EMT White Paper
| .. | |||||
| White paper for E-Money Token | |||||
| Digital Token Identifier: | N/A | ||||
| Issuer of the e-money token: | 254900XFMACGD0L7AI73 - UAB BLUE EMI LT | ||||
| Type of submission: | Modify | ||||
| Table of content | |||||
| General information | |||||
| SUMMARY | |||||
| Part A - Information about the issuer of the e-money token | |||||
| Part B - Information about the e-money token | |||||
| Part C - Information about the offer to the public of the e-money token or its admission to trading | |||||
| Part D - Information on the rights and obligations attached to e-money tokens | |||||
| Part E - Information on the underlying technology | |||||
| Part F - Information on the risks | |||||
| Part G - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts | |||||
| [Table 4] Template for white papers for e-money tokens | |||||
| Template for white papers for e-money tokens [abstract] | |||||
| General information | |||||
| I.00 Table of content | boolean true | ||||
| I.01 Date of notification | date | ||||
| I.02 Statement in accordance with Article 51(3) of Regulation (EU) 2023/1114 | boolean true | ||||
| I.03 Compliance statement in accordance with Article 51(5) of Regulation (EU) 2023/1114 | boolean true | ||||
| I.04 Warning in accordance with Article 51(4), points (a) and (b), of Regulation (EU) 2023/1114 | boolean true | ||||
| SUMMARY | |||||
| I.05 Warning in accordance with Article 51(6), second subparagraph of Regulation (EU) 2023/1114 | boolean true | This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this e-money token on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and that any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law. |
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| I.06 Characteristics of the crypto-asset | textBlock | The token is designed exclusively for on-platform transactions – such as purchasing and selling securities and receiving coupon payments – and cannot be used, traded or transferred outside the Axiology platform. Blue EMI serves as the tokenisation service provider for all eurodenominated payments on Axiology DLT. SHORT DESCRIPTION OF FUNDS FLOW Axiology clients top up their Axiology DLT TSS wallets to trade. A top-up means the client transfers fiat funds to the Axiology client account held at Blue EMI and, in parallel, receives one BLUEUR token for each euro to their Axiology wallet. Blue EMI immediately tokenises the received funds and credits the client's wallet; the tokens are then available for transaction settlement. Clients' fiat funds are safeguarded in accordance with the MiCAR and the Law on Electronic Money and Electronic Money Institutions until redeemed. Blue EMI safeguards all Axiology client funds in a safeguarding account at a credit institution. Holders of Blue EMI e-money tokens have a claim against UAB Blue EMI LT, which safeguards fiat funds equivalent to the EMTs issued. The number of tokens circulating on the Axiology platform equals the euro funds received by Blue EMI. The value of EMTs does not increase relative to the euro, as they reference the euro 1:1. EMTs are redeemed by Blue EMI upon the holder's request at any time and at par value. Blue EMI redeems tokens by transferring fiat funds (other than electronic money, or EMT) equal to the monetary value of the EMTs redeemed. Funds are transferred to the Axiology client's bank account initially registered with the Axiology platform. As the funds flow is similar to e-money issuance under the current e-money licence, Blue EMI's existing internal control mechanisms and risk management procedures apply. |
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| I.07 Right of redemption | textBlock | Blue EMI complies with applicable laws, including AML and CFT requirements. EMT holders shall meet the eligibility criteria set out in the dedicated Terms & Conditions. To qualify for redemption, holders must: • Provide accurate information for identity verification (e.g., identification documents) and any additional KYC/KYB documents requested under a risk-based approach. • Submit a correct IBAN from an EEA bank or payment service provider for the funds transfer. • Provide written confirmation that the bank account details are accurate, that they are the rightful owner of the account, that the account can accept EUR transfers, and that any transfer fees are the customer's responsibility. As part of the redemption process, Blue EMI will: • Verify identity – confirm the EMT holder's identity through internal due diligence procedures. • Monitor transactions – assess EMT transaction history and verify ownership. • Check EMT availability – confirm whether any EMTs are subject to blocks, freezes, or other restrictive measures. • Apply additional compliance measures – take any other necessary actions to ensure full compliance. BLUEUR holders acknowledge that sending EMTs to another address irrevocably transfers the right to redeem those funds (if eligible) to the recipient and any subsequent holders. Transactions involving BLUEUR are final and cannot be reversed. By sending BLUEUR, holders accept the risk of permanently losing access to, and any claim over, those funds. This includes (but is not limited to) scenarios where: • An incorrect address is entered, making recovery impossible. • The sender loses, or never possesses, the private key for the destination address. • The recipient refuses to return the BLUEUR. • The recipient requires additional steps (e.g., identity verification) before returning funds. Blue EMI is not responsible for tracking, verifying, or determining the origin or ownership of BLUEUR balances. Holders are responsible for securely storing their BLUEUR tokens, safeguarding and correctly using their Axiology wallet access, and ensuring transfers are accurate. No reimbursements are available for users who fail to meet these requirements. Users have the right to:11 • Submit complaints about Blue EMI services (e.g., customer service, issuance, redemptions) in accordance with the Complaints Handling Policy. • Top up their Axiology wallets with euro funds. • Redeem BLUEUR tokens for euros to their bank account. • Privacy of information, with data protection policies applicable in the user's jurisdiction (e.g., GDPR), preventing unlawful disclosure of personal data without explicit consent, as detailed in the Privacy Policy (https://blueemi.com/privacy-policy/). Users must provide truthful information to facilitate KYC, AML, and related requirements. Providing inaccurate or fraudulent data may result in prosecution. LIMITATIONS TO REDEMPTION RIGHTS Blue EMI is obliged to prevent Restricted Parties from holding EMTs. A Restricted Party is any natural or legal entity that meets one or more of the following criteria: • Insufficient identification – unable to provide adequate or consistent information for identity verification under Applicable Laws. • Sanctioned individuals/entities – listed on any sanctions list maintained by the European Union, or as defined under Blue EMI's AML/CFT Policies. • Prohibited jurisdictions – located in, organised under, or resident in a country or territory appearing on: (i) Commission Delegated Regulation C(2022)9649, amending Delegated Regulation (EU) 2016/1675, adding Democratic Republic of the Congo, Gibraltar, Mozambique, Tanzania, and United Arab Emirates to Table I of the Annex. (ii) Jurisdictions under Increased Monitoring as identified in the FATF publication dated 21 October 2022. (iii) The Office of Foreign Assets Control (OFAC) list, issued by the United States Treasury Department, as of 10 March 2022. • Suspicious transactions – engaged in transactions deemed suspicious under Applicable Laws. • Ownership/control by Restricted Parties – owned or controlled, directly or indirectly, by any of the above. Holders must provide truthful information to facilitate KYC/AML requirements and other services. Inaccurate or fraudulent data may be subject to prosecution. By holding, using, or accessing BLUEUR, holders warrant that: • They are doing so in compliance with this White Paper and applicable laws; and • They will not use BLUEUR for any illegal activity, including but not limited to illegal gambling, money laundering, fraud, blackmail, extortion, ransoming data, terrorism financing, other violent activities, or any prohibited market practices. The rights and obligations of EMT holders may change to comply with current laws and regulations,improve services, or accommodate legal precedents and customer complaints. In the event of changes, users will be notified via their provided contact details and will receive the updated Terms and Conditions or other informational documents. Users must consent to changes; refusal may result in loss of access to services and the forced redemption of tokens. |
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| I.08 Key information about the offer and/ or admission to trading | textBlock | The offer to the public of the BLUEUR e-money token is governed by the Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCAR), applicable in the European Union. The competent authority overseeing public offers of e-money tokens is the Bank of Lithuania, and the relevant court for legal proceedings is the Vilnius Regional Court. |
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| Part A - Information about the issuer of the e-money token | |||||
| A.1 Statutory name | text | ||||
| A.2 Trading name | text | ||||
| A.3 Legal form | text | ||||
| A.4 Registered address | |||||
| Registered addess | text | ||||
| Country | enumeration | ||||
| Sub-division | text | ||||
| A.5 Head office | |||||
| Head office | text | ||||
| Country | enumeration | ||||
| Sub-division | text | ||||
| A.6 Registration date | date | ||||
| A.7 Legal entity identifier | LEI | ||||
| A.8 Another identifier required pursuant to applicable law | text | ||||
| A.9 Contact telephone number | text | ||||
| A.10 E-mail address | text | ||||
| A.11 Response time (days) | integer | ||||
| A.12 Parent company | text | ||||
| A.13 Members of the management body | |||||
| Member #1 | id | 1 | |||
| Identity | text | ||||
| Business address | text | ||||
| Function | text | ||||
| Member #2 | id | 2 | |||
| Identity | text | ||||
| Business address | text | ||||
| Function | text | ||||
| Member #3 | id | 3 | |||
| Identity | text | ||||
| Business address | text | ||||
| Function | text | ||||
| Member #4 | id | 4 | |||
| Identity | text | ||||
| Business address | text | ||||
| Function | text | ||||
| A.14 Business activity | textBlock | ||||
| A.15 Parent company business activity | textBlock | ||||
| A.16 Conflicts of interest | text | 1. One of our board members, Algirdas Neciunskas, is also the COO of Axiology DLT. 2. Another member of the board, Audrius Šilgalis, is an advisor to Axiology DLT under a service contract. Since Blue EMI issues EMTs as a settlement asset in Axiology platform, as described in this White Paper, the foregoing means that: • One person holds leadership positions at both companies; • Both persons have access to business, strategic and other critical information on both companies; • The points described above could potentially create conflict of interest situations when making business decisions. In order to manage the risks identified, Blue EMI is disclosing this relationship publicly. The company will also ensure that under its internal policies and procedures the aforementioned members of the board will not participate in decisions where this relationship could affect their impartiality and any decisions on related matters shall be subject to auditing and regulatory scrutiny, thus, increasing transparency and protection of the interests of service users. In addition to this, the partnership between companies will be conducted on a industry standard terms and market prices. Blue EMI shall manage any potential conflicts under its Internal Control Policy, Conflict of Interest Policy, Vendor Management Policy etc. |
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| A.17 Issuance of other crypto-assets | boolean | ||||
| A.18 Activities related to other crypto-assets | boolean | ||||
| E-money token issuer and DLT business association | |||||
| A.19 Connection between the issuer and the entity running the DLT | boolean | ||||
| A.20 Description of the connection between the issuer and the entity running the DLT | textBlock | ||||
| A.21 Newly established | boolean | ||||
