Disclosure Statements
Ensuro Re Ltd
Disclosure Statements
(Made pursuant to and for the purposes of the Bermuda Digital Asset Business (Client Disclosure) Rules 2018
1. Introduction
1.1. Welcome to Ensuro Re Ltd (“Ensuro”, “we”, “us”, or “our”). We are a blockchain-based, licensed reinsurance platform that enables decentralized capital support for insurance and protection products, leveraging smart contracts and decentralized finance to optimize capital efficiency, transparency, and accessibility.
1.2. Ensuro is a Bermuda-domiciled company regulated by the Bermuda Monetary Authority (BMA), licensed under both the Insurance Act 1978 as a Class IIGB insurer and the Digital Asset Business Act 2018 as a Class M digital asset business. All transactions between you and us are governed by the applicable Bermuda legislation and regulatory framework.
1.3. This Disclosure Statement is made pursuant to the requirements of the Bermuda Digital Asset Business (Client Disclosure) Rules 2018.
1.4. Please read this Statement carefully. It outlines essential information about Ensuro and our platform for all users and participants (“you” or “your”).
1.5. A glossary of defined terms is provided at the end of this Statement.
2. Our Platform
2.1. Ensuro operates a smart-contract-based platform on the Polygon blockchain, enabling the issuance of reinsurance and protection policies backed by digital asset capital. These insurance-linked contracts are priced, collateralized, and managed entirely on-chain.
2.2. All underwriting activities are carried out through individual Segregated Accounts (each a “Cell”) within our Segregated Accounts Company (SAC) structure. These Cells are capitalized by investors—referred to as Liquidity Providers or Capital Providers—who deposit funds via stablecoins such as USDC.
2.3. Capital Providers receive eTokens, which represent their proportional Capital Investment in a specific Cell and entitle them to earn yield based on policy performance and allocated risk.
3. Disclaimer
3.1. Except as expressly provided in a written agreement between you and Ensuro, we disclaim and exclude, to the fullest extent permitted by applicable law, all liability for any losses or damages arising from your use of the Platform, including any delay, failure, or interruption in operation, or any reliance on information obtained via the Platform.
3.2. Ensuro does not provide investment, legal, or tax advice. We make no recommendation as to the suitability, legality, or appropriateness of any eToken, Capital Investment, or Transaction. You should seek independent advice from qualified professionals regarding your personal circumstances before participating in our platform.
4. Material Risks
Ensuro’s platform involves significant risks. By participating, you confirm that you understand and accept the following material risks, which may result in partial or total loss of capital, illiquidity, loss of access to digital assets, or inability to transact on the platform.
A. Capital and Financial Risks
4.1. Capital Investments and Tokenized Assets Investing in Segregated Accounts (Cells) and holding eTokens involves the risk of:
Capital loss due to claim obligations or investment underperformance;
Illiquidity or delay in redemption during peak utilization;
Exposure to underlying (re)insurance risk models, which may prove inaccurate.
4.2. Insurance Claim Risk In the event of a valid claim:
4.2.1. Ensuro’s obligation is strictly limited to the assets available in the relevant Cell;
4.2.2. If those assets are insufficient, the claimant has no recourse to other Cells or to the General Account. Obligations are extinguished once the Cell’s assets are exhausted.
4.3. eToken-Specific Risks eTokens:
4.3.1. May lose all value due to protocol failure, insurance losses, or market events; 4.3.2. Are not legal tender and are not guaranteed or insured by any public authority; 4.3.3. Are not protected by deposit insurance or refund rights; 4.3.4. May become unsupported or discontinued due to technological or legal reasons; 4.3.5. Are non-voting instruments that do not confer equity in Ensuro; 4.3.6. May be subject to taxation, depending on your jurisdiction.
4.4. Underwriting and Pricing Risk Despite actuarial modeling (e.g., Value-at-Risk), there is a risk of:
Mispricing, claim surges, or catastrophic events depleting Cell capital;
Total loss of Capital Investment due to performance shortfall in a Cell.
4.5. Liquidity Risk
Capital and eTokens may not be redeemable on demand;
Liquidity can be constrained during high claim activity or market volatility.
4.6. DeFi Protocol Exposure Ensuro may allocate capital to third-party DeFi protocols. This introduces:
Smart contract vulnerabilities and potential exploits;
Governance risks due to centralized admin keys;
Losses due to liquidity crunches or systemic DeFi failure.
