Terms & Conditions
YieldFi — General Terms and Conditions
Issuer: Block Labs Limited (BVI) (“YieldFi”, the “Issuer”, “we”, “us”, “our”) Governing law: British Virgin Islands (“BVI”) law
IMPORTANT NOTICE
PLEASE READ THESE GENERAL TERMS AND CONDITIONS CAREFULLY. THEY AFFECT YOUR LEGAL RIGHTS AND OBLIGATIONS. INFORMATION MADE AVAILABLE ON OUR WEBSITE OR IN MARKETING MATERIALS IS FOR GENERAL DESCRIPTION ONLY, MAY CHANGE OVER TIME, AND DOES NOT FORM PART OF THESE GENERAL TERMS AND CONDITIONS UNLESS EXPRESSLY INCORPORATED BY REFERENCE.
NO REGULATOR HAS AUTHORISED OR APPROVED THESE GENERAL TERMS AND CONDITIONS OR ANY TOKEN TERMS. DEALING IN TOKENS IS HIGH RISK AND MAY RESULT IN A TOTAL LOSS OF CAPITAL. TOKENS MAY BE RESTRICTED IN TRANSFERABILITY AND MAY BE ILLIQUID. YOU DO NOT BENEFIT FROM ANY STATUTORY COMPENSATION SCHEME OR DEPOSIT PROTECTION IN RELATION TO TOKENS.
IF YOU HAVE NOT DEALT IN CRYPTOASSETS OR TOKENISED PRODUCTS BEFORE, YOU SHOULD SEEK INDEPENDENT PROFESSIONAL ADVICE (LEGAL, TAX, AND FINANCIAL) BEFORE DEALING IN TOKENS. IF YOU DO NOT AGREE TO THESE GENERAL TERMS AND CONDITIONS, DO NOT DEAL IN THE TOKENS. BY DEALING IN TOKENS, YOU CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AND ACCEPTED THESE GENERAL TERMS AND CONDITIONS AND THE APPLICABLE TOKEN TERMS (INCLUDING ANY SCHEDULES AND POLICIES).
1. INTRODUCTION
1.1 These General Terms and Conditions, together with any schedules, policies, and documents incorporated by reference (together, the “General Terms and Conditions” and each a “Condition”), apply to all Tokens issued by the Issuer and must be read together with the token-specific terms for the relevant Token (the “Token Terms”).
1.2 The Token Terms will describe key commercial and operational parameters for the relevant Token (including, where applicable, denomination, settlement currency, fees, minting/redemption rules, eligibility restrictions, and risk disclosures). If there is any conflict between these General Terms and Conditions and the Token Terms, the Token Terms prevail to the extent of the inconsistency.
1.3 Unless stated otherwise, capitalised terms not defined in these General Terms and Conditions have the meanings given in the relevant Token Terms.
1.4 Nature of Tokens (Subordinated Debt Instruments)
All YieldFi-issued Tokens are contractual debt instruments that constitute unsecured, contractually subordinated obligations of the Issuer.
By acquiring Tokens, each Tokenholder becomes a creditor of the Issuer, holding a claim for payment under the terms set out in the Product Documentation. Tokens are not equity, do not confer ownership, governance, voting, or profit-participation rights, and do not represent any legal or beneficial interest in any underlying assets.
Each Token is structured as a subordinated debt obligation, meaning that:
the Tokenholder’s claim is junior to all present and future unsubordinated creditors of the Issuer;
the Tokenholder’s claim ranks senior only to shareholders and equity holders of the Issuer; and
payment obligations are subject to the qualified subordination regime set out in Condition 10.
Tokens are therefore economically and legally comparable to subordinated notes, and should be evaluated accordingly.
2. REPRESENTATIONS, ELIGIBILITY, AND COMPLIANCE
2.1 Authority and capacity. You represent and warrant that:
you are of legal age in your jurisdiction and have full legal capacity to enter into these General Terms and Conditions; and
if you act on behalf of an entity, you have authority to bind that entity, and all references to “you” include that entity.
2.2 Sanctions and restricted persons. You represent and warrant that neither you nor (where applicable) your beneficial owners, directors, officers, authorised persons, or wallets are:
subject to economic or trade sanctions administered or enforced by any governmental authority; or
listed on any prohibited or restricted parties list; or
located, resident, organised, or ordinarily resident in a jurisdiction subject to comprehensive sanctions (or otherwise restricted by Applicable Law), in each case as determined by the Issuer in its discretion acting reasonably.
