Payout Methods Policy

This Policy applies to each and every disbursement, transfer, advance, bonus, commission, revenue share, royalty, performance payment, milestone payment, reimbursement, expense settlement, and any other monetary or monetary-equivalent consideration (each, a “Payout”) that is intended to compensate, or has the effect of compensating, any Partner for services rendered, performance achieved, content delivered, exposure provided, products reviewed, or other participation in an Engagement. It applies irrespective of whether the Engagement is characterized as a paid sponsorship, unpaid ambassadorship, gifted seeding, affiliate arrangement, pay-for-performance campaign, or any similar nomenclature.

This Policy is incorporated by reference into, and supplements (without superseding), the Orno Terms of Service, the Master Services Agreement, each individual sponsorship contract or insertion order, and every other written agreement between Orno and any Brand or Partner. By executing any such agreement, or by initiating or accepting an Engagement on the Orno platform, each Brand and each Partner expressly acknowledges, agrees, and consents to be bound by every provision of this Policy.

Orno operates as the central contracting, compliance, and settlement layer between Brands and Partners. The integrity of every Engagement depends on Payouts being (i) remitted through channels that can be reconciled, audited, and traced; (ii) subject to proper tax withholding, information reporting, and anti-money-laundering controls; (iii) capable of supporting chargebacks, clawbacks, and reversals in the event of breach, fraud, or regulatory enforcement; and (iv) documented sufficiently to satisfy the Federal Trade Commission, the Internal Revenue Service, state revenue departments, and foreign regulators that exercise jurisdiction over the parties. Peer-to-peer wallet systems, instant-transfer applications, and informal payment channels cannot satisfy these requirements. This Policy exists to close that gap by restricting Payouts to a limited, approved set of institutional rails.

Capitalized terms used in this Policy shall have the following meanings. Terms defined in the singular include the plural, and vice versa; references to any statute or regulation include all amendments and successor provisions.

The following are the exclusive rails through which a Payout may be delivered to a Partner. Orno may add, suspend, or remove rails from this list at its sole discretion, with notice communicated through the Partner portal.

All Permitted Payout Rails deliver funds into a bank account held in the Partner’s verified legal name (or, for corporate Partners, in the Partner’s verified business name). Accounts held in the name of a third party, a nominee, or any person other than the Partner are not eligible to receive Payouts, regardless of any direction by the Partner to the contrary.

• Canadian Interac e-Transfer (including Interac e-Transfer Autodeposit, Interac e-Transfer for Business where used outside an Approved Payment Processor, and Request Money);
• PayPal — including PayPal Personal, PayPal Business outside an Approved Payment Processor arrangement, PayPal “Friends & Family” transfers, PayPal Goods & Services for sponsorship consideration, PayPal.Me links, PayPal invoices sent outside the platform, and PayPal Credit;
• Cash App (Block, Inc.) — including $cashtag transfers, business-account transfers for sponsorship consideration, and Cash App Pay;
• Venmo (including Venmo Business Profiles where used for sponsorship consideration), Zelle (peer-to-peer channel), Google Pay / Google Wallet peer transfers, Apple Cash / Apple Pay Cash, Samsung Pay peer transfers, Facebook Pay / Meta Pay peer transfers;
• International peer-wallet systems, including WeChat Pay, Alipay, UPI peer transfers, Paytm, PhonePe, Mercado Pago peer transfers, Revolut peer transfers, Wise personal transfers, N26 personal transfers, Monzo peer transfers, Starling peer transfers, and any successor or analogous service;
• Money-transmitter / remittance services used in person-to-person mode, including Western Union, MoneyGram, Remitly personal, Xoom, WorldRemit, Ria Money Transfer, and similar services when used to send funds to an individual recipient outside of an Approved Payment Processor integration;
• Cryptocurrency, stablecoins, and digital tokens of any kind, including Bitcoin, Ether, Solana, USDC, USDT, DAI, and any other on-chain asset (see Section 8);
• Gift cards, store credit, prepaid cards, and closed-loop value, whether reloadable or single-use (see Section 10);
• Cash of any kind, whether delivered in person, by courier, or otherwise (see Section 10);
• Unregulated peer-to-peer marketplaces and “wallet” applications not licensed as a money transmitter or equivalent in the jurisdiction of sender and recipient;
• Any transfer that lands in an account not held in the Partner’s verified legal name, including accounts held by a friend, family member, manager, agent, or shell entity, regardless of the instrument used;
• Any off-platform arrangement by which value is delivered to a Partner outside the Orno invoicing, reporting, and disbursement workflow (see Section 14).

