Applicant ; Nischal Shetty; Affidavit ; 1st ; 27.08.

2024

IN THE GENERAL DIVISION OF THE HIGH COURT OF THE REPUBLIC OF

SINGAPORE

HC/OA /2024
In the matter of Section 64 of the Insolvency,
Restructuring and Dissolution Act 2018 (No. 40
of 2018)

And

In the matter of ZETTAI PTE. LTD.

(Singapore UEN No. 201900774K)

ZETTAI PTE. LTD.

(Singapore UEN No. 201900774K)

… Applicant

AFFIDAVIT

Name of maker: Nischal Shetty (Government of India, Income Tax Department,

Permanent Account Number BNTPS2268H)
Address: c/o 20 Bendemeer Road #03-12 BS Bendemeer Centre,
Singapore 339914
Occupation: Director
Description: Applicant

I, NISCHAL SHETTY (Government of India, Income Tax Department,

Permanent Account Number BNTPS2268H), do solemnly and sincerely affirm and say

as follows:

I. INTRODUCTION

1. I am a director of Zettai Pte Ltd (“Zettai”) and I am duly authorised to make this

affidavit.

2. Unless otherwise stated, all matters stated herein are within my personal

knowledge and are true. Insofar as matters deposed herein are not within my
 2

personal knowledge, they are based on documents within my possession

which are true to the best of my knowledge, information and belief.

3. I make this affidavit in support of Zettai’s application pursuant to section 64 of

the Insolvency, Restructuring and Dissolution Act 2018 (the “IRDA”) for, among

others, the following orders:-

(a) For a period of six (6) months from the date of this application or until

further order:

(i) No resolution shall be passed for a winding up of Zettai;

(ii) No proceeding, whether before a court, arbitral tribunal or

administrative agency, and whether current, pending or

threatened against Zettai, shall be commenced or continued

against Zettai, except with the leave of the Court and subject to

such terms as the Court imposes. This order shall not apply to

any proceeding commenced by Zettai, or to any

counterclaim(s) made against Zettai in any proceeding

commenced by Zettai prior to 23 August 2024; and

(iii) No execution, distress or other legal process may be

commenced, continued or levied against any property of Zettai,

except with the leave of the Court and subject to such terms as

the Court imposes.

(the “Moratorium Order”)

 4

The above-listed shareholders shall hereinafter be collectively referred to as

the “Founders”.

7. Zettai has 2 directors. Apart from myself, Paripooranam d/o V Chettiar is the

only other director of Zettai. She is Zettai’s local resident director.

8. A copy of the Accounting and Corporate Regulatory Authority (“ACRA”)

business profile search of Zettai conducted on 26 August 2024 is exhibited at

“NCS-1, Tab 1”.

The WazirX Platform (the “Platform”)

9. The Platform is a leading cryptocurrency exchange in India with over 16 million

registered users, of whom ~4.4 million users have cryptocurrency balances in

their accounts maintained with the Platform.1 The Platform offers services for

users to buy, sell, and trade cryptocurrencies, including Bitcoin, Ethereum,

Ripple, and many more. The Platform can be accessed via mobile phone apps

or via website browser.2

10. The Platform was owned by Zettai and operated by Zanmai India from May

2019 until November 2019. Zanmai India is a company incorporated and

existing under the laws of the Republic of India. Zanmai India was incorporated

on 21 December 2017 and is wholly owned by Zettai. As at the date of this

affidavit, Zanmai India’s directors are Sameer Hanuman Mhatre, Tushar Patel

and Muthuswamy Iyer and me. A copy of Zanmai India’s Ministry of Corporate

1 https://wazirx.com/blog/about/
2 https://wazirx.com/
 5

Affairs master data extracted on 25 January 2024 is exhibited at “NCS-1, Tab

2”.

11. In around 2019, a group of entities known as “Binance” entered into

negotiations with the Founders to acquire the Platform. Binance’s website

claims that Binance is the “world’s leading blockchain ecosystem, with a

product suite that includes the largest digital asset exchange”.3

12. The negotiations were successful. On 21 November 2019, Binance announced

on its website that it has acquired the Platform, in a blog post titled “Binance

Acquires India’s Leading Digital Asset Platform WazirX to Launch Multiple Fiat-

to-Crypto Gateways” dated 21 November 2019.4 A copy of the aforesaid blog

post is exhibited hereto at “NCS-1, Tab 3”, an extract of which is below:

13. As the existence of the agreements associated with Binance’s acquisition of

the Platform (“Transfer Transaction”) and its terms are strictly confidential, I

am unable to go into any detail on the structure or terms of the Transfer

Transaction in this affidavit.

14. From November 2019, Zettai delivered control of all cryptocurrency wallets (the

“WazirX Wallets”) and cryptographic tokens relating to the Platform to

3 https://www.binance.com/en/about (accessed on 15 August 2024)

4 https://www.binance.com/en/blog/all/binance-acquires-indias-leading-digital-asset-platform-wazirx-
to-launch-multiple-fiattocrypto-gateways-404105749895733248 (accessed on 15 August 2024)
 6

Binance. Ownership and control over the Platform were also transferred to

Binance.

15. Notwithstanding the transfer of ownership and control of the Platform to

Binance, Zanmai India continued to play a role in the operation of the Platform.

Zanmai India operated INR-related services on the Platform, while Binance

operated the cryptocurrency-related services on the Platform. A copy of the

Platform’s user agreement5 is exhibited at “NCS-1, Tab 4”.

16. However, in or around August 2022, Binance started to publicly distance itself

from the Platform and disavow its ownership of and control over the Platform.

On 5 August 2022, Binance issued a message regarding the Transfer

Transaction on their blog,6 a screenshot of which is below:

17. Mr Zhao (the CEO of Binance at that time) also posted a statement that said

that “Binance does not own any equity in Zanmai Labs”,7 a screenshot of which

is below:

5 The terms of use may also be found on the Platform’s website: https://wazirx.com/
6
https://www.binance.com/en/blog/all/binance-acquires-indias-leading-digital-asset-platform-
wazirx-to-launch-multiple-fiattocrypto-gateways-404105749895733248
7
https://x.com/cz binance/status/1555578415901802507 (accessed on 15 August 2024)
 7

18. Binance was seeking to back out from the Transfer Transaction. The dispute

over the ownership of the Platform was publicised on social media platforms

and news outlets.8 The dispute is ongoing.

19. The dispute intensified when, among other things, Binance informed the

Founders, and publicly stated, that it would terminate the wallets that were used

to hold the Platform’s digital assets. This was notwithstanding Mr Zhao’s earlier

statement that Binance would not take drastic action such as to “disable WazirX

wallets” or “hurt users”. A screenshot of the aforesaid statement on Twitter is

set out below.9

8
See for example: https://economictimes.indiatimes.com/tech/startups/binance-wazirx-ownership-
fallout-sees-founders-exchange-claims-and-counter-claims/articleshow/93396554.cms?from=mdr
(accessed on 15 August 2024); https://www.coindesk.com/business/2023/01/27/wazirx-says-
binance-lied-about-ownership-as-dispute-about-indias-largest-exchange-escalates/ (accessed on
19 August 2024)
9 Screenshot obtained from https://news.bitcoin.com/binance-ceo-warns-we-could-disable-wazirx-

wallets-advises-investors-to-transfer-funds-to-binance/ (accessed on 15 August 2024).

 8

20. On or around 3 February 2023, Binance publicly announced its decision to

cease providing services in relation to the Platform. An excerpt from Binance’s

announcement is below:10

21. While the Founders were of the view that Binance had no basis for their

conduct, the Founders wanted to ensure the continuity of the Platform and to

safeguard the interests of the Platform’s users. Accordingly, Zettai was

compelled to accept (albeit under protest) the transfer of the cryptocurrency

10
https://www.binance.com/en-IN/blog/community/to-wazirx-users-zanmairun-wazirx-can-no-
longer-use-binance-wallet-services-6687744643229571570
 9

tokens held by Binance, which Binance asked to be transferred out, so as to

maintain the status quo of the Platform whilst the dispute between Zettai and

Binance remains ongoing. Zettai thus took over control from Binance of these

cryptocurrency tokens under protest, solely in the interests of WazirX users.

Notwithstanding the above, it should be noted that Binance did not relinquish

control of all cryptocurrency tokens relating to the Platform. I have referred to

these cryptocurrency tokens as contingent assets, and elaborate at [36] below.

22. It was in these circumstances that on 31 January 2023, Zettai entered into a

License Agreement with Answer Eleven Pte Ltd (“Liminal”). Pursuant to this

agreement, Liminal would provide, inter alia, the digital asset wallet

management services the Platform needed due to Binance’s actions. I wish to

add that it was necessary to engage the services of Liminal so as to strengthen

the security and safety of the cryptocurrency tokens relating to the Platform.

Between 30 January 2023 and 8 February 2023, the cryptocurrency tokens in

the Binance wallets were moved to wallets on Liminal’s platform.

23. The dispute between Zettai and Binance on the ownership of the Platform is

ongoing. Zettai maintains that Binance wrongfully relinquished control of the

digital assets which were transferred to Binance, which Zettai had no choice

but to take over so as to maintain the status quo and ensure that operations of

the Platform would not be affected by the ongoing dispute. I am not able to

provide any further details on the ongoing dispute because of confidentiality

reasons.

The 18 July 2024 cyberattack

 10

24. On 18 July 2024, the Platform fell victim to a vicious cyberattack which was

widely reported on various news sources.11 This cyberattack is presently being

investigated by the authorities in India and authorities in another country which

I am not at liberty to disclose. The identity of the cyber-attacker(s) remains

unknown. Zettai has also lodged a complaint with the authorities in Singapore

on 17 August 2024.