2.3 Compliance with law. You represent and warrant that you will comply with all Applicable Laws, including those relating to AML/CFT, sanctions, tax, securities/financial promotions, and consumer protection. You will not use Tokens for any unlawful purpose or to facilitate unlawful activity.
2.4 No reliance. You acknowledge that:
we do not provide legal, tax, investment, accounting, or other professional advice; and
you have made your own independent assessment of the Tokens, the risks, and the suitability for your circumstances.
3. INTERPRETATION AND DEFINITIONS
3.1 Interpretation rules. Unless the context requires otherwise:
headings are for convenience only and do not affect interpretation;
words in the singular include the plural and vice versa;
“include”, “including”, “for example” and similar expressions are illustrative and not limiting;
references to statutes or regulations include amendments and replacements;
“person” includes individuals, partnerships, companies, trusts, and other entities.
3.2 Dealing in Tokens. References to “dealing in” or “deal in” Tokens include any activity relating to Tokens or cryptoassets, including buying, subscribing, receiving, holding, transferring, selling, redeeming, staking (if applicable), or otherwise using Tokens.
3.3 Defined terms. In these General Terms and Conditions, unless inconsistent with the context:
“Adverse Regulatory Event” means a material change in the regulatory environment or its interpretation that materially impairs the Issuer’s ability to issue, operate, support, distribute, or comply with Applicable Law in relation to Tokens.
“Adverse Tax Event” means a material change in tax law or interpretation that results in a substantial adverse tax consequence to the Issuer related to issuing, operating, or supporting Tokens.
“Applicable Law(s)” means all laws, statutes, rules, regulations, orders, sanctions, and regulatory requirements applicable to the Parties in connection with Tokens and these General Terms and Conditions (including AML/CFT and sanctions requirements).
“Business Day” means a day on which banks are open for business in the BVI and any relevant settlement systems identified in the Token Terms are operating (as applicable).
“Event of Default” has the meaning given in Condition 17.
“Greenlisted / Greenlisting” means completion of onboarding and satisfaction of KYC/AML Requirements, as confirmed by the Issuer.
“Insolvency Event” has the meaning given in Condition 17.
“Issuer Call Option” means (if specified in the Token Terms) the Issuer’s right to initiate redemption or unwind procedures due to force majeure or events beyond reasonable control, including Adverse Regulatory Events, Adverse Tax Events, war/terrorism, natural disasters, or dissolution/cessation of the Issuer.
“KYC/AML Requirements” means the Issuer’s onboarding, identification, verification, AML/CFT, sanctions screening, and related processes.
“Market Disruption Event” has the meaning given in Condition 6.
“Product Documentation” means these General Terms and Conditions and the applicable Token Terms, together with any schedules and policies incorporated by reference, as amended from time to time in accordance with these General Terms and Conditions.
“Redemption Amount” means the amount payable on redemption in the Settlement Currency calculated under the Token Terms (net of applicable fees and costs).
“Redemption Fees” means the fees specified in the Token Terms.
“Settlement Currency” means the currency or stablecoin(s) in which redemption is settled, as specified in the Token Terms.
“Token(s)” means the digital tokens issued by the Issuer via smart contracts on a supported blockchain network, which constitute debt instruments (contractual claims) against the Issuer as described in the Product Documentation.
“Tokenholder(s)” means the person controlling the private key(s) for a wallet address holding Tokens (subject to Greenlisting where required).
“Underlying” has the meaning given in the Token Terms (if applicable).
“Website” means yield.fi (or such successor domain as notified by the Issuer).
4. KYC/AML REQUIREMENTS AND ONBOARDING (GREENLISTING)
4.1 Greenlisting requirement. To subscribe for, mint, redeem, or otherwise access certain functionality of Tokens, you may be required to successfully complete onboarding and satisfy KYC/AML Requirements. Where Greenlisting is required, the Issuer may treat any non-Greenlisted person as ineligible to mint, redeem, or otherwise access restricted features.
4.2 Information required (individuals). You may be required to provide:
full legal name;
residential address;
date and place of birth;
nationality;
government-issued identification details; and
contact details (including email), and any additional information required for enhanced due diligence.