Peer-to-Peer Wallet Systems, as defined in Section 3, are categorically excluded as a permissible Payout rail. The exclusion applies whether the wallet is accessed from a mobile device, a desktop browser, or a backend API; whether the sending party frames the transfer as “Friends & Family,” “Goods & Services,” “Business,” “Gift,” or any other product designation; and whether the funds settle to an underlying bank account or remain as a wallet balance.

The Brand shall not:

• Solicit or accept a Partner’s wallet handle, email address, phone number, QR code, or $cashtag as a payment destination;
• Direct any employee, agent, or affiliate to initiate a peer-to-peer transfer in lieu of a Permitted Payout Rail;
• Condition acceptance of any deliverable on Partner acceptance of a Prohibited Payment Instrument;
• Offer a larger amount via a Prohibited Instrument in exchange for a smaller amount via a Permitted Rail, or otherwise structure transactions to avoid this Policy.

The Partner shall not:

• Provide a wallet handle, $cashtag, PayPal.Me link, Venmo QR code, or similar destination to a Brand or its agents;
• Accept funds into a Peer-to-Peer Wallet System on behalf of an Engagement, regardless of any solicitation, offer, or inducement by the Brand;
• Direct the Brand to route funds via a Prohibited Instrument, whether by written request, oral instruction, or email signature;
• Receive consideration from a third party acting as a conduit for the Brand.

Canadian Interac e-Transfer (“e-Transfer”), operated by Interac Corp., is a Canadian interbank messaging service that transmits funds between accounts at participating Canadian financial institutions by reference to email address or SMS phone number. Notwithstanding that e-Transfer settles bank-to-bank, the service is excluded from Permitted Payout Rails because: (i) the addressing model does not provide Orno with counterparty-level beneficiary data sufficient to satisfy FINTRAC recordkeeping or FATF Travel Rule obligations in the hands of Orno’s U.S.-based compliance program; (ii) the typical Autodeposit or security-question flow does not support the pre-credit screening, withholding, and reversibility controls that Orno applies to institutional rails; and (iii) the fees, limits, timing, and reversal procedures of e-Transfer are inconsistent with the Orno milestone-release and clawback model.

Canadian Partners are instead remitted via international wire to a Canadian-domiciled bank account, via Approved Payment Processor disbursement, or via such other rail as is listed in the Partner portal. Orno does not and will not initiate or accept Payouts via Interac e-Transfer. Any purported Payout delivered by e-Transfer shall be treated as a side-channel payment under Section 14 and shall be reversed, clawed back, or offset against future Payouts at Orno’s discretion.

Payouts shall not be made in, denominated in, or settled through any cryptocurrency, stablecoin, central-bank digital currency, non-fungible token, in-game token, loyalty token, reward token, or other digital asset, whether on a public blockchain, a permissioned ledger, or an issuer-operated closed system. This exclusion applies regardless of whether the asset is routed through a licensed exchange, a self-custodied wallet, a smart contract, or a fiat-onramp service. Orno does not maintain the money-transmitter licenses, sanctions-screening infrastructure, or tax-reporting regimes necessary to handle digital-asset compensation, and the volatility and settlement-finality characteristics of such assets are incompatible with the Orno milestone-release and clawback model.