25. While the systems of Zettai and Zanmai India were not compromised by the

cyberattack, the cyberattack saw one of the Platform’s wallets (containing

digital assets with an aggregate value of around USD234 million at the time)

managed using Liminal’s digital asset custody and wallet infrastructure emptied

of its funds. The digital assets were taken out of the Platform’s wallets, and it

is suspected that most of the digital assets stolen have since been dissipated

by the cyber-attackers across numerous wallets. This represents a theft of

digital assets amounting to close to half of the Platform’s digital assets.

26. Within hours of the cyberattack, the Platform ceased processing all users’

withdrawal requests to prevent further losses.12 The Platform also

subsequently ceased to process trades.

27. I reiterate that Zettai only took control of these digital assets relating to the

Platform under protest, after Binance made clear its desire to relinquish control

of them. Zettai maintains that the Platform and its assets were effectively

11 See for example: https://economictimes.indiatimes.com/tech/technology/wazirx-suffers-security-

breach-cybersecurity-firm-pegs-hack-at-234-9-million/articleshow/111831916.cms?from=mdr
(accessed on 15 August 2024) and https://timesofindia.indiatimes.com/technology/tech-news/wazirx-
hacked-ceo-makes-this-clarification-on-fir-filed/articleshow/112336810.cms (accessed on 15 August
2024)
12 https://wazirx.com/blog/wazirx-cyber-attack-day-wise-report/
 11

transferred to Binance in accordance with the Transfer Transaction, and should

have remained with Binance.

28. Nevertheless, Zettai is taking proactive steps to manage the crisis whilst the

dispute with Binance remains ongoing. Zettai has been pursuing the recovery

of the stolen digital assets. Since the cyberattack, Zettai has engaged a third-

party blockchain forensics and tracing firm zeroShadow to actively trace and

tag stolen token assets on the blockchain. With their findings, Zettai has

reached out to over 500 cryptocurrency exchanges to block the identified wallet

addresses to which some of the stolen token assets have been transferred.13

Zettai has also called on the community to help track and freeze these stolen

token assets and to assist in their recovery.14 To date, some small amounts of

the stolen token assets have been traced to third-party exchanges, and Zettai

is working to recover those assets which the third party exchanges have

assisted to freeze. Zettai has also been working with various law enforcement

agencies to identify the perpetrators of this devastating cyberattack.

III. FINANCIAL DIFFICULTIES

29. The cyberattack and the theft of digital assets has caused a loss of about

USD234 million in digital assets at the time. The cyberattack and the publicity

surrounding it has also caused a wave of panic and uncertainty, resulting in an

increased number of cryptocurrency withdrawal requests in the wake of the

news of the cyberattack. As there was a real danger of an uncontrolled bank

run of withdrawal requests that the Platform would not be able to meet, Zettai

13 https://wazirx.com/blog/wazirx-cyber-attack-day-wise-report/
14 https://wazirx.com/blog/wazirx-bounty-program/
 12

made the difficult decision to suspend all withdrawal requests on 18 July 2024

and all trading on 21 July 2024. Zettai has also since restored all users’

positions as at 18 July 2024, undoing any trades conducted after 18 July 2024.

30. Notwithstanding the measures taken above, the Platform continues to receive

requests for withdrawals through other channels such as email / direct

message. Since the cyberattack, the Platform has received more than 9,700 of

such requests, and it is expected that the Platform will continue to receive such

requests.

31. To the best of my knowledge and belief, I set out below the liquid assets under

Zettai’s control as at 23 August 2024 (the “Liquid Assets”).

32. The following Liquid Assets are custodied in a range of wallets and on multiple

third-party exchanges, and are under Zettai’s control:

Token Price
S.No Token Liquidity Quantity (Token) Value (USD)
(USD / Token)
1 btc Liquid
1,138 61,239.83935 69,707,901
2 doge Liquid
261,299,646 0.10748 28,084,325
3 xrp Liquid
39,092,847 0.60083 23,488,173
4 sol Liquid
123,418 145.64987 17,975,780
5 trx Liquid
98,489,789 0.15440 15,206,605
6 poe Liquid
9,190,325 1.50194 13,803,320
7 wrx Liquid
83,731,832 0.15949 13,354,157
8 ada Liquid
29,799,415 0.38127 11,361,585
9 lovely Liquid
1,150,253,727 0.00979 11,258,872
 13

10 bttc Liquid
7,465,141,789,923 0.00000 7,017,233
Other tokens
11 Liquid
and fiat N/A N/A 72,787,263
Subtotal
284,045,215

33. In addition to the assets listed above at [32], the Liquid Assets also include an

additional aggregate of USD12 million in cryptocurrency tokens which have

been set aside to meet the following costs and expenses that Zettai anticipates

to incur in the near future:

(a) Expenses incurred to continue investigations and recovery efforts

relating to the stolen cryptocurrency tokens;

(b) Costs and expenses in respect of a comprehensive restructuring,

including financial assessments, community outreach, scheme-related

expenses, KYC expenses, and operational costs necessary to support

the restructuring; and

(c) Legal costs for ongoing proceedings which I am not in a position to

provide further details because of confidentiality reasons.

34. To the best of my knowledge and belief, I set out below Zettai’s illiquid

contingent assets as at 23 August 2024 (the “Illiquid Assets”):

S.No Token Liquidity Value (USD)

1 Contingent Assets Illiquid 17,742,017

35. The Illiquid Assets comprise USD14.8 million of token assets which remain in

wallets with Binance (which Binance has restricted Zettai’s ability to withdraw)

and USD3.0 million of WRX tokens that Binance was supposed to airdrop to
 14

Zettai in line with the WRX token unlock schedule of users with WRX token

holdings on the Platform (but have not done so). These assets are listed above

as contingent assets, as Zettai has identified these assets as attributable to the

liabilities of the Platform but have not yet been able to realise.

36. As Zettai took control over the Platform’s funds under protest, most of Zettai’s

liabilities are contingent on the outcome of the ownership dispute between

Binance and Zettai. With the exception of certain token deposits held on trust

for various law enforcement agencies, these liabilities are unsecured liabilities

owed by the owner of the Platform to the Platform’s users, which broadly reflect

the users’ account balances. In the event the Platform’s users make withdrawal

requests in accordance with the Platform’s terms of use, Zettai would be liable

to transfer those sums to the users (if Zettai is found to own the Platform

together with its funds). With the above in mind, the Platform’s users constitute

the vast majority of Zettai’s creditors. To the best of my knowledge and belief,

I have set out below a breakdown of the user balances on the Platform as of

18 July 2024, the date of the Withdrawal Freeze:

Nature of
S.No Category Number of Users USD Amount Claim against
Zettai
Individual
Unsecured,
1 Platform 4,352,659 558,671,126
Contingent
Users
Corporate
Unsecured,
2 Platform 640 11,397,232
Contingent
Users
Total 4,353,299 570,068,358

37. These individual and corporate users are mostly from India, with more than

94% of active users from India.

 15

38. Besides the liabilities that Zettai may owe to the Platform’s users, Zettai has

approximately USD247,000 of trade payables (owing to some 13 creditors)

outstanding as at 31 July 2024, which are associated with operations and

ongoing legal proceedings, including legal costs, software infrastructure costs,

software subscription costs, and manpower costs. I shall refer to the aggregate

user balances and the trade payables collectively as “Liabilities”.

39. In addition, over the years, the Platform had accepted deposits of

cryptocurrency tokens aggregating USD28,004,198 (valued as at 18 July 2024)

from various Indian law enforcement agencies (“LEAs”) under a special

arrangement where the Platform would hold these tokens on trust for the LEAs.

These tokens (save for a balance of tokens valued at under USD1,000 as at

23 August 2023 that remain with Binance) remain with Zettai, were unaffected

by the cyberattack, and continue to be held on trust for the LEAs. For the

avoidance of doubt, these cryptocurrency tokens are not part of the assets

listed in the table at [32] above.

40. The Liabilities are valued on the date of the cyberattack and the suspension of

withdrawal (18 July 2024). The Assets are valued as at a more recent time (23

August 2024) intended to reflect their latest available value applicable to

Liabilities. While the underlying tokens balances comprising the Assets remain

substantially unchanged as of 18 July 2024, they have been and will continue

to be subject to further price movements in line with the volatility experienced

in the cryptocurrency market, and the above valuation of Assets is only

intended to be a valuation snapshot at a specific time (23 August 2024).

 16

41. It should be noted that as there are different source currencies for the Assets

and Liabilities, price movements will affect token Assets differently from the

token Liabilities. Fixing and valuing the Liabilities at a specific point allows for

a fixed point of reference. However, that alone would not be sufficient to align

the impact of price movement on Assets and Liabilities. A rebalancing of Assets

needs to be undertaken to align allocation of value across token denominations

in both Assets and Liabilities (“Asset Rebalancing”) to ensure proportionate

exposure to cryptocurrency price movements in respect of both the Assets and

the Liabilities. An Asset Rebalancing is presently being considered by Zettai as

part of the restructuring pending an internal assessment and consultation with

creditors.

IV. Top 20 Creditors

42. To the best of my knowledge and belief, the top 20 unsecured, unrelated

creditors of Zettai as at 18 July 2024 are set out below. These creditors have

contingent claims against Zettai, for the reasons explained above at [36].