| A.22 Financial condition for the past three years | textBlock | The share capital of Blue EMI is 700,000 EUR. Over the past three reported years, BLUE EMI's sales revenue has grown from €8,350 in 2022, €3,660 in 2023, and then more substantially to €19,931 in 2024 - an overall upward trend in turnover. Despite this revenue growth, the company has recorded negative profitability: a small net profit of €3,280 in 2022, and then significant net losses of €313,304 in 2023 and €721,278 in 2024, with net profit margins deeply negative in those latter years. Equity capital improved sharply from a negative position in 2021 to positive levels in 2022 and 2023, but then declined again in 2024, while liabilities increased markedly by 2024, reflecting elevated obligations relative to equity. Blue EMI has established the core regulatory and operational foundations to support its growth phase. The company is managing its financial resources prudently as it scales commercial activity. As Axiology's e-money tokenisation partner, Blue EMI is positioned to innovate and expand its services alongside Axiology's trading and settlement infrastructure. |
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| A.23 Financial condition since registration | textBlock | ||||
| A.24 Exemption from authorisation | boolean | ||||
| A.25 E-money token authorisation | text | ||||
| A.26 Authorisation authority | enumeration | ||||
| Information on whether persons other than issuer are involved | |||||
| A.27 Persons other than the issuer offering to the public or seeking admission to trading of the e-money token in accordance with Article 51(1), second subparagraph, of Regulation (EU) 2023/1114 | N/A | . | |||
| A.28 Persons other than the issuer offering to the public or seeking admission to trading of the e-money token in accordance with Article 51(1), second subparagraph, of Regulation (EU) 2023/1114 | N/A | . | |||
| A.29 Reason for offering to the public or seeking admission to trading of the e-money token | N/A | . | |||
| Part B - Information about the e-money token | |||||
| B.1 Name | text | ||||
| B.2 Abbreviation | text | ||||
| B.3 Details of all natural or legal persons involved in design and development | |||||
| Person #1 | id | 1 | |||
| Type of person | enumeration | ||||
| Name of person | text | ||||
| Business address of person | text | ||||
| Domicile of company | enumeration | ||||
| A description of the characteristics of the e-money token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109, as specified in accordance with paragraph 8 of that Article | |||||
| B.4 Type of white paper | enumeration | ||||
| B.5 Type of submission | enumeration | ||||
| B.6 Crypto-asset characteristics | textBlock | Axiology clients top up their Axiology DLT TSS wallets to trade. A top-up means the client transfers fiat funds to the Axiology client account held at Blue EMI and, in parallel, receives one BLUEUR token for each euro to their Axiology wallet. Blue EMI immediately tokenises the received funds and credits the client's wallet; the tokens are then available for transaction settlement. Clients' fiat funds are safeguarded in accordance with the MiCAR and the Law on Electronic Money and Electronic Money Institutions until redeemed. Blue EMI safeguards all Axiology client funds in a safeguarding account at a credit institution. Holders of Blue EMI e-money tokens have a claim against UAB Blue EMI LT, which safeguards fiat funds equivalent to the EMTs issued. The number of tokens circulating on the Axiology platform equals the euro funds received by Blue EMI. The value of EMTs does not increase relative to the euro, as they reference the euro 1:1. EMTs are redeemed by Blue EMI upon the holder's request at any time and at par value. Blue EMI redeems tokens by transferring fiat funds (other than electronic money, or EMT) equal to the monetary value of the EMTs redeemed. Funds are transferred to the Axiology client's bank account initially registered with the Axiology platform. As the funds flow is similar to e-money issuance under the current e-money licence, Blue EMI's existing internal control mechanisms and risk management procedures apply. |
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| B.7 Website of the issuer | text | ||||
| B.8 Starting date of offer to the public or admission to trading | date | ||||
| B.9 Publication date | date | ||||
| B.10 Any other services provided by the issuer | textBlock | • Card payment acquiring supporting major card networks (VISA, Mastercard). • Open banking, including payment initiation and account information services. • Embedded payment checkout solutions for merchants' websites. Blue EMI provides specialised financial services for ECSP-regulated crowdfunding operators, offering: • Dedicated e-money accounts for investors and fundraising entities. • End-to-end transaction processing covering investment collection, periodic interest distribution, and investment repayments. • Integrated compliance solutions, such as automated KYC, transaction monitoring and client funds safeguarding. |
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| B.11 Language or languages of white paper | text | ||||
| B.12 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available | text | ||||
| B.13 Functionally fungible group digital token identifier, where available | text | ||||
| B.14 Personal data flag | boolean | ||||
| B.15 LEI eligibility | boolean | ||||
| B.16 Home member state | enumeration | ||||
| B.17 Host member states #1 | enumerationSet | ||||
| Part C - Information about the offer to the public of the e-money token or its admission to trading | |||||
| C.1 Public offering or trading | enumeration | ||||
| C.2 Number of units | integer | ||||
| Trading platforms characteristics | |||||
| C.3 Trading platforms name | text | ||||
| C.4 Trading platforms market identifier code (MIC) | text | ||||
| C.5 Applicable law | textBlock | ||||
| C.6 Competent court | textBlock | ||||
| Part D - Information on the rights and obligations attached to e-money tokens | |||||
