Risk Disclosure

1. Paper Trading Status

SPA is currently in paper trading mode. All performance data displayed on this website and the associated dashboard reflects simulated trading operations on a virtual portfolio of $100,000 USDC. Paper trading began on June 10, 2026.

Paper trading performance does not account for:

• Live transaction slippage and gas costs
• Liquidity impact of real-size trades on DeFi protocols
• Smart contract execution risk in live conditions
• Market impact of simultaneous rebalancing by multiple strategies
• Real-time oracle failures or delays

The target go-live date is approximately August 1, 2026, contingent on all 26 GoLiveChecker criteria being satisfied for 7+ consecutive days, followed by a mandatory manual review by the platform owner (ADR-002). Until that point, no real capital is at risk on this platform.

2. General Investment Risk Warning

Investing in crypto-assets and DeFi protocols involves significant risks, including but not limited to the complete loss of capital. Crypto-assets are highly volatile assets whose value can increase or decrease significantly over short time periods. Past performance, whether simulated or live, is not indicative of future results.

You should only allocate capital that you can afford to lose entirely. Diversification across asset classes and strategies does not eliminate risk.

3. DeFi-Specific Risks

The following risks are specific to decentralized finance protocols:

4. SPA's Risk Mitigation Framework

The following controls are built into RiskPolicy v1.0. They reduce — but do not eliminate — risk:

• TVL floor: ≥$5M per pool — excludes low-liquidity, potentially manipulable protocols
• Per-protocol cap: 40% max for Tier 1, 20% max for Tier 2 — enforces diversification
• Tier 2 total cap: ≤50% of portfolio — limits exposure to less-audited protocols
• APY bounds: 1%–30% — excludes unsustainable yield outliers
• Cash buffer: ≥5% — maintains liquidity for rebalancing
• Kill switch: Portfolio drawdown ≥5% closes all positions — non-overridable
• T3 advisory-only: Speculative strategies (Pendle YT) never open positions automatically

These controls are enforced by deterministic code in spa_core/risk/policy.py. No agent, LLM, strategy, or human operator can override an approved=False decision from the RiskPolicy gate.

5. Regulatory Status

SPA is NOT regulated by the European Securities and Markets Authority (ESMA), the European Banking Authority (EBA), the Financial Conduct Authority (FCA), the SEC, the CFTC, or any other financial regulatory authority.

SPA operates as an advisory technology platform. It does not hold client funds, execute trades on behalf of third parties, or provide regulated investment advice. During the paper trading phase, all operations are conducted on virtual funds only.

SPA is not a registered investment advisor, portfolio manager, or broker-dealer. Nothing on this website or dashboard constitutes a regulated financial service under MiCA (Regulation EU 2023/1114), MiFID II, or equivalent regulations.

6. Jurisdictional Restrictions

This service is NOT available to:

• US Persons — as defined under Regulation S of the US Securities Act of 1933. This includes US citizens (regardless of residence), US resident aliens (green card holders), US-incorporated entities, and trusts or estates with US beneficiaries.
• Residents or nationals of Russia (EU sanctions, 20th package, April 2026)
• Residents or nationals of Belarus (EU sanctions)
• Residents or nationals of Iran (OFAC comprehensive embargo)
• Residents or nationals of North Korea (OFAC comprehensive embargo)
• Residents or nationals of Cuba (OFAC comprehensive embargo)
• Residents or nationals of Syria (OFAC comprehensive embargo)
• Any person located in, incorporated in, or operating from a sanctioned jurisdiction

By accessing this website, you confirm that you are not a US Person and are not located in or subject to the laws of a restricted jurisdiction. This confirmation is a contractual representation.

7. Not Financial or Legal Advice

Nothing on this website, dashboard, API, or associated communications constitutes financial advice, investment advice, legal advice, or tax advice. The information provided is for informational and educational purposes only.

You should consult with qualified financial advisors, legal counsel, and tax professionals before making any investment decisions. SPA does not know your financial situation, investment objectives, risk tolerance, or personal circumstances.

8. Privacy and GDPR

We collect and process personal data in accordance with the EU General Data Protection Regulation (GDPR, Regulation EU 2016/679). Minimal usage data may be collected for operational purposes. No personal data is sold to third parties.

For our full privacy policy, please see Privacy Policy.

9. Changes to This Disclosure

This risk disclosure may be updated as the platform moves from paper trading to live trading, as regulatory requirements change, or as new risks are identified. Material changes will be highlighted on the homepage with a dated notice. Continued use of the platform after changes constitutes acceptance of the updated disclosure.