Claim Value as at Nature of

S.No Name
18 July 2024 (USD) Claim
Unsecured,
1
Party A* 6,337,298 Contingent
Unsecured,
2
Party B* 1,482,740 Contingent
Unsecured,
3
Vishal Moral 1,468,207 Contingent
Unsecured,
4
Party C 1,161,034 Contingent
Unsecured,
5
Rakesh Agrawal 1,003,487 Contingent
Unsecured,
6
Neeraj Kumar Burman 559,082 Contingent
Unsecured,
7
Punit Dilipkumar Mehta 527,847 Contingent
 17

Unsecured,
8
Rajesh Lachmandas Kaura 521,865 Contingent
Unsecured,
9
Party D 516,396 Contingent
Unsecured,
10
Harish Paruchuru 482,975 Contingent
Unsecured,
11
Pritee Hemchandra Shroff 473,707 Contingent
Bangalore Mallaiah Unsecured,
12
Malikarjunaiah 440,357 Contingent
Unsecured,
13
Sandeep Rai 435,321 Contingent
Unsecured,
14
Vijay 421,342 Contingent
Unsecured,
15
Party E 388,821 Contingent
Unsecured,
16
Party F 384,349 Contingent
Unsecured,
17
Adinarayana Rao Mandapalli 362,287 Contingent
Unsecured,
18
Biju Zachariah 342,371 Contingent
Unsecured,
19
Lokesh Ratnam 337,228 Contingent
Unsecured,
20
Krishna Ramchandra Miskin 331,446 Contingent
* Subject to confirmation

43. The creditors, Party C, Party D, Party E and Party F have requested that they

not be identified in this affidavit, with at least one creditor citing potential

security risks.

44. Zettai does not have any secured creditors.

V. PROPOSAL FOR RESTRUCTURING AND NEED FOR MORATORIUM

45. Following the cyberattack, Zettai has come forward to take the lead in finding

a solution for the benefit of the Platform’s users. To this end, Zettai’s
 18

management has engaged the following professionals to advise Zettai on its

legal and financial options:

(a) Kroll Pte Ltd as financial advisors;

(b) Nishith Desai Associates as legal advisors in India; and

(c) Rajah & Tann Singapore LLP as legal advisors in Singapore.

46. Having received their advice, Zettai’s management believes that there is

potential in formulating a restructuring plan by way of a scheme of arrangement

involving Zettai and the users of the Platform as contingent creditors of Zettai

that would be beneficial for the parties involved. This is so even though the

users of the Platform are contingent creditors of Zettai, as it would be in the

interests of the users to see a resolution of their balances on the Platform

sooner rather than later.

47. At present, Zettai contemplates that the restructuring process would likely

involve the following:

(a) Engaging a suitable white knight to provide capital to, among others,

improve recoveries to users, maintain operational expenses and/or to

cover professional fees.

(b) Considering the needs and wants of users in relation to receiving payouts

under a potential scheme of arrangement and determining an

appropriate mechanism to effect the same.

(c) Considering potential solutions which may include, among others:

 19

(i) A classification of user token balances and potential re-

balancing of available token assets to match pro-rata the token

denomination of user token balances, allowing in-kind

distributions of cryptocurrency tokens to users instead of fiat;

(ii) Deleveraging exercise(s) to quickly deliver liquidity to users

who need liquidity urgently which will allow improved recoveries

to remaining users through the extinguishment of other user

balances; and/or

(iii) The commercial and technical assessment and implementation

of cryptocurrency-specific mechanisms to improve token

recoveries to users which may include cross-platform

collaborations with third party cryptocurrency exchanges and /

or OTC desks to generate cashflows, the implementation of

non-custodial Decentralized Finance smart contract products

which allow profit sharing via airdropped tokens, and potentially

the tokenization of outstanding user balances for trading on the

secondary market.

(d) Making the necessary applications to Court to seek the Court’s

approval for a scheme of arrangement.

48. As part of the proposed restructuring, Zettai’s management has been in

discussions with potential white knights. Zettai’s management is currently at

various stages of discussion with 11 different cryptocurrency exchanges and

trading businesses to discuss potential options. These 11 potential white

knights comprise large and well-established players in the cryptocurrency

 20

market serving in the range of 5.5 – 100 million users, covering 500 – 1,000+

tokens, with daily transaction volumes ranging from USD5 million – 4 billion.

Progress on discussions range from informal conversations, to executed Non-

Disclosure Agreements (“NDAs”) followed by active data provision in relation

to potential collaboration options. Three NDAs have been signed to date with

prominent cryptocurrency exchanges with user bases in the range of 12 – 100

million users and between ~USD5 million and ~USD1.5 billion in daily trade

volume.

49. At this preliminary stage, some of the white knights have expressed interest in

providing rescue financing or partnering with Zettai. Informal offers from

potential investors to date include capital injections to improve user recoveries,

collaboration on various revenue-generating products and profit-sharing

mechanisms, airdrops, assistance for the recovery of stolen assets through

forensic analysis and litigation support, and the deployment of token assets to

generate yield. In this regard, I am optimistic for the following reasons:

(a) The cyberattack that occurred on 18 July 2024 did not compromise the

Platform’s infrastructure, which remains fully capable of supporting

integrations with third-party cryptocurrency platforms and their

associated technology stacks to drive the generation of new revenue-

generating products. Further, following the cyberattack, a third-party

cybersecurity and investigations firm certified that the Platform’s

relevant hardware was not compromised.

(b) Notwithstanding the ongoing dispute with Binance and up to 18 July

2024, the Platform continued to serve the cryptocurrency trading needs

 21

of its users, supporting an average daily trading volume of USD3.5

million and average monthly trading volume of USD107 million over the

12 months prior to 18 July 2024. The Platform’s ability to support this

operational volume has not changed and was not affected by the

cyberattack of 18 July 2024.

(c) The Platform has a significant user base of approximately 16 million

users, of which approximately 4.4 million maintain cryptocurrency

balances on the Platform. A large part of this user base will continue to

have cryptocurrency trading requirements that the Platform will be

positioned to service.

50. However, a key caveat that has been raised by multiple potential white knights

is the ongoing uncertainty and possibility of legal action which may compromise

ongoing discussions. In Zettai management’s view, a moratorium is therefore

necessary to effectively assure potential white knights that we have sufficient

time and protection to realistically pursue these options.

51. Further, as of 24 August 2024, the Platform has already received upwards of

9,700 withdrawal-related emails and platform messages. It is foreseeable that

frustrated and hostile users of the Platform may commence legal proceedings

against all entities involved in the Platform’s operations (past and present). To

this end, between 21 July 2024 and 2 August 2024, the Platform has received

4 legal notices. Resolving such legal proceedings would consume considerable

time and resources, which would frustrate genuine attempts at restructuring

and would not be beneficial for the general run of the Platform users.
 22

52. In view of the above, Zettai is seeking a moratorium for a period of six (6)

months from the date of this application or until further order. Zettai’s

restructuring is expected to be a significant undertaking. Zettai will need time

for extensive discussions and negotiations with potential white knights. During

the moratorium period, Zettai will also be actively engaging with the Platform’s

user base (with 4.4 million active users) to establish support for a compromise

or arrangement.

53. Zettai is in the process of engaging creditors to seek their support on the

moratorium. One of the Platform’s top 20 creditors has come forward to

express support for the moratorium, and I am hopeful that more creditors will

come forward to indicate their support for the moratorium as well. A copy of the

email evidencing this support (redacted to maintain the anonymity of the user)

is exhibited at “NCS-1, Tab 5”.

54. I intend to file a supplemental affidavit in due course to set out the support from

Zettai’s creditors for the moratorium once their responses are collated.

VI. PROCEDURAL REQUIREMENTS

55. For good order, I confirm the following:

(a) No orders have been made and no resolutions passed in respect of the

winding up of Zettai.

(b) Zettai undertakes to make, as soon as practicable:

 23

(i) an application under section 210(1) of the Companies Act 1967

for the Court to order to be summoned a meeting of the

creditors or class of creditors in relation to a scheme of

arrangement; or

(ii) an application under section 71(1) of the IRDA to approve the

scheme of arrangement.

(c) Zettai has not and will not make any separate application(s) for a

moratorium under section 210(10) of the Companies Act 1967.

(d) Zettai has not made an application under section 64 of the IRDA or

section 211B of the Companies Act (as in force immediately before 30

July 2020) in the past 12 months.

(e) Zettai undertakes to provide any requisite notices including publication

of notice of this application and making the necessary advertisements.

In this regard, as the main means of communication between the

Platform and its users is via emails, blog posts, and push notifications

via the Platform, Zettai intends to publish advertisements by way of a

blog post, in one local Singapore newspaper and in one local Indian

newspaper.

(f) I have been advised that Zettai does not belong to any of the classes

of companies which are prohibited from seeking relief under section 64

of the IRDA.
 24

56. I have also been advised that pursuant to section 64(6) of the IRDA, the Court

would order Zettai to submit to the Court sufficient information relating to its

financial affairs to enable its creditors to assess the feasibility of the intended

restructuring plan. In this connection, I confirm that the information set out

above at [31] to [44] is accurate at the time of this affidavit.

57. I wish to highlight that since Zettai’s Assets comprise primarily of

cryptocurrency tokens, a valuation report relating to the Assets would likely be

unnecessary. Further, as Zettai has halted trading activity on the Platform

following the cyberattack, there are no periodic financial reports and profitability

forecasts that Zettai can provide. Zettai will be able to provide the Honourable

Court with a cashflow forecast, which Zettai will update the Honourable Court

on when there are substantial changes.

58. Should the Honourable Court make an order for information to be submitted,

Zettai undertakes to do so to the best of its abilities. In this regard, Zettai

humbly requests for at least two (2) weeks to comply with any order on the

provision of information.