| D.1 Holder's rights and obligations | text | Blue EMI complies with applicable laws, including AML and CFT requirements. EMT holders shall meet the eligibility criteria set out in the dedicated Terms & Conditions. To qualify for redemption, holders must: • Provide accurate information for identity verification (e.g., identification documents) and any additional KYC/KYB documents requested under a risk-based approach. • Submit a correct IBAN from an EEA bank or payment service provider for the funds transfer. • Provide written confirmation that the bank account details are accurate, that they are the rightful owner of the account, that the account can accept EUR transfers, and that any transfer fees are the customer's responsibility. As part of the redemption process, Blue EMI will: • Verify identity – confirm the EMT holder's identity through internal due diligence procedures. • Monitor transactions – assess EMT transaction history and verify ownership. • Check EMT availability – confirm whether any EMTs are subject to blocks, freezes, or other restrictive measures. • Apply additional compliance measures – take any other necessary actions to ensure full compliance. BLUEUR holders acknowledge that sending EMTs to another address irrevocably transfers the right to redeem those funds (if eligible) to the recipient and any subsequent holders. Transactions involving BLUEUR are final and cannot be reversed. By sending BLUEUR, holders accept the risk of permanently losing access to, and any claim over, those funds. This includes (but is not limited to) scenarios where: • An incorrect address is entered, making recovery impossible. • The sender loses, or never possesses, the private key for the destination address. • The recipient refuses to return the BLUEUR. • The recipient requires additional steps (e.g., identity verification) before returning funds. Blue EMI is not responsible for tracking, verifying, or determining the origin or ownership of BLUEUR balances. Holders are responsible for securely storing their BLUEUR tokens, safeguarding and correctly using their Axiology wallet access, and ensuring transfers are accurate. No reimbursements are available for users who fail to meet these requirements. Users have the right to: • Submit complaints about Blue EMI services (e.g., customer service, issuance, redemptions) in accordance with the Complaints Handling Policy. • Top up their Axiology wallets with euro funds. • Redeem BLUEUR tokens for euros to their bank account. • Privacy of information, with data protection policies applicable in the user's jurisdiction (e.g., GDPR), preventing unlawful disclosure of personal data without explicit consent, as detailed in the Privacy Policy (https://blueemi.com/privacy-policy/). Users must provide truthful information to facilitate KYC, AML, and related requirements. Providing inaccurate or fraudulent data may result in prosecution. LIMITATIONS TO REDEMPTION RIGHTS Blue EMI is obliged to prevent Restricted Parties from holding EMTs. A Restricted Party is any natural or legal entity that meets one or more of the following criteria: • Insufficient identification – unable to provide adequate or consistent information for identity verification under Applicable Laws. • Sanctioned individuals/entities – listed on any sanctions list maintained by the European Union, or as defined under Blue EMI's AML/CFT Policies. • Prohibited jurisdictions – located in, organised under, or resident in a country or territory appearing on: (i) Commission Delegated Regulation C(2022)9649, amending Delegated Regulation (EU) 2016/1675, adding Democratic Republic of the Congo, Gibraltar, Mozambique, Tanzania, and United Arab Emirates to Table I of the Annex. (ii) Jurisdictions under Increased Monitoring as identified in the FATF publication dated 21 October 2022. (iii) The Office of Foreign Assets Control (OFAC) list, issued by the United States Treasury Department, as of 10 March 2022. • Suspicious transactions – engaged in transactions deemed suspicious under Applicable Laws. • Ownership/control by Restricted Parties – owned or controlled, directly or indirectly, by any of the above. Holders must provide truthful information to facilitate KYC/AML requirements and other services. Inaccurate or fraudulent data may be subject to prosecution. By holding, using, or accessing BLUEUR, holders warrant that: • They are doing so in compliance with this White Paper and applicable laws; and • They will not use BLUEUR for any illegal activity, including but not limited to illegal gambling, money laundering, fraud, blackmail, extortion, ransoming data, terrorism financing, other violent activities, or any prohibited market practices. The rights and obligations of EMT holders may change to comply with current laws and regulations, improve services, or accommodate legal precedents and customer complaints. In the event of changes, users will be notified via their provided contact details and will receive the updated Terms and Conditions or other informational documents. Users must consent to changes; refusal may result in loss of access to services and the forced redemption of tokens. |
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| D.2 Conditions of modifications of rights and obligations | text | ||||
| D.3 Description of the rights of the holders | textBlock | If Blue EMI becomes unable to fulfil its obligations or faces insolvency, EMT reserves are protected under applicable law. Funds received in exchange for EMT issuance are safeguarded and remain protected from any claims by Blue EMI's creditors, even in enforcement or insolvency proceedings. In the event of financial distress or insolvency, Blue EMI will activate its Wind-Down plan, Recovery Plan, and/or Redemption Plan to ensure EMT holders can exercise their redemption rights. Blue EMI issues e-money tokens at par value and only upon receipt of euro funds. Fiat funds paid in for EMT issuance are safeguarded in accordance with the MiCAR and the Republic of Lithuania Law on Payments, Republic of Lithuania Law on Payment Institutions, 23 July 2020 issued Resolution no. 03-106, amending resolution no 247 of the Board of the Bank of Lithuania of 30 December 2009 on requirements for electronic money institutions and payment institutions regarding internal control, risk management and safeguarding of received funds, as well as other implementing and applicable legal acts. Holders of e-money tokens have a claim against Blue EMI, which safeguards fiat funds equivalent to the EMTs issued at a credit institution. EMTs are redeemed by the Blue EMI upon the holder's request, at any time and par value, by transferring funds (other than electronic money) equal to the monetary value of the EMTs held. Funds are redeemed to the user's bank account registered on the Axiology platform. |