4.7. No Insurance Coverage for Token Loss Ensuro does not offer protection for:
Cyber attacks, platform failure, smart contract bugs, or DeFi exposure. You must evaluate these risks independently.
B. Operational, Technical, and Cyber Risks
4.8. Smart Contract and Platform Risks Despite rigorous testing and audits:
Smart contracts may contain unknown bugs;
Frontend, oracle, or settlement layer failure can disrupt functionality or fund access.
4.9. System Failures and Accounting Risks Due to the platform’s complexity, there may be:
Misstatements in financial reporting;
Operational errors due to technology or human oversight.
4.10. Cybersecurity Threats Ensuro applies advanced security protocols, but the following risks persist:
Phishing, wallet spoofing, malware, and smart contract exploits;
Data loss or system downtime from Distributed Denial of Service (DDoS) attacks;
Unauthorized wallet access if you do not protect your private keys.
4.11. Loss of Private Keys You are solely responsible for your wallet credentials. If lost or compromised, your eTokens and capital cannot be recovered by Ensuro.
4.12. User Profile Security
Profiles may be suspended or terminated by Ensuro at its discretion or due to legal requirements;
Actions via your profile are deemed authorized unless otherwise notified;
Unauthorized access may occur if your credentials are not adequately secured.
4.13. Data Handling and Privacy Risk
KYC/AML data is stored off-chain under compliance protocols, but remains vulnerable to breaches despite best practices.
C. Regulatory and Legal Risks
4.14. Legal Uncertainty in DeFi and Digital Assets The legal landscape governing blockchain, smart contracts, and tokenized assets is:
Rapidly evolving and varies across jurisdictions;
Subject to abrupt changes or restrictive interpretations by regulators.
4.15. Jurisdictional and Sanction Risks
Services are restricted in certain jurisdictions (e.g., the U.S., sanctioned countries);
You must ensure your participation does not violate any sanctions or local laws.
4.16. Regulatory Change Impact Changes in Bermuda or other jurisdictions may:
4.16.1. Force Ensuro to restrict, suspend, or cease services (including eToken issuance or redemptions);
4.16.2. Alter Ensuro’s business model, investment strategy, or compliance obligations;
4.16.3. Cause financial losses due to asset lock-up, token devaluation, or forced shutdown, without recourse or compensation.
D. Force Majeure and Service Availability Risks
4.17. Platform Disruption or Shutdown Risk In cases of regulatory intervention, technical failure, insolvency, or force majeure events, Ensuro’s platform and related services may become temporarily or permanently inaccessible, and funds may be delayed or inaccessible.
E. User Responsibility
4.18. Independent Evaluation Required
Ensuro provides no financial, legal, or tax advice.
You must evaluate all aspects of participation independently and consult your own advisors as needed.
Past performance is not indicative of future results.
5. Matters Applicable to Our Services
Regulatory Licenses
5.1. Ensuro Re Ltd is licensed by the Bermuda Monetary Authority (BMA) under:
a Class IIGB license under the Insurance Act 1978; and
a Class M license under the Digital Asset Business Act 2018 (DAB Act).
5.2. Ensuro is also registered as a Segregated Accounts Company (SAC) under the Segregated Accounts Companies Act 2000. These licenses subject Ensuro to Bermuda’s regulatory standards, including solvency, reporting, and operational conduct.
5.3. Suspension or revocation of any of Ensuro’s licenses could:
5.3.1. Prevent one or more Segregated Accounts (Cells) from writing or performing reinsurance contracts, potentially indefinitely or until regulatory approval is restored; 5.3.2. Undermine market confidence and materially affect Ensuro’s reputation, operations, and business continuity.
5.4. Schedule of Fees
Underwriting Fee: Up to 10% of the premium capital earned by the pool, applied at the time a risk is underwritten.
Blockchain Transaction (Gas) Fees: Variable fees paid by the user during interactions with smart contracts, dependent on blockchain network congestion.
All fees are processed transparently via smart contracts, allowing users to track them in real time.
Changes to the Fees & Charges
If we make any material changes a notice may be posted on this page along with the updated Fees & Charges structure, and an email notification will be sent to our Liquidity Providers prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our Fees & Charges.