59. Zettai will also continue to do its best to engage its key stakeholders and

maintain open lines of communication, especially in relation to providing

periodic updates on the progress of court proceedings and the restructuring. In

this regard, I confirm that Zettai's main means of communication with the

Platform’s users is via a combination of emails, blog posts, and push

notifications via the Platform. I further confirm that the usual means of

communication with the other unsecured creditors is by way of email.

 25

VII. CONCLUSION

60. In light of the foregoing, Zettai humbly prays that the application herein be

granted to enable it to work with its advisors and stakeholders on a proposal

that will benefit its stakeholders.

Dated this day of 2024

AFFIRMED by the abovenamed )

NISCHAL SHETTY )
on the 27th day of August 2024 )
in SINGAPORE )
appearing before the Commissioner for Oaths )
through a live video link )
and signed electronically )

Before me

___________________________________

A COMMISSIONER FOR OATHS

This Affidavit is filed on behalf of the Applicant

27
31
1/25/24, 12:36 PM Ministry Of Corporate Affairs - MCA Services
32
Ministry Of Corporate Affairs
Date : 25-01-2024 12:36:36 pm

Company Information

CIN U72900MH2017PTC303170

Company Name ZANMAI LABS PRIVATE LIMITED

ROC Name ROC Mumbai

Registration Number 303170

Date of Incorporation 21/12/2017

Email Id contact@zanmai.in

HD-024, WeWork Enam Sambhav, C - 20, G Block Rd, G Block

Registered Address BKC, Bandra Kurla Complex, Bandra East,, Mumbai City,
MUMBAI, Maharashtra, India, 400051

Address at which the books of account

-
are to be maintained

Listed in Stock Exchange(s) (Y/N) No

Category of Company Company limited by shares

Subcategory of the Company Non-government company

Class of Company Private

ACTIVE compliance ACTIVE Compliant

Authorised Capital (Rs) 1,00,000

Paid up Capital (Rs) 1,00,000

Date of last AGM 30/09/2023

Date of Balance Sheet 31/03/2023

Company Status Active

Jurisdiction

ROC (name and office) ROC Mumbai

RD (name and Region) RD, Western Region

Index of Charges
1/25/24, 12:36 PM
No Records Found
Ministry Of Corporate Affairs - MCA Services
33

Director/Signatory Details

Sr. Date of Cessation

DIN/PAN Name Designation Signatory
No Appointment Date
SAMEER
1 05171548 HANUMAN Director 21/12/2017 - Yes
MHATRE

NISCHAL
2 05171543 Director 21/12/2017 - Yes
SHETTY

TUSHAR
3 10046498 LALJIBHAI Director 06/03/2023 - Yes
PATEL

MUTHUSWAMY
4 10054859 NAGARAJAN Director 06/03/2023 - Yes
IYER
34
 35
Buy Crypto Markets Trade Futures Earn Square More Log In Sign Up

Binance Acquires India’s Leading Digital Asset Platform WazirX to Launch Multiple
Fiat-to-Crypto Gateways
2019-11-21

Update 5th August 2022: We would like to clarify that the 2019 'acquisition’ described in this blog was limited
to an agreement to purchase certain assets and intellectual property of WazirX. Binance did not purchase any
equity (and does not own any equity) in Zanmai Labs, the entity operating WazirX and established by the
original founders. In addition, WazirX (including the foregoing assets) continues to be operated and managed
by Zanmai Labs.

Starting November 25, people in India can buy and sell cryptocurrencies with fiat currencies through the
Binance Fiat Gateway.

Global cryptocurrency exchange and blockchain ecosystem, Binance, today announced its acquisition of
WazirX, India's most trusted bitcoin exchange. Starting November 25, you can buy and sell crypto with Indian
rupees (INR) on the Binance Fiat Gateway.

In Q1 of 2020, WazirX’s unique auto-matching engine will be integrated into the Binance Fiat Gateway platform
itself, bringing easy cryptocurrency access to over a billion people. Users on Binance.com will be able to
directly place orders on Binance.com and the Binance iOS or Android app to purchase Tether (USDT) against
INR. This integration will allow users to trade any digital asset available on Binance.com with the purchase of
USDT from the WazirX digital asset marketplace

"The young demographic in India give an edge to adopt and build on new financial technologies, and I believe
this will play a vital role in making India a global blockchain innovation center to also spur cryptocurrency
adoption throughout the larger public in the country," said CZ (Changpeng Zhao), Binance CEO. "The
acquisition of WazirX shows our commitment and dedication to the Indian people and strengthen the
blockchain ecosystem in India as well as another step forward in achieving the freedom of money.”
38
 39

USER AGREEMENT
VERSION 1.04
LAST REVISED ON: 1st August, 2023

This user agreement (this “Agreement”) along with the Know Your Client (KYC)- Anti Money Laundering (AML)
T&C sets forth the legally binding terms and conditions your access to and use of any websites, mobile sites, mobile
applications, desktop applications, products or services (the “Services”) offered by Zanmai Labs Private Limited
(“Zanmai”) and the business known as “Binance” (further described on www.binance.com). Binance and Zanmai
operate separate parts of the Services to the extent further described under Sections 5 and 6, respectively, below.

Any reference to “WazirX”, “us”, “our”, and “we” in this Agreement shall be construed to be a reference to either
Binance or Zanmai depending on the relevant part of the Service in question. For instance, Clauses 3 (Prohibited
Activities) and 7 (Fees and Taxes) applies vis-à-vis Binance for its portion of the Services as described under Clause
5 below, and Clause 3 applies vis-à-vis Zanmai for its portion of the Services as described under Clause 6 below.
The “User”, “you”, “your” shall refer to any natural person or entity and its authorized users that subscribes or uses
the Services. Certain features of the Site may be subject to additional guidelines, terms, or rules, which will be posted
on the Site in connection with such features. All such additional terms, guidelines, and rules are incorporated by
reference into this Agreement.

BY ACCESSING OR USING THE SERVICES, YOU ARE ACCEPTING THIS AGREEMENT AS WELL AS THE
KNOW YOUR CLIENT (KYC)- ANTI MONEY LAUNDERING (AML) T&C (ON BEHALF OF YOURSELF OR
THE ENTITY THAT YOU REPRESENT), AND YOU REPRESENT AND WARRANT THAT YOU HAVE THE
RIGHT, AUTHORITY, AND CAPACITY TO ENTER INTO THIS AGREEMENT (ON BEHALF OF YOURSELF
OR THE ENTITY THAT YOU REPRESENT). YOU MAY NOT ACCESS OR USE THE SERVICES OR ACCEPT
THIS AGREEMENT IF YOU ARE NOT AT LEAST 18 YEARS OLD. IF YOU DO NOT AGREE WITH ALL OF
THE PROVISIONS OF THIS AGREEMENT, DO NOT ACCESS AND/OR USE THE SITE. THESE TERMS
REQUIRE THE USE OF ARBITRATION (SECTION 13.1) ON AN INDIVIDUAL BASIS TO RESOLVE
DISPUTES AND ALSO LIMIT THE REMEDIES AVAILABLE TO YOU IN THE EVENT OF A DISPUTE. A
REFERENCE TO THIS AGREEMENT SHALL ALWAYS INCLUDE REFERENCE TO THE KNOW YOUR
CLIENT (KYC)- ANTI MONEY LAUNDERING (AML) T&C. SUCH KNOW YOUR CLIENT (KYC)- ANTI
MONEY LAUNDERING (AML) T&C SHALL ALWAYS BE CONSIDERED AS A PART AND PARCEL OF AND
IS TO BE READ WITH THIS AGREEMENT. IN THE EVENT OF ANY CONFLICT OR INCONSISTENCY
BETWEEN THE PROVISIONS OF THIS AGREEMENT AND THE KNOW YOUR CLIENT (KYC)- ANTI
MONEY LAUNDERING (AML) T&C, THE PROVISIONS OF THIS AGREEMENT SHALL PREVAIL TO THE
EXTENT OF SUCH CONFLICT OR INCONSISTENCY.

We may amend this Agreement related to the Services from time to time. Amendments will be effective upon our
posting of such updated Agreement at this location or the amended policies or supplemental terms on the applicable
Service. Your continued access or use of the Services after such posting constitutes your consent to be bound by the
Agreement, as amended.

YOU ACKNOWLEDGE THAT TRADING IN CRYPTOCURRENCIES (ALSO REFERRED TO AS VIRTUAL

DIGITAL ASSETS, CRYPTO-ASSETS, ETC.) INVOLVES A HIGH DEGREE OF RISK. CRYPTOCURRENCIES
ARE SUBJECT TO CONSTANT AND FREQUENT FLUCTUATIONS IN VALUE AND EXCHANGE RATES,
AND THE VALUE OF YOUR CRYPTOCURRENCY ASSETS MAY INCREASE OR DECREASE AT ANY TIME.
ACCORDINGLY, YOU MAY SUFFER A COMPLETE LOSS OF THE FUNDS HELD IN YOUR ACCOUNT.
YOU ACKNOWLEDGE THAT YOU ARE SOLELY RESPONSIBLE FOR DETERMINING THE NATURE,
SUITABILITY, AND APPROPRIATENESS OF THESE TRADING RISKS FOR YOU. YOU ACKNOWLEDGE
AND AGREE THAT WAZIRX BEARS NO RESPONSIBILITY OR LIABILITY TO YOU OR ANY OTHER
PERSON WHATSOEVER FOR ANY LOSSES OR GAINS INCURRED IN CONNECTION WITH YOUR USE OF
THE SERVICES. YOU ALSO ACKNOWLEDGE AND AGREE THAT WAZIRX DOES NOT GIVE ADVICE OR
RECOMMENDATIONS REGARDING THE TRADING OF CRYPTOCURRENCIES, INCLUDING THE
SUITABILITY AND APPROPRIATENESS OF, AND INVESTMENT STRATEGIES FOR,
CRYPTOCURRENCIES. YOU ALSO DECLARE THAT YOU ARE NOT IN THE BUSINESS OR PROFESSION
OF REFERRING NEW USERS TO US. THE REFERRALS MADE BY YOU TO US ARE IN YOUR INDIVIDUAL
 40

CAPACITY. IN THE EVENT YOU ARE UNDERTAKING SUCH REFERRALS IN FURTHERANCE TO A

BUSINESS OR PROFESSION, YOU ARE UNDER THE OBLIGATION TO BRING IT TO OUR NOTICE. IN
SUCH A CASE, WE WILL BE ENTITLED TO DEDUCT / COLLECT ADDITIONAL WITHHOLDING TAXES
AS MAY BE REQUIRED BY APPLICABLE LAW.

