliance decisions. If an ESP applies a hold or review to your transaction, that decision is made independently by the provider.

What this means in practice

Because ESPs operate under their own regulatory frameworks, a transaction may be subject to review or a hold that Husher cannot anticipate or reverse. Users should be aware that:

• ESP compliance rules vary by provider and jurisdiction

• Husher routes your swap to the selected provider but cannot override that provider's compliance controls

• Any hold or review applied by an ESP is governed by that ESP's own terms and policies

For more context on how these responsibilities are distributed, see the Compliance & Responsibility overview.