Eligibility
5.5. All participants must complete Ensuro’s Financial Literacy Test, Know Your Customer (KYC) and Anti-Money Laundering (AML) onboarding process prior to engagement in any platform activity.
No Insurance Coverage
5.6. Ensuro does not provide insurance for:
Digital asset losses, cyber theft, smart contract bugs, or DeFi protocol failures.
You must factor this lack of coverage into your investment decisions.
Irrevocability of Blockchain Transactions
5.7. Once confirmed on the blockchain, all eToken transactions are final and cannot be reversed by Ensuro or any third party.
Governance and Voting
5.8. eToken holders do not receive governance or voting rights in Ensuro Re Ltd. Their rights are limited to economic participation in the performance of the specific Cell to which their tokens are linked.
General Rights and Obligations
5.9. Ensuro disclaims all liability to the extent permitted by law for any mistaken, unauthorized, or unintended token transfers. While we may, at our sole discretion, attempt to recover such assets, there is no obligation to do so.
5.10. You are responsible for ensuring that your contact and compliance details remain accurate and up to date for regulatory and operational communications.
5.11. A submitted transaction may only be cancelled if the instruction has not yet been processed on-chain.
5.12. Ensuro may decline to execute a transaction if doing so would violate applicable laws, AML rules, sanctions restrictions, or regulatory orders.
5.16. You may request a formal receipt of any on-platform transaction, which will be provided within 14 business days via email.
5.17. Where permitted under a governing agreement, we will notify you of changes to service terms or policies at least 30 days prior to effect via email or the platform interface.
5.18. Information
At the conclusion of any Transaction, you will have access to the following information through the Ensuro Platform or upon written request:
5.18.1. Ensuro Re Ltd.’s name and contact details
5.18.2. Contact information to:
(a) Access and manage your account;
(b) Inquire about our insurance, risk capital, or protocol operations;
(c) Submit a complaint through our formal complaint-handling procedures; 5.18.3. A record of each Transaction, including type, value, date, time, and transaction hash or reference ID; 5.18.4. A breakdown of any fees or commissions associated with the Transaction.
Our Structure
5.13. Ensuro Re Ltd. is a licensed Segregated Accounts Company (SAC) under Bermuda law. In accordance with the SAC Act, we must segregate the assets and liabilities of each Cell (Segregated Account) from those of other Cells and from Ensuro’s General Account.
5.14. Liabilities incurred by a Cell are obligations solely of that specific Cell. Creditors of one Cell have no recourse to the assets of other Cells or the General Account. Likewise, assets within a Cell may only be applied to liabilities linked to that same Cell.
5.15. This legal segregation is well-established under Bermuda law. However, other jurisdictions may not fully recognize the statutory protection offered by Bermuda’s SAC framework or may interpret it differently.
5.16. Holders of eTokens (Participation Tokens) issued through the Ensuro Platform have no ownership interest in Ensuro Re Ltd. or its affiliates. Their rights are strictly contractual and linked only to the performance of the specific Cell in which their eTokens are invested.
5.17. Ensuro’s operating model—where (re)insurance contracts are originated solely through fully collateralized Cells—aims to reduce systemic insolvency risk. However, in the event of Ensuro’s insolvency, some or all Cells may be unable to enter into new (re)insurance contracts or perform existing ones. In such cases, your eTokens may be rendered valueless.
5.18. As an innovative and relatively young entity operating at the intersection of insurance and DeFi, Ensuro has limited operating history. The rapidly evolving nature of blockchain and digital asset markets may impact our capacity to scale operations or respond to market and regulatory shifts.
6. Cyber Reporting
Ensuro shall notify affected clients without undue delay if a “cyber reporting event”, as defined in Section 2(1) of the Bermuda Digital Asset Business Act 2018, has occurred. This includes any event involving unauthorised access to, or misuse of, personal or transactional client data, or a breach of any of our cybersecurity protocols.
In accordance with our Cybersecurity Policy and Incident Response Plan, notifications will include a summary of the breach, remedial actions taken, and guidance for affected users. Ensuro is committed to maintaining transparency and regulatory compliance in the event of such incidents.
7. Privacy
For details on how Ensuro Re Ltd. collects, uses, stores, and shares your personal data, including your rights under applicable data protection regulations, please refer to our full Privacy Policy, available at: https://ensuro.co/PrivacyPolicy.pdf
We comply with Bermuda’s Personal Information Protection Act (PIPA) and any applicable privacy obligations in other jurisdictions in which we operate or engage clients.