YOU ALSO ACKNOWLEDGE AND AGREE THAT WAZIRX AND YOUR ABILITY TO USE THE SERVICES
MAY BE DETRIMENTALLY IMPACTED BY REGULATORY ACTION OR CHANGES IN REGULATIONS
APPLICABLE TO CRYPTOCURRENCY. YOU AGREE THAT WE MAY DISCLOSE YOUR PERSONAL AND
ACCOUNT INFORMATION IF WE BELIEVE THAT IT IS REASONABLY NECESSARY TO COMPLY WITH
A LAW, REGULATION, LEGAL PROCESS, OR GOVERNMENTAL REQUEST.

YOU HEREBY ACKNOWLEDGE AND AGREE THAT WAZIRX IS NOT A FINANCIAL INSTITUTION, BANK,
CREDIT UNION, TRUST, HEDGE FUND, BROKER OR INVESTMENT OR FINANCIAL ADVISOR, AND IS
NOT SUBJECT TO THE SAME LAWS, REGULATIONS, DIRECTIVES OR REQUIREMENTS APPLICABLE
TO SUCH PERSONS. YOU ACKNOWLEDGE AND AGREE THAT NO ORAL OR WRITTEN INFORMATION
OR ADVICE PROVIDED BY WAZIRX, ITS OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS, NOR ANY
INFORMATION OBTAINED THROUGH THE SERVICES, WILL OR SHALL CONSTITUTE INVESTMENT,
OR FINANCIAL ADVICE. YOU ARE SOLELY AND EXCLUSIVELY RESPONSIBLE FOR ALL TRADING
DECISIONS MADE BY YOU WHILE USING THE SERVICES.

WAZIRX IS MERELY A TECHNOLOGY PLATFORM AND YOU ARE SOLELY AND ENTIRELY
RESPONSIBLE FOR THE LEGAL, REGULATORY AND TAX COMPLIANCE OF ALL TRANSACTIONS
CARRIED OUT BY YOU USING THE SERVICES, SUBJECT TO THE TERMS OF THIS AGREEMENT.

1. ACCOUNTS

1.1 Account Creation. In order to use certain features of the Site, you must register for an account
(“Account”) and provide certain information about yourself as prompted by the account registration
form. You represent and warrant that: (a) all required registration information you submit is truthful and
accurate; (b) you will maintain the accuracy of such information; (c) your use of the Services is and shall
be in accordance with applicable law. You may temporarily suspend your Account at any time, for any
reason, by following the instructions on the Site. WazirX may suspend or terminate your Account in
accordance with Section 9.

1.2 Identity Verification. You agree to provide us with the information we request for the purposes of
identity verification and the detection of money laundering, terrorist financing, fraud, or any other
financial crime and permit us to keep a record of such information, consistent with our Know Your Client
(KYC)- Anti Money Laundering (AML) T&C. You will need to complete certain verification procedures
before you are permitted to use the Services and your access to the Services may be altered as a result of
information collected on an ongoing basis. The information we request may include certain personal
information, including, but not limited to, your name, address, telephone number, e-mail address, date
of birth, taxpayer identification number, government identification number, and information regarding
your bank account (such as the name of the bank, the account type, routing number, and account number).
In providing us with this or any other information that may be required, you confirm that the information
is accurate and authentic. You agree to update this information and keep it current at all times. You
authorize us to make the inquiries, whether directly or through third parties, that we consider appropriate,
in our sole discretion, to verify your identity or protect you and/or us against fraud or other financial
crimes, and to take action we reasonably deem necessary based on the results of such inquiries.

1.3 Certain Restrictions. By using the Services, you represent and warrant that: (i) neither you nor any of
your directors, officers, employees, agents, affiliates or representatives is an individual or an entity that
is, or is owned or controlled by an individual or entity that is (a) currently the subject of any Sanctions,
or (b) located, organized or resident in a Designated Jurisdiction; (ii) you have complied in all material
respects with all applicable laws relating to Sanctions, anti-terrorism, anti-corruption and anti-money
laundering; and (iii) you have instituted and maintained policies and procedures designed to promote
 41

and achieve compliance with such laws. For the purpose of this Agreement, “Designated Jurisdiction”
means any country or territory to the extent that such country or territory itself is the subject of any
Sanction; “Sanction(s)” means any international economic sanction administered or enforced by the
United States Government (including OFAC), the United Nations Security Council, the European Union
or other relevant sanctions authority.

1.4 Account Responsibilities. You are responsible for maintaining the confidentiality of your Account login
information and are fully responsible for all activities that occur under your Account including all
consequences under applicable laws. You agree to immediately notify WazirX of any unauthorized use,
or suspected unauthorized use of your Account or any other breach of security. WazirX cannot and will
not be liable for any loss or damage arising from your failure to comply with the above requirements.
WazirX will not be liable or responsible for compromise, unauthorized use or suspected unauthorized
use of your Account or any claims or actions in any manner related thereto.

1.5 Compliance. You are solely responsible for ensuring that your use of the Services is in compliance with
all laws, rules and regulations applicable to you and the right to access the Services is automatically
revoked where use of the Services is prohibited or to the extent that the offering, sale or provision of the
Services conflicts with any law, rule or regulation applicable to you.

1.6 Available Only Where Permitted by Law. The Services are only available in jurisdictions where they
may be legally offered for sale. The Services are not available to “U.S. Persons”, as such term is defined
under Regulation S promulgated under the Securities Act of 1933. By accessing or using the Site, you
represent and warrant that you are not a U.S. Person.

2. ACCESS TO THE SERVICES

2.1 License. Subject to this Agreement, WazirX grants you a non-transferable, non-exclusive, revocable,
limited license to use and access the Services solely for your own personal or internal business purposes,
in accordance with the Account type you are currently subscribing to.

2.2 Modification. WazirX reserves the right, at any time, to modify, suspend, or discontinue the Services
(in whole or in part) with or without notice to you. You agree that WazirX will not be liable to you or to
any third party for any modification, suspension, or discontinuation of the Services or any part thereof.

2.3 No Support or Maintenance. You acknowledge and agree that WazirX will have no obligation to
provide you with any support or maintenance in connection with the Services.

2.4 Ownership. You acknowledge that all the intellectual property rights, including copyrights, patents,
trademarks, and trade secrets, in the Services and its content are owned by WazirX or its suppliers.
Neither this Agreement (nor your access to the Services) transfers to you or any third party any rights,
title or interest in or to such intellectual property rights, except for the limited access rights expressly set
forth in Section 2.1. WazirX and its suppliers reserve all rights not granted in this Agreement. There are
no implied licenses granted under this Agreement.

2.5 Feedback. If you provide WazirX with any feedback or suggestions regarding the Site (“Feedback”),
you hereby assign to WazirX all rights in such Feedback and agree that WazirX shall have the right to
use and fully exploit such Feedback and related information in any manner it deems appropriate. WazirX
will treat any Feedback you provide to WazirX as non-confidential and non-proprietary. You agree that
you will not submit to WazirX any information or ideas that you consider to be confidential or
proprietary.

3. PROHIBITED ACTIVITIES

3.1 Prohibited Activities. In connection with your use of Services, you hereby agree that you will not:
 42

(a) violate (or assist any other party in violating) any applicable law, statute, ordinance, or regulation;
(b) intentionally try to defraud (or assist in the defrauding of) WazirX or any other User;
(c) provide false, inaccurate, or misleading information;
(d) trade taking advantage of any technical glitch, malfunction, failure, delay, default, or security
breach;
(e) take any action that interferes with, intercepts, or expropriates any system, data, or information;
(f) partake in any transaction involving the proceeds of illegal activity;
(g) attempt to gain unauthorized access to other WazirX Accounts, the Services, or any related
networks or systems;
(h) use the Services on behalf of any third party or otherwise act as an intermediary between WazirX
and any third parties, unless WazirX and the User have specifically entered into a written
agreement enabling such use or action;
(i) use the Services to engage in conduct that is detrimental to WazirX or to any other User or any
other third party;
(j) collect any user information from other Users, including, without limitation, email addresses;

(k) defame, harass, or violate the privacy or intellectual property rights of WazirX or any other User;
or
(l) upload, display or transmit any messages, photos, videos or other media that contain illegal goods,
pornographic, violent, obscene or copyrighted images or materials for use as an avatar, in
connection with a payment or payment request, or otherwise.
(m) In addition, you agree not to: (i) upload, transmit, or distribute to or through the Services any
computer viruses, worms, or any software intended to damage or alter a computer system or data;
(ii) interfere with, disrupt, or create an undue burden on servers or networks connected to the
Services, or violate the regulations, policies or procedures of such networks; (iii) attempt to
reverse engineer, de-compile, disable, interfere with, disassemble, copy, or disrupt the integrity
or the performance of the Services, any third-party use of the Services, or any third-party data
contained therein (except to the extent such restrictions are prohibited by applicable law; or (iv)
access the Services in order to build a competitive product or service or copy any ideas, features,
functions, or graphics of the Services.

