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UNVEILING THE FUTURE OF DIGITAL ASSET MANAGEMENT

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EMPOWERING YOU WITH TRUSTED CRYPTO SOLUTIONS

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CRYPTO TRADING CAPABILITIES TO POWER YOUR APP

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GLOBAL PAYMENTS PLATFORM FOR TRANSFERRING FIAT AND DIGITAL ASSETS

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DISCLOSURES


RISKS ASSOCIATED WITH CRYPTOCURRENCY

Cryptocurrencies are not legal tender in the United States and many question
whether they have intrinsic value. Although cryptocurrencies are often
exchangeable for various fiat currencies, unlike fiat currencies, cryptocurrency
are not backed by any government or central bank and do not constitute legal
tender. The price of many cryptocurrencies is based on the agreement of the
parties to a transaction, which may or may not be based on the market value of
the cryptocurrency at the time of the transaction.


PRICE VOLATILITY

The price of a cryptocurrency is based on the perceived value of the
cryptocurrency and subject to changes in sentiment, which make these products
highly volatile. Certain cryptocurrency have experienced daily price volatility
of more than 20%. The extreme price volatility of cryptocurrency and the
possibility of rapid and substantial price movements, which could result in
significant losses. It is possible that the market for a given cryptocurrency
can collapse altogether.


VALUATION AND LIQUIDITY

Cryptocurrency can be traded through privately negotiated transactions and
through numerous cryptocurrency exchanges and intermediaries around the world.
The lack of a centralized pricing source poses a variety of valuation
challenges. Generally accepted auditing methods for cryptocurrency do not exist
and cryptocurrency platforms do not have consistent methods for auditing their
holdings and some do not have audits at all. In addition, the dispersed
liquidity may pose challenges for market participants trying to exit a position,
particularly during periods of stress. In some cases, you will likely have to
accept a lower price for the amount of your cryptocurrency in order to redeem
your investment.


CYBERSECURITY

The cybersecurity risks of cryptocurrency and related “wallets” or spot
exchanges include hacking vulnerabilities and a risk that publicly distributed
ledgers may not be immutable. A cybersecurity event could result in a
substantial, immediate, and irreversible loss for market participants that trade
cryptocurrency. Even a minor cybersecurity event in a cryptocurrency is likely
to result in downward price pressure on that product and potentially other
cryptocurrency. The price of cryptocurrency may be negatively impacted by future
legal and regulatory developments, which may make cryptocurrency less valuable,
adversely impact the ability of cryptocurrency-related investment products to
operate and/or materially decrease the value of an investment. Consequently, you
may incur losses due to software or hardware failures and system failures.


OPAQUE SPOT MARKET

Cryptocurrency balances are generally maintained as an address on the blockchain
and are accessed through private keys, which may be held by a market participant
or a custodian. Although cryptocurrency transactions are typically publicly
available on a blockchain or distributed ledger, the public address does not
identify the controller, owner or holder of the private key. Unlike bank and
brokerage accounts, some cryptocurrency exchanges and custodians that hold
cryptocurrency do not always identify the owner. Trading by employees of the
platforms and the platform themselves are often not adequately restricted to
prevent trading abuses.


CRYPTOCURRENCY EXCHANGES, INTERMEDIARIES AND CUSTODIANS

Cryptocurrency exchanges, as well as other intermediaries, custodians and
vendors used to facilitate cryptocurrency transactions, are relatively new and
largely unregulated in both the United States and many foreign jurisdictions.
Cryptocurrency exchanges generally purchase cryptocurrency for their own account
on the public ledger and allocate positions to customers through internal
bookkeeping entries while maintaining exclusive control of the private keys.
Under this structure, cryptocurrency exchanges collect large amounts of customer
funds for the purpose of buying and holding cryptocurrency on behalf of their
customers. The opaque underlying spot market and lack of regulatory oversight
creates a risk that a cryptocurrency exchange may not hold sufficient
cryptocurrency and funds to satisfy its obligations and that such deficiency may
not be easily identified or discovered.

In addition to a higher level of operational risk than regulated futures or
securities exchanges, cryptocurrency exchanges can experience volatile market
movements, flash crashes, fraud, various forms of market manipulation, theft,
transaction processing delays and other cybersecurity risks. Trading in
cryptocurrency may be halted by the various trading venues due to unusual
trading activity, outages, or other problems with a cryptocurrency platform. If
Axos Digital Assets experiences such technical difficulties, those difficulties
could prevent you from accessing the cryptocurrency in your Axos Digital Asset
Account. Axos Digital Assets may not have sufficient financial coverage through
bonds, insurance or other products to repay your losses.


OPERATIONAL RISK

Many cryptocurrency exchanges have experienced significant outages, downtime and
transaction processing delays and may have a higher level of operational risk
than regulated securities exchanges. As a result, your transaction may be
delayed through no fault of your own, which may cause you to pay a higher price
for a cryptocurrency or sell for a lower price due to these processing delays.


REGULATORY LANDSCAPE

Cryptocurrency currently face an uncertain regulatory landscape in the United
States and many foreign jurisdictions. In the United States, cryptocurrency is
not subject to federal regulatory oversight but may be regulated by one or more
state regulatory bodies. One or more jurisdictions may, in the future, adopt
laws, regulations or directives that affect cryptocurrency networks and their
users. Such laws, regulations or directives may impact the price of your
cryptocurrency and/or its acceptance by users, merchants, and service providers.