4.3 Information required (entities). You may be required to provide:
legal name, legal form, and registered office;
registry details (if applicable);
beneficial ownership and control information;
authorised signatories;
constitutional documents (if requested);
contact details (including email), and any additional information required for enhanced due diligence.
4.4 Wallet designation and screening. As part of onboarding, you may be required to designate one or more wallet addresses and provide proof of ownership/control. We may conduct wallet screening and other checks.
4.5 Accuracy and updates. You warrant that all information you provide is complete, accurate, and not misleading. You must promptly notify the Issuer of any changes to onboarding information.
4.6 Verification and third parties. The Issuer may use third-party service providers to verify information and perform screening. The Issuer may accept or reject onboarding at its discretion acting reasonably and in accordance with Applicable Law.
4.7 Status confirmation. We will notify you if onboarding is successful. Upon confirmation, you will be considered Greenlisted (if applicable for the Token).
5. ORDERING, SUBSCRIPTION, AND DELIVERY OF TOKENS
5.1 Wallet requirement. You must use a compatible wallet for the relevant blockchain network(s). You are responsible for maintaining access to your wallet and private keys.
5.2 Subscription process. Tokens may be subscribed for through the Website or other approved channels described in the Token Terms. You must provide required details, including the subscription amount and the wallet address to receive Tokens.
5.3 Payment methods. You must pay the subscription amount using the payment method(s) specified in the Token Terms, which may include (as applicable):
bank transfer in fiat currency to an account specified by the Issuer; and/or
stablecoin transfer to a wallet address specified by the Issuer.
5.4 When payment is due. Unless stated otherwise in the Token Terms, payment is due immediately upon acceptance of your subscription by the Issuer.
5.5 Minting and delivery. Upon confirmed receipt of funds (and subject to Greenlisting where required), the Issuer will mint and deliver Tokens to the wallet address you specified. Token quantity and pricing mechanics are defined in the Token Terms.
5.6 Errors. You are solely responsible for ensuring the accuracy of wallet addresses and payment details. Transfers to incorrect addresses may be irreversible.
6. MARKET DISRUPTION EVENTS
6.1 Definition. A Market Disruption Event occurs if, in respect of the Underlying (where relevant), the price, reference rate, or value necessary for determining Token valuation, minting, redemption, or settlement cannot be determined, published, or made available on a relevant day.
6.2 Postponement. If a Market Disruption Event occurs on a relevant valuation/fixing day, that day may be postponed until the next Business Day on which the disruption no longer exists.
6.3 Issuer determination. If disruption continues, the Issuer may determine the relevant value using its discretion exercised reasonably and consistent with established market practice and the Token Terms.
7. UNDERLYING ILLIQUIDITY
7.1 Definition. Underlying Illiquidity means low or no trading volume, limited market depth, or practical difficulty in buying/selling the Underlying (or hedging/closing relevant positions) within a reasonable time without materially affecting price, or a comparable illiquidity event.
7.2 Effect on calculations. In Underlying Illiquidity conditions, the Issuer may calculate the Redemption Amount using a best-efforts realised execution price (net of costs) rather than a standard reference fixing, where consistent with the Token Terms.
7.3 Delays. Determination and/or payment of the Redemption Amount may be delayed to account for prevailing market conditions and operational constraints.
8. EXERCISE OF RIGHTS; PRIVATE KEYS; ENFORCEMENT
8.1 Recognised Tokenholders. Where Greenlisting is required, the Issuer will recognise only persons who both (i) hold Tokens and (ii) have successfully completed KYC/AML Requirements.
8.2 Private key responsibility. Token functionality (including transfer where enabled, redemption, and other interactions) may require the private key. You acknowledge that loss, theft, compromise, or mismanagement of your private key can result in loss of Tokens. You unilaterally waive claims against the Issuer for losses arising from your wallet security failures.
8.3 Compliance actions. To comply with Applicable Law, regulatory requirements, court orders, sanctions obligations, or law enforcement requests, the Issuer may restrict transfers, freeze functionality, refuse transactions, or take other actions permitted under the Product Documentation, Legal Documents or Applicable Law.
9. REDEMPTION
9.1 How redemption is initiated. Redemption is initiated in accordance with the Token Terms, which may include:
submission of a redemption request through an approved process; and/or
transfer of Tokens to an address specified for redemption initiation (if applicable); and/or
exercise of the Issuer Call Option (if applicable).