3.2 Enforcement. We reserve the right (but have no obligation) to investigate and/or take appropriate action
against you in our sole discretion if you engage in Prohibited Activities or violate any other provision of
this Agreement or otherwise create liability for us or any other person. Such action may include, in our
sole and absolute discretion, terminating your Account in accordance with Section 9, reporting you to
law enforcement authorities without providing any notice of you about any such report and confiscating
any balance remaining in an Account which has been terminated.

4. THIRD-PARTY PRODUCTS AND SERVICES; OTHER USERS

4.1 Third-Party Services. You acknowledge that the Service will enable or assist you to access, interact
with, and/or purchase services from several supported platforms and other third parties via third-party
websites or applications (collectively, “Third-Party Services”). Such Third-Party Services are not
under the control of WazirX, WazirX does not review, approve, monitor, endorse, warrant, or make any
representations with respect to Third-Party Services and is not responsible for any Third-Party Services.
You use all Third-Party Services at your own risk, and should apply a suitable level of caution and
discretion in doing so. Any use of Third-Party Services is governed solely by the terms and conditions
of such Third-Party Services and any contract entered into, or any transaction completed via any Third-
Party Services, is between you and the relevant third party, and not with WazirX. You shall comply in
all respects with all applicable terms of the Third-Party Services that you access or subscribe to in
connection with the Services. If at any time any Third-Party Services cease to make their programs
available to us on reasonable terms, we may cease to provide such features to you without entitling you
to refund, credit, or other compensation.
 43

4.2 Other Users. We do not guarantee the identity of any User or other party or ensure that a buyer or seller
is authorized to complete a transaction or will complete a transaction. Your interactions with other Users
are solely between you and such Users. You agree that WazirX will not be responsible for any loss or
damage incurred as the result of any such interactions. If there is a dispute between you and any User,
we are under no obligation to become involved.

4.3 Release. You hereby release and forever discharge WazirX (and our officers, employees, agents,
successors, and assigns) from, and hereby waive and relinquish, each and every past, present and future
dispute, claim, controversy, demand, right, obligation, liability, action and cause of action of every kind
and nature (including personal injuries, death, and property damage), that has arisen or arises directly or
indirectly out of, or that relates directly or indirectly to, the Services (including any interactions with, or
act or omission of, other Users or any Third-Party Products and Services).

5. SERVICES OFFERED AND OPERATED BY BINANCE

Only the following Services are offered and operated by Binance.

5.1 Supported Cryptocurrencies. The WazirX wallet allows you to send, receive and store cryptocurrency
(together, “Wallet Transactions”). The WazirX wallet is only available in relation to the
cryptocurrencies that WazirX, in its sole discretion, decides to support (“Supported Cryptocurrency”
or “Supported Cryptocurrencies”). Information about the Supported Cryptocurrencies can be found
on the FAQ page on the WazirX website. The Supported Cryptocurrencies may change from time to
time. Under no circumstances should you attempt to carry out a WazirX Wallet Transaction in relation
to a cryptocurrency other than a Supported Cryptocurrency.

5.2 Transaction instructions. WazirX will process Wallet Transactions according to your instructions. You
accept and agree that:

(a) WazirX does not guarantee the identity of any user, receiver, or other party to a WazirX Wallet
Transaction. You are solely responsible for ensuring all transaction details are correct, and you
should carefully verify all transaction information prior to submitting transaction instructions to
WazirX;
(b) WazirX does not have any control over, or any liability in relation to, the delivery, quality or any
other aspect of any goods or services that you may buy from or sell to any third party. WazirX
shall not be responsible for, and will take no action in relation to, ensuring that any buyer or seller
you transact with using your WazirX wallet completes the relevant transaction or has the requisite
authority to do so;
(c) (i) if you send Supported Cryptocurrency using the WazirX wallet, you shall send such Supported
Cryptocurrency only to another blockchain wallet owned by you; or (ii) if you send Supported
Cryptocurrency using the WazirX wallet to a third party, you shall not receive any consideration
for such transfer; and,
(d) without prejudice to the generality of this Agreement, you will strictly comply with the Foreign
Exchange Management Act, 1999 and Income Tax Act, 1961 in connection with all Wallet
Transactions.

5.3 Receiving cryptocurrency. You may receive Supported Cryptocurrency into your WazirX wallet by
providing the sender with a receive address generated in your WazirX wallet. Your WazirX wallet will
only be credited with Supported Cryptocurrency sent to a receive address generated through your
WazirX wallet and associated with that Supported Cryptocurrency. For example, your WazirX wallet
will be credited with ETH when it is sent to an ETH receive address generated through your WazirX
wallet. Without prejudice to the generality of this Agreement, you will strictly comply with the Foreign
Exchange Management Act, 1999 and Income Tax Act, 1961 in connection with all Wallet Transactions.

5.4 Fiat Currency P2P (peer-to-peer) transactions. WazirX allows you to use fiat currency funds solely
in exchange for certain Supported Cryptocurrencies and with other WazirX Users in so-called “P2P
 44

transactions.” In a P2P transaction, WazirX holds the cryptocurrency in escrow between the two
counterparties until payment in fiat currency funds between the buyer and seller Users has been
confirmed. Such Supported Cryptocurrency is released as soon as payment is confirmed. WazirX does
not take custody or facilitate transfer of the fiat currency funds in this model, and the transfer of the fiat
currency funds is solely between Users without any responsibility or liability of WazirX in this
connection. Without prejudice to the foregoing, you hereby grant WazirX the right to resolve issues and
disputes among Users in its sole discretion.
5.5 Trading between Supported Cryptocurrencies. WazirX allows you to trade with other Users between
various Supported Cryptocurrencies (e.g., BTC-ETH, BTC-LTC etc.).

5.6 Sharing User Information. In the course of processing a Wallet Transactions, WazirX may be required
to share your user information with other contractual third parties, or as required under applicable laws
or demanded upon a lawful request by any governmental authority. You hereby irrevocably grant full
permission and authority for WazirX to share this information with such contractual third parties, or as
required under applicable laws or demanded upon a lawful request by any governmental authority, and
release WazirX from any liability, error, mistake, or negligence related thereto.

5.7 Trade Corrections. You acknowledge and agree that WazirX may correct, reverse or cancel, in its sole
discretion, any order, trade, transfer, or other transaction or activity with respect to which WazirX has
discovered that there was an error or abnormality, whether such error or abnormality was caused by you,
WazirX or a third party or due to technical issues, system issues, software failure or otherwise. WazirX
provides no guarantee or warranty that any such attempt will be successful and will have no
responsibility or liability for such error(s) or any correction attempt(s).

6. SERVICES OFFERED AND OPERATED BY ZANMAI

Only the following Services are offered and operated by Zanmai.

Zanmai enables Users to trade with each other in trading pairs involving Indian Rupees (INR) on the one hand, and
Supported Cryptocurrency on the other hand e.g., INR-BTC, INR-ETH. Such enabling of trades is on a non-P2P basis
only ( as P2P transactions are offered and operated by Binance (as described under Clause 5.4 above).

Terms applicable to Indian Resident Users

In non-P2P transactions, Users resident in India (as defined under the Foreign Exchange Management Act, 1999) add
to their INR balance by depositing Indian Rupees from their registered bank account / payment instrument to Zanmai’s
or its partners’ bank account using regulated banking and payment channels, and can redeem their INR balance to their
bank accounts / payment instrument by placing a withdrawal request to Zanmai, upon which request Zanmai will
transfer the INR balance amount to the Users’ registered bank account / payment instrument, using regulated banking
and payment channels, subject to Know Your Customer and other safeguards carried out in Zanmai’s sole discretion,
and subject to withdrawal limits published on the website / mobile application from time to time. In this model, Zanmai
merely acts as a duly appointed agent of the User to whom the payment is due, and does not operate a payment system.
You hereby duly appoint Zanmai as your agent for this purpose.

Terms applicable to Non-Indian Resident Users

In all circumstances, Users not resident in India (as defined under the Foreign Exchange Management Act, 1999) shall
not use Zanmai’s Services to trade between Indian Rupee (INR) and Supported Cryptocurrencies.

7. FEES AND TAXES.

7.1 General. You agree to pay WazirX the fees set forth at https://wazirx.com/fees which may be updated
from time to time in our sole discretion. Any such updated fees will apply prospectively to any trades or
other transactions that take place following the effective date of such updated fees. You authorize
 45

WazirX to remove any amounts from your Account for any applicable fees owed by you under this
Agreement

7.2 Withdrawal / Send fees. You may be charged a fee to send or withdraw a Supported Cryptocurrency
from your WazirX wallet. We currently do not charge fees to deposit or receive Supported
Cryptocurrency into your WazirX wallet.
7.3 Service fees. WazirX applies a Maker / Taker fee structure for customers who trade Supported
Cryptocurrency using the Services. Please consult the page set forth at https://wazirx.com/fees for further
information on applicable Maker and Taker fees. WazirX will, at the time of any transaction on the
WazirX Exchange, notify you of any fees that will apply to the transaction. By proceeding with any
transaction, you accept and agree to the applicable fees. Such fees will also be displayed in your
transaction history upon completion of the transaction.

7.4 Taxes. All fees paid by you shall be made free and clear of, and without reduction for, any and all taxes,
except any required withholding of taxes pursuant to applicable law or on account of any Goods and
Services Tax to the extent applicable. In case where you withhold taxes pursuant to applicable law, you
shall furnish to us a statement detailing such withholding and deposit of withheld taxes.