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| D.4 Rights in implementation of recovery plan | textBlock | Potential crisis scenarios include operational failures, a run on the token (massive redemptions), cybersecurity breaches, and disaster events – each of which can affect Blue EMI's liquidity, solvency, or operational capacity. When Blue EMI determines that risk levels have increased, the Recovery Plan is activated, and the relevant measures are implemented. Stakeholders and clients are informed when the Recovery Plan is initiated. During this period, holders' ability to acquire, use, or redeem EMTs may be temporarily affected. Blue EMI will work to restore normal operations as quickly as possible. Holder protections and rights during recovery: • Protected claims to reserves. If the Recovery Plan is activated, holders retain legally protected claims to reserve assets. All EMTs are fully backed by reserve assets held with EU credit institutions, and those reserves are protected from Blue EMI's liabilities. • Right to redeem at par. EMT holders maintain the right to redeem EMTs 1:1 for euros, though operational pauses or delays may occur and will be communicated by Blue EMI. • Priority in insolvency. In the unlikely event of insolvency, EMT holders retain priority to the reserve assets, supporting redemption at par value in fiat currency. • Immediate notice. Holders receive prompt notification of Recovery Plan activation, including the nature of the disruption, expected timeline for resolution, and any temporary service limitations. • Regulatory contact. Holders may contact the Bank of Lithuania if recovery actions deviate from disclosed policies. Blue EMI's risk team monitors real-time indicators – liquidity thresholds, operational stability, and credit exposures – with automated escalation to predefined recovery measures when thresholds are breached. During stabilisation, temporary service limitations (e.g., paused redemptions) may apply. Transparent communication is paramount: Blue EMI will notify stakeholders upon initiation, provide regular progress updates, and outline expected timelines for service restoration. All actions align with the Bank of Lithuania's requirements, including submission of the plan within six months of the EMT public offering. This focus on resilience and holder rights aims to keep EMTs a reliable medium of exchange even under stress. |
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| D.5 Rights in implementation of redemption plan | textBlock | Under the Redemption Plan, all EMT holders have equal rights to redeem their EMTs at any time and at par value, subject to AML/CFT requirements. Depending on the circumstances triggering the plan, Blue EMI may need to impose restrictions on the redemption of BLUEUR. Once the plan takes effect, EMT holders will be informed of its initiation and the steps to follow, including how to submit a redemption claim. Redemption claims are subject to the eligibility criteria described in the Redemption Procedure section above – covering the holder's identity, token ownership, AML/CFT compliance, bank account details, and any other applicable information. If automatic redemption is not available, Blue EMI will initiate a manual process to fulfil redemption claims. Provided all relevant information is supplied, EMT holders will be paid the full nominal value of their EMTs in euros, with no fees applied for EMT redemption. Redemption Plan: 1) Once the Bank of Lithuania decides that the Redemption Plan is to be initiated, it takes effect. Blue EMI informs stakeholders by email and/or via its website. 2) Automatic issuance and/or redemption of EMTs via Blue EMI is stopped. From this point, any redemption requests must be made manually. 3) EMT holders submit their redemption request to Blue EMI at support@blueemi.com and provide the following information: a) Personal identification documents. b) An IBAN for the return of EUR funds – an account that can accept euro payments. c) A written confirmation that the bank details are accurate, that the EMT holder is the rightful owner of the account, that the account can accept euro transfers, and an acknowledgement that any transfer fees are the customer's responsibility. d) Any other information required by the Blue EMI Compliance team. 4) Blue EMI verifies the EMT holder's identity, EMT ownership, and bank account ownership. 5) Blue EMI conducts AML/CFT checks (e.g., transaction monitoring, ML/TF screening, sanctions screening). 6) Blue EMI assesses EMT availability to confirm if any EMTs are subject to blocks, freezes, or other restrictive measures. 7) Blue EMI performs any additional actions necessary to ensure full compliance before returning funds. 8) The EMT holder transfers EMTs to the designated wallet provided by Blue EMI to complete redemption. 9) Blue EMI initiates the funds transfer to the EMT holder's provided bank account. The Redemption Plan is designed for extreme scenarios in which Blue EMI cannot continue normal operations. Under ordinary circumstances, please redeem EMTs via the Axiology platform. |
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| D.6 Complaint submission contact | text | ||||
| D.7 Complaints handling procedures | textBlock | • The Company will acknowledge receipt and inform the complainant whether the complaint is admissible within 1 (one) business day. The company will review all the relevant information and respond within 15 (fifteen) Business Days, or 35 (thirty-five) Business Days in exceptional cases. • Complaints are handled in writing. In exceptional cases, a meeting may be convened to resolve the dispute amicably; a meeting may be initiated by either the Applicant or the Company. For full details, please see the Complaints Handling Policy on the Company's website: https://blueemi.com/complaints-handling-policy/. |