9.2 Settlement instructions. If redemption is paid in stablecoins, you must provide a compatible wallet address and ensure you control it. If paid in fiat, you must provide correct bank details. You bear any bank fees and charges; if the Issuer incurs costs, we may deduct them from the Redemption Amount where permitted in the Token Terms.
9.3 Timing. Redemption timing, processing windows, and SLAs are described in the Token Terms and may be impacted by Market Disruption Events, Underlying Illiquidity, compliance checks, and operational constraints.
9.4 Fees and deductions. Redemption Fees and any other deductions are as specified in the Token Terms.
9.5 Eligibility. If Greenlisting applies, redemption may be permitted only for Greenlisted Tokenholders (and may be suspended for those who cease to meet KYC/AML Requirements).
10. Qualified Subordination and Structural Ranking
10.1 Structural intent. The Parties expressly agree that the Tokens are issued as subordinated debt instruments, and that the subordination set out in this Condition is a fundamental economic and legal characteristic of the Tokens.
10.2 Contractual subordination of all Tokenholder claims. All present and future claims of Tokenholders against the Issuer arising under or in connection with the Tokens and the Product Documentation (the “Subordinated Claims”) are contractually subordinated to the claims of all unsubordinated creditors of the Issuer.
Accordingly, in any liquidation, insolvency, administration, restructuring, or similar proceeding affecting the Issuer:
Subordinated Claims shall rank after all unsubordinated creditor claims (including trade creditors, lenders, service providers, tax authorities, and other senior obligations);
Subordinated Claims shall rank pari passu among themselves (unless otherwise stated in the Token Terms); and
Subordinated Claims shall rank ahead only of shareholders and holders of equity instruments of the Issuer.
10.3 No enforcement if it would cause insolvency. Tokenholders may only demand payment or enforce Subordinated Claims to the extent that such payment would not cause the Issuer to become insolvent, illiquid, or over-indebted within the meaning of applicable insolvency principles under BVI law.
If payment of any Subordinated Claim would (in the Issuer’s reasonable assessment) trigger or worsen an insolvency condition, then:
such Subordinated Claim shall be deemed not due and not payable for so long as that condition persists; and
Tokenholders shall have no right to accelerate, enforce, or otherwise pursue such claim during that period.
10.4 Payment prohibition and clawback. If the Issuer makes any payment on a Token in breach of this subordination framework or in violation of applicable insolvency restrictions, the Issuer may require the recipient Tokenholder to repay such amount, to the extent permitted under applicable law.
10.5 No security; structurally unsecured. Unless expressly stated in the Token Terms, Tokens constitute unsecured subordinated obligations of the Issuer. No collateral, guarantee, reserve, or third-party security is provided in respect of Tokenholder claims.
10.6 Commercial understanding. Each Tokenholder acknowledges that:
they are investing in a subordinated credit exposure to the Issuer,
the Issuer’s ability to pay depends on its overall financial condition, and
they bear Issuer credit risk similar to a holder of subordinated notes issued by a corporate issuer.
11. LIMITED RECOURSE
11.1 To the maximum extent permitted by Applicable Law, no recourse in respect of any breach of the Issuer’s obligations under the Tokens shall be held against any shareholder, director, officer, employee, manager, affiliate, or service provider of the Issuer in their capacity as such, except in cases of actual fraud, wilful misconduct, or gross negligence where liability cannot lawfully be excluded.
11.2 This Condition survives redemption and burning of Tokens.
12. SMART CONTRACT MODIFICATIONS AND UPGRADES
12.1 Upgrade mechanisms. Tokens may be governed by smart contracts that include upgrade or modification mechanisms. The Issuer may use such mechanisms only to:
address security vulnerabilities or operational threats;
correct bugs or unintended deviations from Product Documentation;
maintain compatibility with network upgrades or external dependencies;
refactor code without materially changing economic intent; or
amend components rendered ineffective or impractical due to external changes.
12.2 Material changes. Any modification that materially changes Tokenholder rights, economic mechanics, or risk profile will be implemented in accordance with the Product Documentation and Applicable Law, including applicable notice obligations. Unless expressly stated in the Token Terms, such modifications do not require prior Tokenholder consent, and the Issuer retains discretion to make such changes where deemed necessary.