7.5 Withholding taxes. You hereby authorize WazirX to withhold tax and deposit on your behalf in
accordance with this Clause with effect from July 1, 2022. Unless otherwise specified in this Agreement,
WazirX will withhold tax at rate of 1% (or at such rate(s) as specified under law) of the total order value
as per transactions undertaken by you in Supported Cryptocurrencies. For the purpose of this Clause,
you will be presumed to be an Indian resident if you have provided an Indian address at time of Account
creation, unless such information is updated subsequently in accordance with Clause 1.2. In case where
WazirX withholds tax, WazirX shall provide you with evidence of such withholding as per the statutory
requirements. You would be solely responsible for ascertaining the total volume of relevant transactions
carried out by you and claim exemption(s), if any, from tax authorities. WazirX shall not be responsible
in any manner whatsoever for the same.

8. CONTESTS. We may from time to time offer you the ability to participate in contests of skill (“Contest” or
“Contests”). If you choose to participate in any Contests, you accept and agree to be bound and abide by the
applicable Contest terms and conditions which will be published on the WazirX website from time to time and
incorporated herein by reference (the “Contest Terms”). WazirX reserves the right to modify the Contest
Terms or discontinue any contests at any time for any reason, including but not limited to product availability,
pricing issues, reduced demand. Prizes, discounts and special pricing may be changed or substituted at any
time without prior notice. Taxes on any prize or award are the sole responsibility of the recipient. We have the
right to withhold tax as may be applicable at applicable rates on the winnings in Contest. In such a case, we
will provide you with evidence of such withholding as per prescribed timelines.

9. OTHER REWARDS. You may receive or be entitled to receive crypto-currency as airdrops or on

redemption of coupons or campaign rewards or referral rewards. You hereby declare that you have not paid
any consideration, either in kind or otherwise, for receipt of these rewards. You hereby also agree that you are
solely responsible for paying any taxes and / or complying with tax obligations which may be applicable
pursuant to receipt of such rewards by you.

10. SUSPENSION, TERMINATION, AND CANCELLATION.

10.1 General. This Agreement will continue to apply to you until terminated by either you or WazirX. Any
provision of this Agreement which, either by its terms or to give effect to its meaning, must survive, and
such other provisions which expressly, or by their nature, are intended to survive termination shall
survive the expiration or termination of this Agreement.

10.2 Suspension, Termination. We may terminate your Account or suspend your access to the Services at
any time and with immediate effect for any reason or no reason, in our sole and absolute discretion. We
 46

may decline to process any deposit or withdrawal without prior notice and may limit or suspend your
use of one or more Services at any time, in our sole discretion. For example, we may, in our sole
discretion, not process, withhold, suspend, pause, or hold the deposits or withdrawals if we believe the
transaction is suspicious, may involve fraud or misconduct, violates applicable laws, or violates the terms
of this Agreement. If you have a balance remaining in an Account which has been suspended, we may
freeze such balance for so long as the Account is suspended. If the Account is terminated due to fraud,
violation of law, or violation of this Agreement, WazirX may, in its discretion, confiscate any balance
remaining in the Account and deliver it to any applicable government, law enforcement, or other
authorities where circumstances warrant.

10.3 Cancellation. You may cancel your Account at any time by withdrawing all balances and sending us a
message through the contact page requesting the cancellation of your Account. Upon termination of this
Agreement and your Account, you remain liable for all transactions made while the Account was open.

11. DISCLAIMERS

THE SERVICES ARE PROVIDED ON AN “AS-IS” AND “AS AVAILABLE” BASIS, AND WAZIRX
EXPRESSLY DISCLAIMS ANY AND ALL WARRANTIES AND CONDITIONS OF ANY KIND,
WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING ALL WARRANTIES OR
CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, QUIET
ENJOYMENT, ACCURACY, OR NON-INFRINGEMENT. WE (AND OUR SUPPLIERS) MAKE NO
WARRANTY THAT THE SERVICES WILL MEET YOUR REQUIREMENTS, WILL BE AVAILABLE ON
AN UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE BASIS, OR WILL BE ACCURATE,
RELIABLE, FREE OF VIRUSES OR OTHER HARMFUL CODE, COMPLETE, LEGAL, OR SAFE. IF
APPLICABLE LAW REQUIRES ANY WARRANTIES WITH RESPECT TO THE SITE, ALL SUCH
WARRANTIES ARE LIMITED IN DURATION TO NINETY (90) DAYS FROM THE DATE OF FIRST
USE. WAZIRX DISCLAIMS ANY AND ALL RESPONSIBILITY OR LIABILITY IN RELATION TO THE
CONTENT MADE AVAILABLE THROUGH THE SERVICES, INCLUDING THE CUSTOMER
CONTENT, OR ANY CONTENT OR SERVICES PROVIDED BY THIRD PARTIES. WAZIRX DOES NOT
CONTROL OR VET CUSTOMER CONTENT AND IS NOT RESPONSIBLE FOR WHAT USERS POST,
TRANSMIT, OR SHARE ON OR THROUGH THE SERVICES. WAZIRX IS NOT RESPONSIBLE OR
LIABLE IN ANY MANNER FOR ANY THIRD-PARTY SERVICES

ASSOCIATED WITH OR UTILIZED IN CONNECTION WITH THE SERVICES, INCLUDING THE

FAILURE OF ANY SUCH THIRD-PARTY SERVICES OR SUPPORTED PLATFORMS.

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO THE

ABOVE EXCLUSION MAY NOT APPLY TO YOU. SOME JURISDICTIONS DO NOT ALLOW
LIMITATIONS ON HOW LONG AN IMPLIED WARRANTY LASTS, SO THE ABOVE LIMITATION
MAY NOT APPLY TO YOU.

12. INDEMNIFICATION. You agree to indemnify and hold WazirX (and its officers, employees, and agents)
harmless, including costs and attorneys’ fees, from any claim or demand made by any third party due to or
arising out of (a) your use of the Services, (b) your violation of this Agreement, (c) your violation of
applicable laws or regulations, or (d) Third-Party Services. WazirX reserves the right, at your expense, to
assume the exclusive defense and control of any matter for which you are required to indemnify us, and you
agree to cooperate with our defense of these claims. You agree not to settle any matter without the prior
written consent of WazirX. WazirX will use reasonable efforts to notify you of any such claim, action or
proceeding upon becoming aware of it.

13. LIMITATION ON LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL WAZIRX,

ITS AFFILIATES AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS,
 47

EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS OR CONTRACTORS BE

LIABLE FOR ANY INCIDENTAL, INDIRECT, SPECIAL, PUNITIVE, CONSEQUENTIAL OR SIMILAR
DAMAGES OR LIABILITIES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, DAMAGES
FOR LOSS OF DATA, INFORMATION, REVENUE, PROFITS OR OTHER BUSINESS OR FINANCIAL
BENEFIT) ARISING OUT OF OR IN CONNECTION WITH THE SERVICES, ANY PERFORMANCE OR
NON-PERFORMANCE OF THE SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM
PROVIDED BY OR ON BEHALF OF WAZIRX AND ITS AFFILIATES, WHETHER UNDER CONTRACT,
STATUTE, STRICT LIABILITY OR OTHER THEORY EVEN IF WAZIRX HAS BEEN ADVISED OF THE
POSSIBILITY OF SUCH DAMAGES EXCEPT TO THE EXTENT OF A FINAL JUDICIAL
DETERMINATION THAT SUCH DAMAGES WERE A RESULT OF WAZIRX’S GROSS NEGLIGENCE,
FRAUD, WILLFUL MISCONDUCT OR INTENTIONAL VIOLATION OF LAW. SOME JURISDICTIONS
DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL
DAMAGES, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU.
NOTWITHSTANDING THE FOREGOING, IN NO EVENT WILL THE LIABILITY OF WAZIRX, ITS
AFFILIATES AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS,
EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS OR CONTRACTORS
ARISING OUT OF OR IN CONNECTION THE SERVICES, ANY PERFORMANCE OR NON-
PERFORMANCE OF THE SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM
PROVIDED BY OR ON BEHALF OF WAZIRX OR ITS AFFILIATES WHETHER UNDER CONTRACT,
STATUTE, STRICT LIABILITY OR OTHER THEORY, EXCEED THE AMOUNT OF THE FEES PAID
BY YOU TO WAZIRX UNDER THIS AGREEMENT IN THE TWELVE-MONTH PERIOD
IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM FOR LIABILITY.

14. GENERAL

14.1 Dispute Resolution. Please read this Arbitration Agreement carefully. It is part of your contract with
WazirX and affects your rights. It contains procedures for MANDATORY BINDING ARBITRATION
AND A CLASS ACTION WAIVER.

(a) Any dispute, controversy or claim arising out of or relating to this contract, or the breach,
termination or invalidity thereof, shall be settled by arbitration as follows:

(i) In the case of disputes, controversies or claims involving Binance: You and Binance
agree to resolve any claims relating to this Agreement (including any question regarding
their existence, validity, termination, or any services or products provided and any
representations made by us) through final and binding arbitration, except as set forth
under Exceptions to Agreement to Arbitrate below. You agree to first give us an
opportunity to resolve any claims by contacting us on our website / mobile / desktop
applications. If we are not able to resolve your claims within 60 days of receiving the
notice, you may seek relief through arbitration or in the Small Claims Tribunals of
Singapore (“SCT”), as set forth below.