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| D.8 Dispute resolution mechanism | textBlock | • Email: info@lb.lt • Online form: an electronic form available on the Bank of Lithuania's website • E. Delivery System: submit a complaint via the electronic delivery system • Mail: Totorių g. 4, LT-01121 Vilnius • Correspondence box: Totorių g. 4, Vilnius (business days 08:00–17:00) • In person: Totorių g. 4, LT-01121 Vilnius – request a meeting with a responsible officer from the Corporate Services Department, Document and Information Management Division • Available Monday–Friday during business hours (including lunch breaks). • Tuesdays 17:00–19:00: prior registration required. Find more on the consumer dispute procedure with financial service providers on the Supervisory Authority's website: https://www.lb.lt/en/dbc-settle-a-dispute-with-a-financial-service-provider. If the Company does not satisfy the Applicant's demands in full or satisfies them in part and the Applicant is not a consumer, the Applicant may apply to a court in accordance with the laws of the Republic of Lithuania. |
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| E-money token schemes details | |||||
| D.9 Token value protection schemes | boolean | ||||
| D.10 Token value protection schemes description | textBlock | ||||
| D.11 Compensation schemes | boolean | ||||
| D.12 Compensation schemes description | textBlock | ||||
| D.13 Applicable law | textBlock | ||||
| D.14 Competent court | textBlock | ||||
| Part E - Information on the underlying technology | |||||
| E.1 Distributed ledger technology | text | ||||
| E.2 Protocols and technical standards | textBlock | ||||
| E.3 Technology used | textBlock | ||||
| E.4 Purchaser's technical requirements | textBlock | ||||
| E.5 Consensus mechanism | text | • Agreement on transactions: Participants agree on the set of transactions for the next ledger version. • Application of transactions: Agreed transactions are applied in a well-defined order. • Confirmation of results: Participants confirm they obtained the same results; the ledger is then considered validated and final. • Properties: The protocol enables network-wide agreement on state and ordering without a central operator, addressing the double-spend problem. The protocol continues to evolve as its limits and edge cases are studied. |
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| E.6 Incentive mechanisms and applicable fees | text | ||||
| E.7 Use of distributed ledger technology | boolean | ||||
| E.8 DLT functionality description | textBlock | ||||
| E-money token's audit details | |||||
| E.9 Audit | boolean | ||||
| E.10 Audit outcome | textBlock | ||||
| Part F - Information on the risks | |||||
| F.1 Issuer-related risks | textBlock | - Issuer Liquidity Risk: Blue EMI may be unable to meet obligations to EMT holders due to insolvency, liquidation, or other financial distress. Under applicable law, however, safeguarded client reserves must remain segregated and are not available to cover Blue EMI's creditor claims; safeguarded funds held for Axiology clients are expected to be returned to their holders. Mitigation: Robust financial controls, regular audits, adherence to capital requirements, and maintenance of euro-denominated reserves at a credit institution to meet redemption demands. Stress testing is used to assess severe but plausible scenarios and to support liquidity planning. - Risk of Loss: Fraud, theft, misuse, negligence, operational error, or improper administration could lead to financial loss or data exposure, affecting operations end EMT security. Mitigation: Segregation of duties, strong internal controls, regular audits, and both real-time and retrospective monitoring to detect unusual activity. Eligible EMT holders' redemption rights persist even if Blue EMI incurs a loss in safeguarded assets, subject to law. - Legal and Regulatory Risk: Non-compliance with MiCAR, AML/CFT laws, GDPR, and other financial/consumer protection laws could result in investigations, enforcement actions, and penalties. Regulatory change may impact operations. Mitigation: A formal compliance framework aligned with applicable law, robust KYC and AML/CFT procedures, continuous monitoring for regulatory changes, and periodic internal/external audits. - Operational Risk: Failures of processes, systems, people, or external events – including technologicy outages, cybersecurity breaches, fraud, or human error – could impair the issuance, management, or redemption of EMTs. Mitigation: To minimise operational risk, Blue EMI implements comprehensive internal controls and security measures, including advanced technologies, regular system updates, and internal audits, and maintains contingency plans and business continuity protocols to minimise the impact of any operational disruptions. - Environmental, Social, and Governance Risks: Environmental impact (including energy consumption of underlying infrastructure), social responsibility, and governance practices may affect sustainability, reputation, and long-term performance. Mitigation: Commitment to sustainable operations (e.g., migration to renewable-powered data centres, considerations of carbon offset initiatives), user-centric platform design, strengthened privacy controls, enhanced anti-fraud protections, and a transparent governance framework promoting fair treatment, safety, diversity, and inclusion. - Reputational Risks: Negative publicity arising from regulatory actions, security incidents, operational failures, or adverse market events could reduce confidence among token holders and the market. Mitigation: Proactive communication and stakeholder engagement, transparent cooperation with regulator, a code of conduct and ethics programme, and clear, accurate, and timely disclosures. Blue EMI is committed to continuously strengthening its risk management practices to support the security, stability, and trustworthiness of its e-money token operations, in full compliance with MiCAR and other applicable regulations. |