12.3 Notice and deemed acceptance (where applicable). If we amend Product Documentation in connection with permitted upgrades, we will publish notice in accordance with Condition 15. Where the Token Terms provide for a deemed-acceptance process, it will apply as described there.
13. SUBSTITUTION OF ISSUER
13.1 The Issuer may substitute itself with an affiliate (a “New Issuer”) in respect of rights and obligations under the Tokens if:
the New Issuer can perform all payment and operational obligations; and
the Issuer provides an irrevocable guarantee of the New Issuer’s obligations (or an equivalent arrangement), in each case as described in the Token Terms.
The Issuer is not required to obtain Tokenholder consent for such amendments unless expressly stated in the applicable Token Terms.
13.2 We will publish notice of any substitution. References to the Issuer then include the New Issuer.
14. AMENDMENTS TO THESE TERMS
14.1 We may modify these General Terms and Conditions to reflect changes in law, regulation, product design, or operational requirements.
14.2 If a change is material, we will make reasonable efforts to provide at least 2 days’ notice before it takes effect, unless a shorter period is required for security, compliance, or risk management reasons.
15. NOTICES
15.1 Unless stated otherwise in the Token Terms, notices relating to Tokens and these General Terms and Conditions will be published on the Website or through other official communication channels designated by the Issuer.
16. TAX
Tokenholders are solely responsible for any taxes arising from their Tokens.
16.1 Payments by the Issuer will be made without deduction or withholding for taxes unless required by Applicable Law. Where withholding is required, the Issuer may deduct the applicable amount and has no obligation to gross up.
16.2 If withholding is required, the Issuer may withhold the required amount and will not be obliged to gross-up payments unless the Token Terms expressly provide otherwise.
17. EVENTS OF DEFAULT AND INSOLVENCY EVENTS
17.1 Event of Default. An Event of Default occurs if any of the following happens and continues: a) the Issuer fails to pay an amount due under Tokens within a commercially reasonable timeframe (subject to the Token Terms, Market Disruption Events, Underlying Illiquidity, compliance constraints, and operational SLAs); b) the Issuer commences any voluntary liquidation, winding-up, reorganisation, arrangement, moratorium, or similar process under applicable insolvency law; or c) any involuntary insolvency proceeding is commenced against the Issuer seeking liquidation, winding-up, reorganisation, or similar relief.
17.2 Insolvency Event. An Insolvency Event occurs if: a) the Issuer becomes unable to pay its debts as they fall due; b) the Issuer suspends or announces an intention to suspend payments of all or a material part of its debts; or c) the Issuer enters negotiations with one or more creditors (other than Tokenholders) to reschedule indebtedness due to actual or anticipated financial difficulties.
17.3 Consequences. The Token Terms may specify consequences, including the ability of the Issuer to initiate procedures under the Issuer Call Option or other unwind mechanics, subject always to the qualified subordination in Condition 10.
18. LIMITATION OF LIABILITY
18.1 Except as expressly stated in Product Documentation and to the maximum extent permitted by Applicable Law, the Issuer disclaims liability for indirect, incidental, consequential, special, punitive, or exemplary damages, including loss of profits, loss of opportunity, or loss of goodwill.
18.2 The Issuer is not liable for acts or omissions of independent third parties not under the Issuer’s direct control, including exchanges, custodians, wallet providers, banks, liquidity providers, analytics providers, protocol operators, or infrastructure vendors, except where the Issuer acted with actual fraud, wilful misconduct, or gross negligence that cannot lawfully be excluded.
18.3 Nothing in these Terms limits liability that cannot be excluded under Applicable Law.
19. NON-CUSTODIAL; NO FIDUCIARY DUTIES
19.1 Non-custodial. Unless expressly stated in the Token Terms, the Issuer does not hold custody of Tokenholders’ private keys. You remain solely responsible for wallet security and key management.
19.2 No fiduciary relationship. The Product Documentation does not create any fiduciary duties. To the maximum extent permitted by law, you acknowledge and agree that we do not owe fiduciary duties to you, and any such duties that might otherwise be implied are waived. Our obligations are only those explicitly set out in Product Documentation.