Either you or Binance may submit a dispute (after having made good faith efforts to
resolve such dispute) for final and binding resolution by arbitration under the arbitration
rules of the Singapore International Arbitration Centre (“SIAC”), which are deemed to be
incorporated into these Terms by reference. The arbitration tribunal shall consist of a sole
arbitrator to be appointed by the President of SIAC. The language of the arbitration
hearings shall be English and the seat, or legal place, of arbitration shall be Singapore.
JUDGMENT ON ANY ARBITRAL AWARD MAY BE GIVEN IN ANY COURT
HAVING JURISDICTION OVER THE PARTY (OR OVER THE ASSETS OF THE
PARTY) AGAINST WHOM SUCH AN AWARD IS RENDERED.

Exceptions. Either party may instead choose to assert the claims in the SCT if the claims
fall within the jurisdiction of the SCT, and either party may seek injunctive relief or other
urgent equitable relief in a court of competent jurisdiction. However, for the avoidance of
 48

doubt, where the claims fall outside of the jurisdiction of the SCT, the claims will be
referred to and finally resolved by SIAC arbitration.

(ii) In the case of disputes, controversies or claims involving Zanmai, you and Zanmai agree
to resolve any claims relating to this Agreement (including any question regarding their
existence, validity, termination, or any services or products provided and any
representations made by us) through final and binding arbitration. You agree to first give
us an opportunity to resolve any claims by contacting us on our website / mobile /
desktop applications. If we are not able to resolve your claims within 60 days of
receiving the notice, you may seek relief through arbitration as set forth below.

Either you or Zanmai may submit a dispute (after having made good faith efforts to resolve
such dispute) for final and binding resolution by arbitration under the arbitration rules of
the Singapore International Arbitration Centre (“SIAC”), which are deemed to be
incorporated into these Terms by reference, read with the Indian Arbitration and
Conciliation Act, 1996. The arbitration tribunal shall consist of a sole arbitrator to be
appointed by the President of SIAC. The language of the arbitration hearings shall be
English and the seat of arbitration shall be Singapore.

(b) Waiver of Jury Trial. THE PARTIES HEREBY WAIVE THEIR RIGHTS TO GO TO COURT
AND HAVE A TRIAL IN FRONT OF A JUDGE OR A JURY, as applicable, instead electing
that all claims and disputes shall be resolved by arbitration under this Arbitration Agreement.
Arbitration procedures are typically more limited, more efficient and less costly than rules
applicable in a court and are subject to very limited review by a court. In the event any litigation
should arise between you and WazirX in any state or federal court in a suit to vacate or enforce
an arbitration award or otherwise, YOU AND WAZIRX WAIVE ALL RIGHTS TO A JURY
TRIAL, instead electing that the dispute be resolved by a judge.

(c) Waiver of Class or Consolidated Actions. ALL CLAIMS AND DISPUTES WITHIN THE
SCOPE OF THIS ARBITRATION AGREEMENT MUST BE ARBITRATED OR
LITIGATED ON AN INDIVIDUAL BASIS AND NOT ON A CLASS BASIS, AND CLAIMS
OF MORE THAN ONE CUSTOMER OR USER CANNOT BE ARBITRATED OR
LITIGATED JOINTLY OR CONSOLIDATED WITH THOSE OF ANY OTHER
CUSTOMER OR USER.

(d) Confidentiality. All aspects of the arbitration proceeding, including but not limited to the award
of the arbitrator and compliance therewith, shall be strictly confidential. The parties agree to
maintain confidentiality unless otherwise required by law. This paragraph shall not prevent a
party from submitting to a court of law any information necessary to enforce this Agreement, to
enforce an arbitration award, or to seek injunctive or equitable relief.

(e) Severability. If any part or parts of this Arbitration Agreement are found under the law to be
invalid or unenforceable by a court of competent jurisdiction, then such specific part or parts
shall be of no force and effect and shall be severed and the remainder of the Agreement shall
continue in full force and effect.

(f) Right to Waive. Any or all of the rights and limitations set forth in this Arbitration Agreement
may be waived by the party against whom the claim is asserted. Such waiver shall not waive or
affect any other portion of this Arbitration Agreement.

(g) Survival of Agreement. This Arbitration Agreement will survive the termination of your
relationship with WazirX.

(h) Emergency Equitable Relief. Notwithstanding the foregoing, either party may seek emergency
equitable relief before a court of competent jurisdiction in order to maintain the status quo
 49

pending arbitration. A request for interim measures shall not be deemed a waiver of any other
rights or obligations under this Arbitration Agreement.

(i) Claims Not Subject to Arbitration. Notwithstanding the foregoing, claims of defamation and
infringement or misappropriation of the other party’s patent, copyright, trademark or trade
secrets shall not be subject to this Arbitration Agreement.

14.2 Applicable Law. The laws of India excluding its choice of law provisions, will govern these Terms and
any dispute that arises between you and Zanmai.

14.3 Force Majeure. WazirX is not responsible for damages caused by delay or failure to perform
undertakings under this Agreement when the delay or failure is due to fires; strikes; floods; power
outages or failures; acts of God or the state’s enemies; lawful acts of public authorities; any and all
market movements, shifts, or volatility; computer, server, or Internet malfunctions; security breaches or
cyberattacks; criminal acts; delays or defaults caused by common carriers; acts or omissions of third
parties; or, any other delays, defaults, failures or interruptions that cannot reasonably be foreseen or
provided against. In the event of force majeure, WazirX is excused from any and all performance
obligations and this Agreement shall be fully and conclusively at an end.

14.4 Electronic Communications. The communications between you and WazirX use electronic means,
whether you use the Site or send us emails, or whether WazirX posts notices on the Site or communicates
with you via email. For contractual purposes, you (a) consent to receive communications from WazirX
in an electronic form; and (b) agree that all terms and conditions, agreements, notices, disclosures, and
other communications that WazirX provides to you electronically satisfy any legal requirement that such
communications would satisfy if it were be in a hardcopy writing. The foregoing does not affect your
non-waivable rights.

14.5 Entire Agreement. This Agreement, together with WazirX’s Privacy Policy, constitute the entire
agreement between you and us regarding the use of the Services. Our failure to exercise or enforce any
right or provision of this Agreement shall not operate as a waiver of such right or provision. The section
titles in this Agreement are for convenience only and have no legal or contractual effect. The word
“including” means “including without limitation”. If any provision of this Agreement is, for any reason,
held to be invalid or unenforceable, the other provisions of this Agreement will be unimpaired and the
invalid or unenforceable provision will be deemed modified so that it is valid and enforceable to the
maximum extent permitted by law. Your relationship to WazirX is that of an independent contractor,
and neither party is an agent or partner of the other. This Agreement, and your rights and obligations
herein, may not be assigned, subcontracted, delegated, or otherwise transferred by you without WazirX’s
prior written consent, and any attempted assignment, subcontract, delegation, or transfer in violation of
the foregoing will be null and void. WazirX may freely assign this Agreement. The terms and conditions
set forth in this Agreement shall be binding upon assignees.
50
 51

From: investor@wazirx.com on behalf of < >

Sent: Saturday, 24 August 2024 8:19 pm
To: WazirX
Subject: Re: Regarding announcement dated 23 August 2024

Dear WazirX Team.

1. Yes - you should definitely redact my name.

2. I confirm my support for a moratorium of 6 months that will provide the WazirX platform the time and
space needed to deliver an optimal outcome for users of the platform

I would advise you to allow 25 % crypto withdrawals right away.

I would advise you to minimize impact to BTC investors

All the best in recovering the crypto funds.

On Sat, Aug 24, 2024 at 2:10 PM WazirX <investor@wazirx.com> wrote:

Dear ,

On behalf of the WazirX platform I am reaching out to you in respect of the announcement dated 23
August 2024 which may be accessed at the following https://wazirx.com/blog/announcement-2/

Moratorium Application Disclosure Requirements

As detailed in the announcement, we will shortly be filing a moratorium application with the Singapore
High Court, which will be an essential step in the platform’s plan to deliver an optimal resolution for users
with cryptocurrency balances.

Under Singapore law, a moratorium application will need to be accompanied by a list of the top creditors,
which will set out names and claims (denominated in USD equivalent).

As a user with significant cryptocurrency balances on the WazirX platform, your name and claim will be
included in such a list. If you would like us to redact your name, please let us know in writing by 25 August
2024, 11.59pm IST and we will at first instance redact your name from the list.

Please note however that the Court may subsequently require full disclosure of your name.

Request for Support

We would also like to take this opportunity to request your support for a moratorium which will be
important to ensure that the WazirX platform gets the time and breathing space needed to deliver an
optimal resolution for users of the platform.

It would be very helpful if you could provide the following wording in writing to demonstrate your support
for the moratorium application, which will be provided (in redacted form) to Court as evidence of support
for the moratorium:

I confirm my support for a moratorium that will provide the WazirX platform the time and space needed to
deliver an optimal outcome for users of the platform.
1
 52
Next Steps

Please advise if you would like your name to be redacted from the moratorium application and provide any
written support for the moratorium via return email by 25 August 2024, 11.59pm IST.

We will do our best to cater to emails received after this time, subject to the timing of the filing of the
moratorium application.

We appreciate that you may have some questions on the announcement and the points above – we are
available for a call this weekend (24 – 25 August 2024) to clarify any queries you may have. You can drop
us an email at investor@wazirx.com and we will schedule a call to answer your queries.

Thanks!

The content of this email and any files transmitted with it are confidential and intended for the recipient
specified in the message only. It is strictly forbidden to share any part of this message with any third
party, without a written consent of the sender. Please notify the sender immediately if you have
received this email by mistake and delete this email from your system. If you are not the intended
recipient, you are notified that disclosing, copying, distributing or taking any action in reliance on the
contents of this information is strictly prohibited.

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