TECHNOLOGY

The relatively new and rapidly evolving technology underlying cryptocurrency
introduces unique risks. For example, a unique private key is required to
access, use or transfer a cryptocurrency on a blockchain or distributed ledger.
The loss, theft or destruction of a private key may result in an irreversible
loss. Keep in mind, neither the Securities Investor Protection Corporation nor
the Federal Deposit Insurance Corporation insure your cryptocurrency product.
Existing insurance products are inadequate to cover potential losses if an
exchange fails and/or digital wallets are hacked. Axos Digital Assets may not
have sufficient financial coverage through bonds, insurance or other products to
repay your losses.


TRANSACTION FEES

Many cryptocurrencies allow market participants to offer miners (i.e., parties
that process transactions and record them on a blockchain or distributed ledger)
a fee. While not mandatory, a fee is generally necessary to ensure that a
transaction is promptly recorded on a blockchain or distributed ledger. The
amounts of these fees are subject to market forces and it is possible that the
fees could increase substantially during a period of stress. In addition,
cryptocurrency exchanges, wallet providers and other custodians may charge high
fees relative to custodians in a brokerage account. Please ensure that you have
received and reviewed the fees schedule provided prior to making a transaction.


TAX

The tax treatment of cryptocurrency is relatively new and subject to change. You
may be able to use this account statement to inform your likely tax obligations.
For final tax obligations, please consult your tax advisor concerning the tax
consequences of cryptocurrency-related investment products.


THE FOREGOING RISKS ARE NOT A COMPLETE EXPLANATION OF THE RISKS INVOLVED IN A
CRYPTOCURRENCY INVESTMENT. PLEASE MAKE SURE YOU HAVE RESEARCHED ALL INFORMATION
ABOUT THE SPECIFIC CRYPTOCURRENCY BEFORE MAKING A TRANSACTION.


FOR MORE INFORMATION, WE ENCOURAGE YOU TO REVIEW THE VARIOUS NOTICES REGARDING
CRYPTOCURRENCY PROVIDED BY SEVERAL REGULATORS:

 * Securities and Exchange Commission – Understanding the Risks of Virtual
   Currency Trading
 * Financial Regulatory Authority – Bitcoin: More than a Bit Risky
 * CFTC Customer Advisory – Understanding the Risks of Virtual Currency Trading
 * CFTC Customer Advisory – Beware Virtual Currency Pump-and-Dump Schemes


PRIVACY/BCP DISCLOSURE.

Axos Digital Assets collects important and confidential information about you at
the time you open your account. Axos Digital Assets protects this information in
accordance with its privacy policy. Axos Digital Assets has also developed
contingency plans in the event of a business disruption or other emergency. In
the event of an emergency, you may contact Axos Digital Assets at 888-585-4965.


AXPAY TERMS OF USE

AXPay is a service provided by Axos Digital Assets LLC (“Axos Digital” or
“ADA”). Your use of AXPay is subject to these Terms of Use at all times. If you
do not accept these Terms of Use, you must immediately terminate your access to
and use AXPay. Your access to and use of AXPay is governed by and subject to (a)
these Terms of Use, and (b) the agreement(s) entered into between the entity on
behalf of which you are accessing AXPay (the “Company”) and ADA, including
without limitation the AXPay User Agreement. By continuing to access and/or use
AXPay:

 1. You represent, warrant, and covenant to ADA that:
    1. You are an employee or authorized agent of the Company, and are accessing
       AXPay on behalf of the Company and at the Company’s direction.
    2. The Company has designated you as an authorized user of AXPay.
    3. You will only use AXPay for transactions that have been validly
       authorized by the Company, and any transactions you make using AXPay are
       authorized by the Company.
    4. You are responsible for maintaining the confidentiality of your log-in
       credentials, and agree not to share your ID and password with anyone for
       any reason.
    5. You will immediately notify the Company of any unauthorized use or
       suspected unauthorized use or compromise of your log-in credentials or
       any other breach of the security of AXPay.
 2. You acknowledge and agree that:
    1. Neither ADA nor any of its affiliates shall have any responsibility for
       your use of AXPay on the Company’s behalf.
    2. Except as required by law, ADA shall have no liability to you or the
       Company (i) for any transfers of money or value using AXPay or (ii)
       otherwise in connection with AXPay, including without limitation (a) any
       failure to complete a transaction in the correct amount, (b) any
       unauthorized transaction, or (c) any related losses or damages. Without
       limiting the foregoing, ADA shall not be liable for any typos or
       keystroke errors that you may make when using AXPay.
    3. ADA may limit, restrict, or terminate your or the Company’s access to or
       use of AXPay at any time in its sole absolute discretion and without any
       prior notice
    4. AXPAY IS INTENDED FOR SENDING MONEY TO BUSINESS ASSOCIATES WHOM THE
       COMPANY TRUSTS. YOU SHOULD NOT USE AXPAY TO SEND MONEY TO RECIPIENTS WITH
       WHOM YOU ARE NOT FAMILIAR OR YOU DO NOT TRUST. ADA DOES NOT OFFER REFUNDS
       OR A PROTECTION PROGRAM FOR PAYMENTS MADE THROUGH AXPAY.

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