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| F.2 Token-related risks | textBlock | - Value Stability Risk: Although BLUEUR is designed to maintain a 1:1 reference to the euro, value instability could arise if reserves are not managed properly – for example, during market stress, due to inadequate reserve management, or failures in operational mechanisms. Mitigation: Maintain a liquidity buffer in highly liquid assets to meet redemption requests under stress; where appropriate, apply maximum daily redemption limits or staggered redemption windows to manage sudden spikes in demand. - Technology and Infrastructure Risks: Software bugs, system outages, or failures in the underlying DLT could disrupt transactions or (in extreme cases) lead to loss. Mitigation: Maintain backup token issuance systems and follow an ICT risk management framework; use reliable, audited infrastructure partners; conduct regular testing, implement recovery plans, target highest up-time levels, and leverage scalable cloud solutions. Partner with reputable cybersecurity providers for penetration testing and ongoing ICT compliance. - Custody Risks: While client funds are safeguarded at credit institutions under Blue EMI's custody policy and protected from encumbrance or collateralization, custodians can still pose risks (e.g., loss or misuse). Mitigation: Perform due diligence on custodians (capital strength, credit ratings), require contractual protections that keep client assets available for redemption and insulated from custodian creditors, and monitor custodial controls to prevent fraud, misuse, or negligence. - Risk related to token design: Ambiguity in token structure, use case, or governance can impair functionality and user trust. Because BLUEUR operates via Axiology's private instance of the XRP ledger, technical issues, vulnerabilities, or failures on that platform could affect the EMT functionality or transferability. Mitigation: Conduct regular audits and security reviews of connected systems and continuously monitor the DLT networks relied upon. - Security Risks: EMT holders face wallet security and broader DLT security threats, including cyberattacks, phishing, impersonations of Blue EMI or its executives, fake tokens airdrops, offering fake EMT airdrops, and counterfeit EMTs. These can cause unauthorised transactions or loss. Mitigation: Promote best practice user security (e.g., strong credentials, two-factor authentication, phishing awareness); implement continuous security enhancements jointly with Axiology DLT; and maintain active monitoring and incident-response processes. |
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| F.3 Technology-related risks | textBlock | - Key management: Loss or compromise of a private key can lead to permanent loss of access to assets (general blockchain risk). Mitigation: Multi-signature accounts enable replacement of compromised keys so assets remain preserved. - Limited functionality: Some use cases may be complex to implement without smart contracts. Mitigation: Each process undergoes deep analysis and technical design to ensure it can be implemented correctly using XRPL's native features. - Technical knowledge: Advanced features might require deep XRPL expertise to build and operate. Mitigation: Development and solution design are handled by engineers with expert-level XRP Ledger knowledge, supported by reviews and documentation. - Privacy of the network: A private network requires additional security and fallback measures to ensure consensus continuity. Mitigation: An automated pipeline can add replacement nodes if any fail, with monitoring and failover to help ensure consensus does not halt. |
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| F.4 Mitigation measures | textBlock | - Issuer Liquidity Risk Mitigation: Robust financial controls, regular audits, adherence to capital requirements, and maintenance of euro-denominated reserves at a credit institution to meet redemption demands. Stress testing is used to assess severe but plausible scenarios and to support liquidity planning. - Risk of Loss Mitigation: Segregation of duties, strong internal controls, regular audits, and both real-time and retrospective monitoring to detect unusual activity. Eligible EMT holders' redemption rights persist even if Blue EMI incurs a loss in safeguarded assets, subject to law. - Legal and Regulatory Risk Mitigation: A formal compliance framework aligned with applicable law, robust KYC and AML/CFT procedures, continuous monitoring for regulatory changes, and periodic internal/external audits. - Operational Risk Mitigation: To minimise operational risk, Blue EMI implements comprehensive internal controls and security measures, including advanced technologies, regular system updates, and internal audits, and maintains contingency plans and business continuity protocols to minimise the impact of any operational disruptions. - Environmental, Social, and Governance Risks Mitigation: Commitment to sustainable operations (e.g., migration to renewable-powered data centres, considerations of carbon offset initiatives), user-centric platform design, strengthened privacy controls, enhanced anti-fraud protections, and a transparent governance framework promoting fair treatment, safety, diversity, and inclusion. - Reputational Risks Mitigation: Proactive communication and stakeholder engagement, transparent cooperation with regulator, a code of conduct and ethics programme, and clear, accurate, and timely disclosures. Token Related Risks: - Value Stability Risk Mitigation: Maintain a liquidity buffer in highly liquid assets to meet redemption requests under stress; where appropriate, apply maximum daily redemption limits or staggered redemption windows to manage sudden spikes in demand. - Technology and Infrastructure Risks Mitigation: Maintain backup token issuance systems and follow an ICT risk management framework; use reliable, audited infrastructure partners; conduct regular testing, implement recovery plans, target highest up-time levels, and leverage scalable cloud solutions. Partner with reputable cybersecurity providers for penetration testing and ongoing ICT compliance. - Custody Risks Mitigation: Perform due diligence on custodians (capital strength, credit ratings), require contractual protections that keep client assets available for redemption and insulated from custodian creditors, and monitor custodial controls to prevent fraud, misuse, or negligence. - Risk related to token design Mitigation: Conduct regular audits and security reviews of connected systems and continuously monitor the DLT networks relied upon. - Security Risks Mitigation: Promote best practice user security (e.g., strong credentials, two-factor authentication, phishing awareness); implement continuous security enhancements jointly with Axiology DLT; and maintain active monitoring and incident-response processes. Technology Related Risks: - Key management Mitigation: Multi-signature accounts enable replacement of compromised keys so assets remain preserved. - Limited functionality Mitigation: Each process undergoes deep analysis and technical design to ensure it can be implemented correctly using XRPL's native features. - Technical knowledge Mitigation: Development and solution design are handled by engineers with expert-level XRP Ledger knowledge, supported by reviews and documentation. - Privacy of the network Mitigation: An automated pipeline can add replacement nodes if any fail, with monitoring and failover to help ensure consensus does not halt. |
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| Part G - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts | |||||
| G.1 Adverse impacts on climate and other environment-related adverse impacts | textBlock | Under ESMA's draft RTS for MiCAR sustainability reporting, enhanced reporting is triggered when a crypto-asset's annual energy consumption exceeds 500,000 kWh. Blue EMI does not expect EMT transactions to exceed this threshold. Key sustainability features of XRPL: • Energy-efficient consensus (no Proof-of-Work). XRPL's consensus protocol avoids energy-intensive mining, making it one of the lowest energy large-scale ledgers. • Low energy per transaction. Public XRPL measurements indicate about 0.0079 kWh per transaction – roughly 100,000 times lower than Bitcoin on a per-transaction basis. This translates into an annual energy savings of over 50 billion kWh. • Carbon neutrality. The negligible energy that XRPL uses is offset via EW Zero, and XRPL is described as the first major public blockchain to achieve carbon-neutral status. • Ecosystem focus on sustainability. XRPL supports projects pursuing efficient, low-impact solutions (e.g., tokenised carbon markets and other sustainability use cases). BLUEUR operates on a private XRPL instance. While XRPL's design is energy-efficient by nature, actual consumption depends on the validator set and hosting infrastructure used for the private network. |
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| Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism | |||||
| General information about adverse impacts | |||||
| S.1 Name | text | ||||
| S.2 Relevant legal entity identifier | text | ||||
| S.3 Name of the crypto-asset | text | ||||
| S.4 Consensus mechanism | text | ||||
| S.5 Incentive mechanisms and applicable fees | text | ||||
| S.6 Beginning of period to which disclosed information relates | date | ||||
| S.7 End of period to which disclosed information relates | date | ||||
| Mandatory key indicator | |||||
| S.8 Energy consumption | energy (kWh) | ||||
| Sources and methodologies | |||||
| S.9 Energy consumption sources and methodologies | textBlock | • Energy-efficient consensus (no Proof-of-Work). XRPL's consensus protocol avoids energy-intensive mining, making it one of the lowest energy large-scale ledgers. • Low energy per transaction. Public XRPL measurements indicate about 0.0079 kWh per transaction – roughly 100,000 times lower than Bitcoin on a per-transaction basis. This translates into an annual energy savings of over 50 billion kWh. • Carbon neutrality. The negligible energy that XRPL uses is offset via EW Zero, and XRPL is described as the first major public blockchain to achieve carbon-neutral status. • Ecosystem focus on sustainability. XRPL supports projects pursuing efficient, low-impact solutions (e.g., tokenised carbon markets and other sustainability use cases). BLUEUR operates on a private XRPL instance. While XRPL's design is energy-efficient by nature, actual consumption depends on the validator set and hosting infrastructure used for the private network. |
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| Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of consensus mechanism | |||||
| Supplementary key indicators | |||||
| S.10 Renewable energy consumption | percent | ||||
| S.11 Energy intensity | energy (kWh) | ||||
| S.12 Scope 1 DLT GHG emissions - controlled | GHG emissions (tCO2e) | ||||
| S.13 Scope 2 DLT GHG emissions - purchased | GHG emissions (tCO2e) | ||||
| S.14 GHG intensity | GHG emissions (tCO2e) | ||||
| Sources and methodologies | |||||
| S.15 Key energy sources and methodologies | textBlock | ||||
| S.16 Key GHG sources and methodologies | textBlock | ||||
| Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism | |||||
| Optional indicators | |||||
| S. 17 Energy mix | percent | ||||
| S.18 Energy use reduction | |||||
| Energy use reduction target (absolute value) | energy (kWh) | ||||
| Energy use reduction target (percentage) | percent | ||||
| S.19 Carbon intensity (kgCO2e/kWh) | decimal | ||||
| S.20 Scope 3 DLT GHG emissions - value chain | GHG emissions (tCO2e) | ||||
| S.21 GHG emissions reduction targets or commitments | textBlock | ||||
| S.22 Generation of waste electrical and electronic equipment (WEEE) | mass (tonnes) | ||||
| S.23 Non-recycled WEEE ratio | percent | ||||
| S.24 Generation of hazardous waste | mass (tonnes) | ||||
| S.25 Generation of waste (all types) | mass (tonnes) | ||||
| S.26 Non-recycled waste ratio (all types) | percent | ||||
| S.27 Waste intensity (all types) | mass (tonnes) | ||||
| S.28 Waste reduction targets or commitments (all types) | textBlock | ||||
| S.29 Impact of use of equipment on natural resources | textBlock | ||||
| S.30 Natural resources use reduction targets or commitments | textBlock | ||||
| S.31 Water use | volume (m3) | ||||
| S.32 Non recycled water ratio | percent | ||||
| Sources and methodologies | |||||
| S.33 Other energy sources and methodologies | textBlock | ||||
| S.34 Other GHG sources and methodologies | textBlock | ||||
| S.35 Waste sources and methodologies | textBlock | ||||
| S.36 Natural resources sources and methodologies | textBlock | ||||