8. Glossary
Agreement Means any agreement(s) entered into or proposed to be entered into between you and Ensuro for your access to and/or use of the Platform, and/or services provided in connection with a Segregated Account (Cell).
Blockchain Refers to distributed ledger technology that enables peer-to-peer electronic Transactions and records and shares such Transactions among users. The Ensuro Platform operates on public Blockchains, including but not limited to Polygon, using Smart Contract infrastructure.
BMA Means the Bermuda Monetary Authority, the regulatory authority for insurance and digital asset business in Bermuda.
Capital Investment The total financial contribution made by a Capital Provider to a specific Cell of Ensuro Re Ltd. in return for eTokens and subject to the terms set forth in the applicable Agreement.
Capital Provider An investor or entity that provides Capital Investment to collateralize insurance risk via a Cell and receives eTokens in return.
Capital Transaction Each individual transfer of funds by a Capital Provider to a Segregated Account, collectively forming their Capital Investment.
Claim A demand made under a (re)insurance contract for compensation based on the occurrence of an insured event.
Components All software, protocols, systems, APIs, Blockchain infrastructure, oracles, and other technologies required to operate the Ensuro Platform and to facilitate Transactions.
Cyber Attack Any unauthorized, unlawful, or accidental access to, or interference with, the Platform or its Components, including data breaches, system corruption, loss of data, or similar disruptive events.
DAB Act The Digital Asset Business Act 2018 (Bermuda), as amended from time to time, governing regulated digital asset activities in Bermuda.
eTokens Digital tokens issued to Capital Providers on the Platform representing their fractional Capital Investment in a Segregated Account and entitling them to returns based on Cell performance.
Fiat Government-issued currency such as USD, EUR, or GBP that is not backed by a commodity like gold or silver.
General Account Refers to the account within Ensuro Re Ltd. that holds assets and liabilities not linked to any Segregated Account.
Insurance Act The Bermuda Insurance Act 1978, as amended, and its related rules and regulations, governing insurance entities domiciled in Bermuda.
Insurance Contract A smart-contract-based (re)insurance agreement underwritten through a Segregated Account on the Ensuro Platform.
Insured An individual or entity that holds a valid Insurance Contract issued via the Ensuro Platform.
KYC “Know Your Customer”; a compliance process used to verify the identity of clients and investors in accordance with AML/CFT regulations.
Linked Describes the connection of a specific asset, right, liability, or obligation to a particular Segregated Account or to the General Account by reference in an Agreement, ledger entry, smart contract, or audit trail.
Platform The smart-contract-based infrastructure developed and operated by Ensuro Re Ltd. that enables decentralized risk capital provision, insurance contract management, and issuance of eTokens. Accessible at https://ensuro.co.
Premium The amount paid by an Insured in return for risk coverage under an Insurance Contract. Premiums are transferred into a Cell and contribute to yield for Capital Providers.
Profile A user’s verified account configuration on the Platform, containing permissions, wallet addresses, transactional data, and preferences.
SAC A Segregated Accounts Company under Bermuda law, required to maintain strict legal segregation of assets and liabilities between its Cells.
SAC Act The Segregated Accounts Companies Act 2000 of Bermuda, as amended, establishing legal requirements for SAC entities.
Safeguards Ensuro’s policies, protocols, and tools for detecting, mitigating, and responding to cyber threats and data breaches.
Segregated Account (Cell) A distinct legal account within Ensuro Re Ltd. used for underwriting a defined portfolio of (re)insurance contracts, with separate assets and liabilities. Each Cell supports a specific investment or insurance strategy.
Smart Contracts Computer programs deployed on the Blockchain that automatically execute terms of agreements, including Capital Investments and Insurance Contracts.
Sponsor A third party (e.g., MGA, insurer, DAO) for whom a Cell is established by Ensuro to originate and manage insurance business.
Statement This Disclosure Statement issued in accordance with Bermuda’s Digital Asset Business (Client Disclosure) Rules 2018.
Taxation All taxes, duties, levies, and contributions—whether direct or indirect—imposed by a governmental authority in Bermuda or elsewhere.
Tokens Digital assets, cryptocurrencies, or cryptographic representations of value that are used for economic and investment activities on the Blockchain.
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