20. GOVERNING LAW AND JURISDICTION
20.1 These General Terms and Conditions, the Product Documentation, and any non-contractual obligations arising out of or in connection with them are governed by BVI law, excluding any conflict-of-law rules that would require application of another jurisdiction’s laws.
20.2 Subject to any arbitration clause or dispute mechanism specified in the Token Terms, the courts of the British Virgin Islands shall have jurisdiction to settle disputes arising out of or in connection with these General Terms and Conditions.
21. SEVERABILITY
If any provision of Product Documentation is held to be unlawful, invalid, or unenforceable, the remaining provisions remain in full force and effect. The parties will, where possible, replace the invalid provision with a lawful provision that most closely reflects the original economic intent.
22. MISCELLANEOUS
22.1 Independent advice. We do not provide legal, tax, or accounting advice. You should obtain independent professional advice if you are unsure about any aspect of Tokens.
22.2 No waiver. Any waiver must be in writing by the Issuer. Failure to enforce a provision is not a waiver of future enforcement.
22.3 Entire agreement. Product Documentation constitutes the entire agreement relating to Tokens and supersedes prior statements, subject to any documents expressly incorporated by reference.
22.4 Assignment. The Issuer may assign or transfer its rights and obligations to an affiliate or successor as permitted by the Token Terms. Your ability to transfer Tokens, if any, is governed by the Token Terms and applicable smart contract rules.
SCHEDULE 1 — CERTAIN RISKS RELATING TO TOKENS
Dealing in Tokens involves a high degree of risk and may be suitable only if you can evaluate the risks and bear a complete loss of capital. This list is not exhaustive, and additional risks may arise over time.
Subordinated credit risk of the Issuer Tokens are unsecured, subordinated debt obligations of the Issuer. Tokenholders are exposed to the full credit risk of the Issuer, including the risk that the Issuer becomes insolvent or unable to meet its obligations.
In an insolvency or liquidation of the Issuer:
Tokenholders will be paid only after all senior (unsubordinated) creditors have been paid in full;
Tokenholders may recover nothing or only a small portion of their investment; and
Tokens are not covered by any deposit protection scheme, investor compensation scheme, or insurance mechanism.
Investors should therefore evaluate Tokens as they would evaluate an investment in subordinated corporate debt, not as a secured or asset-backed instrument.
No ownership of underlying. Tokenholders do not directly own or control any Underlying. You hold a debt claim against the Issuer, not an interest in assets.
Qualified subordination. Your Claims are subordinated and may not be payable if payment would cause or worsen insolvency. In insolvency, your Claims rank below non-subordinated creditors and above shareholders.
Market, strategy, and performance risk. Token value may be linked (directly or indirectly) to performance of strategies or Underlyings. Past performance is not indicative of future results. Losses may occur.
Tracking, valuation, and timing differences. Token valuation may not perfectly track any reference value due to fees, operational timing, market disruptions, illiquidity, or settlement constraints.
Liquidity and transferability risk. There may be no active secondary market. Tokens may be illiquid and/or subject to transfer restrictions. You may be unable to sell or exit when desired.
Redemption and settlement risk. Redemptions may be delayed by SLAs, compliance checks, market disruption, illiquidity, or operational constraints. Settlement may involve banking, stablecoin, or blockchain transaction risks.
Third-party and counterparty risk. The Issuer relies on third parties (custodians, exchanges, banks, infrastructure providers, protocol operators). Failure, insolvency, hacking, or outages may impact Tokens.
Smart contract and cybersecurity risk. Smart contract bugs, exploits, governance attacks, private key compromise, oracle issues, and other cybersecurity incidents can cause partial or total loss.
Blockchain risks. Network congestion, high fees, forks, consensus failures, validator/miner attacks, and emerging technologies (including quantum computing) may disrupt operations.
Regulatory and enforcement risk. Laws and regulatory interpretations may change rapidly. The Issuer may be required to obtain licences, restrict jurisdictions, suspend features, or cease operations in some markets.
Tax risk. Tax treatment is uncertain and may change. Withholding may apply. You are responsible for your tax compliance.
Operational and key-person risk. The Issuer is an operating company and may face execution risks, staffing risks, vendor risks, and business continuity risks.
No governance rights. Tokenholders have no voting or management rights in the Issuer.
Unanticipated risks. Tokens and crypto markets evolve quickly. New risks may emerge that are not presently foreseeable.
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