XP2P Regulatory Disclosure - LOTTERII

EARTHX® CORPORATION LTD.

XP2P® EcoSystem
Regulatory Disclosure

Effective Date: December 2, 2025

Platform: earthx.lotterii.io • earthx.xp2p.io

Table of Contents

  1. FAQ
  2. Regulatory Status & Legal Framework
  3. Howey Test Analysis
  4. Pyramid/Ponzi Distinction
  5. Crowdfunding/MLM Distinction
  6. ACTIION Tax Optimization
  7. Gaming Platforms
  8. Products & Services
  9. Regulatory Considerations
  10. Finance Integration
  11. Regulatory Distinction Summary
  12. Risk Disclosure
  13. Platform Transparency
  14. Tax Implications
  15. Regulatory Outlook
  16. Final Considerations

Section 1: FAQ

XP2P operates as a peer-to-peer CrowdGifting platform. Its legal status depends on jurisdiction. The platform is structured to comply with applicable laws regarding peer-to-peer transactions and has been analyzed under multiple regulatory frameworks including the Howey Test.

No. XP2P differs fundamentally from pyramid schemes. Revenue is generated through actual product/service value, not recruitment. There is no inventory loading, mandatory purchases, or requirement to recruit to earn. The cycling system operates on actual fund flows, not promises of future returns from recruitment.

XP2P has been analyzed under the Howey Test and is structured to avoid classification as a security. Participants receive immediate consumptive utility, not an investment contract with expectation of profits from others' efforts.

XP2P operates under general consumer protection, anti-fraud, and financial services regulations. Specific oversight varies by jurisdiction. The platform proactively complies with applicable KYC/AML requirements.

Full disclosure of all terms, risks, and mechanics. Blockchain-verified transactions. Transparent fee structures. Dispute resolution processes. Age verification (18+). Self-exclusion options.

READ BEFORE PARTICIPATING

What XP2P IS:

A decentralized system where participants contribute funds that are redistributed through an 8-stage cycling mechanism, generating returns at each stage.

Funds flow directly between participants through smart contracts and verified transactions, creating a self-sustaining economic cycle.

Through integration with ACTIION membership, participants may access charitable donation-based tax deduction strategies.

XP2P/UBII is designed to generate sustainable income flows for participants, contributing to a universal basic income model.

What XP2P is NOT:

No recruitment required to earn. Revenue from actual fund cycling, not new member deposits. Sustainable regardless of growth rate.

Returns are generated through actual cycling mechanics, not by paying earlier investors with later investors' money. All fund flows are transparent and blockchain-verified.

Does not meet the Howey Test criteria. Participants receive immediate utility, not investment returns dependent on others' efforts.

No inventory loading, no mandatory purchases, no recruitment requirements. Earnings based on cycling mechanics, not downline building.

Participation involves risk. Returns are not guaranteed. Past performance does not predict future results. Only participate with funds you can afford to lose.

Section 2: Regulatory Status & Legal Framework

XP2P operates within the framework of peer-to-peer transaction laws, consumer protection regulations, and applicable financial services requirements. The platform maintains compliance through KYC/AML procedures, transparent operations, and proactive regulatory engagement.

Section 3: Howey Test Analysis

The SEC uses the Howey Test to determine if a transaction qualifies as a security. XP2P has been analyzed under all four elements:

While participants contribute funds, these are for immediate consumptive use (cycling participation), not passive investment.

XP2P's peer-to-peer structure means individual outcomes are not dependent on a common enterprise. Each cycling position operates independently.

Returns come from the cycling mechanism itself, not from appreciation of an underlying asset or enterprise profitability.

Participants must actively engage with the cycling system. Returns are not derived from the managerial efforts of others.

Section 4: Pyramid/Ponzi Distinction

XP2P is fundamentally different from pyramid and Ponzi schemes. Revenue comes from actual cycling mechanics, not recruitment. The system operates sustainably regardless of growth. No inventory loading or mandatory purchases. All fund flows are transparent and verifiable.

Section 5: Crowdfunding/MLM Distinction

XP2P incorporates elements of crowdfunding (community-driven funding) but is distinct from MLM structures. There are no mandatory product purchases, no recruitment requirements, and no downline-dependent earnings.

Section 6: ACTIION Tax Optimization

Through ACTIION membership (auto-enrolled via $59 deduction from qualifying wins), participants access charitable donation tracking and reporting that may provide tax optimization benefits. Participants are encouraged to consult tax professionals for their specific circumstances.

Section 7: Gaming Platforms

XP2P integrates with LOTTERII (lottery), CASIINO (casino gaming), and XBetting (sports/esports). Each platform operates under its own regulatory framework while sharing the unified wallet and identity system.

Section 8: Products & Services

The ecosystem provides actual products and services: gaming platforms, financial services (GUARDIIAN wallet), insurance products (UTOPIIA Pool), and community benefits (UBII). These are not merely vehicles for fund collection.

Section 9: Regulatory Considerations

The platform proactively monitors and adapts to regulatory changes across jurisdictions. Geo-restriction is employed where required. Regular legal review ensures ongoing compliance.

Section 10: Finance Integration

GUARDIIAN Neo Bank serves as the central financial hub, supporting multi-currency operations, cross-platform transactions, and secure fund management across the entire ecosystem.

Section 11: Regulatory Distinction Summary

XP2P is: a peer-to-peer CrowdGifting platform with cycling mechanics, integrated gaming platforms, and financial services. It is NOT: a security, pyramid scheme, Ponzi scheme, MLM, or guaranteed investment.

Section 12: Risk Disclosure

IMPORTANT RISK WARNING

Participation in XP2P involves financial risk. You may lose all contributed funds. Returns are not guaranteed. Cryptocurrency values fluctuate. Regulatory changes may affect platform operations. Only participate with funds you can afford to lose entirely.

Conduct thorough independent research. Understand the mechanics, risks, and limitations. Don't rely solely on promotional materials or testimonials.

Consult qualified legal, financial, and tax professionals before participating. Every individual's situation is different.

Read this document, terms of service, and all platform documentation in their entirety before participating.

Consider all factors including your financial position, local laws, and personal risk appetite before deciding to participate.

Section 13: Platform Transparency

All transactions are blockchain-verified. Fund flows are publicly auditable. Fee structures are clearly disclosed. Regular third-party audits maintain system integrity.

Section 14: Tax Implications

Cycling returns and gaming winnings may be subject to income tax. ACTIION membership provides tools for charitable donation tracking. Form 1099 reporting for applicable thresholds. Participants are responsible for their own tax obligations.

Section 15: Regulatory Outlook

The regulatory landscape for peer-to-peer platforms and cryptocurrency-based services continues to evolve. EARTHX Corporation maintains active engagement with regulatory developments and adapts platform operations accordingly.

Section 16: Final Considerations

XP2P represents an innovative approach to peer-to-peer fund redistribution integrated with gaming and financial services. While structured for regulatory compliance, participants must understand and accept all risks before participating.

Important Notice

This regulatory disclosure is provided for informational purposes only. It does not constitute legal, financial, or tax advice. All participation in XP2P® is voluntary and at the participant's own discretion and risk.

© 2023-2026 EARTHX® Corporation. All rights reserved.
18+ only. Participate responsibly. Not available in all jurisdictions.

© 2023-2026 EARTHX® Corporation. All rights reserved.

18+ only. Participate responsibly. Not available in all jurisdictions.