PayPal Holdings, Inc. and its affiliated services (including Venmo and Xoom) are categorically excluded from Permitted Payout Rails. This exclusion is not a statement about any particular provider’s regulatory status; it is an operational determination driven by (i) the provider’s retained authority to freeze, hold, reverse, or offset funds under provider-written user agreements without Orno’s consent; (ii) the provider’s ability to re-characterize transactions post-hoc (for example, reversing a “Friends & Family” transfer or applying a “Goods & Services” dispute) in a manner that disrupts Orno’s reconciliation; (iii) incompatibility between the provider’s dispute processes and Orno’s contractual milestone-release and chargeback procedures; and (iv) insufficient granularity of tax and KYC artefacts returned by the provider to satisfy Orno’s 1099 and 1042-S reporting obligations at the Partner level. The same considerations apply to Cash App (Block, Inc.), Zelle in its peer-to-peer mode, Apple Cash, Google Pay peer transfers, and analogous closed-wallet platforms.

Partners who hold accounts with any such provider may, of course, continue to use them in their personal capacity; this Policy restricts only Payouts that are connected to an Orno Engagement. If you are a Partner and you do not hold, or cannot hold, a traditional bank account or an Approved Payment Processor account, please contact payments@orno.io to discuss alternative arrangements under Section 16.

Cash (in any currency, whether physical or carried by courier), prepaid cards, gift cards, store credit, travel vouchers, merchandise credits, “points,” loyalty balances, cryptocurrency airdrops, and other in-kind value substitutes shall not be used as Payouts. Such instruments are untraceable, evade tax and information-reporting obligations, and, in some jurisdictions, trigger money-services-business licensing requirements for the issuer or transmitter.

The prohibition on in-kind substitutes does not apply to product seeding, sample shipments, or promotional inventory that is (i) treated as non-monetary consideration, (ii) disclosed to the Partner in writing, (iii) valued at fair market value for tax-reporting purposes where required, and (iv) separately disclosed under Orno’s FTC Compliance & Disclosures Policy. Such non-monetary consideration is not a “Payout” under this Policy but remains subject to the applicable disclosure, tax, and compliance rules.

This Policy is informed by, and aligns with, the following U.S. and international legal and regulatory regimes. The absence of any given authority from the list below does not narrow the scope of this Policy.

• Bank Secrecy Act (31 U.S.C. §§ 5311 et seq.) and implementing FinCEN regulations (31 C.F.R. Chapter X), including the Recordkeeping Rule, Travel Rule, and Customer Identification Program requirements;
• USA PATRIOT Act, including Section 326 customer identification obligations and enhanced due-diligence obligations for certain correspondent relationships;
• OFAC sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control, including the Specially Designated Nationals and Blocked Persons List and comprehensive country sanctions programs;
• Internal Revenue Code §§ 6041, 6041A, 6050W, and 1441–1446, governing information reporting for payments to service providers (Form 1099-NEC / 1099-MISC), for third-party settlement organizations (Form 1099-K), and for payments to non-U.S. persons (Form 1042-S);
• Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS), governing identification and reporting of foreign-account-holding Partners;
• Financial Action Task Force (FATF) Recommendation 16 (the Travel Rule) as implemented in the United States, the European Union’s Transfer of Funds Regulation (Regulation (EU) 2015/847, as recast by (EU) 2023/1113), and analogous foreign rules;
• EU Anti-Money-Laundering Directives (4AMLD, 5AMLD, 6AMLD) and Member-State implementing legislation;
• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), administered by FINTRAC;
• Federal Trade Commission Act, 15 U.S.C. § 45, and the Endorsement Guides (16 C.F.R. Part 255), requiring traceable records of Material Connections.

Each Brand covenants, represents, and warrants to Orno that, with respect to every Engagement:

1. The Brand shall fund every Payout exclusively via the Orno invoice-and-settlement workflow and solely through Permitted Payout Rails;
2. The Brand shall not solicit, offer, accept, or facilitate a Payout through any Prohibited Instrument, and shall not condition any deliverable on a Partner’s acceptance of such an Instrument;
3. The Brand shall not make, and shall not cause any agent, affiliate, employee, contractor, or intermediary to make, any side-channel payment as described in Section 14;
4. The Brand shall preserve records of every funded Payout for not less than seven (7) years and shall produce such records upon Orno’s reasonable request;
5. The Brand shall cooperate with any audit, inquiry, subpoena, or regulatory investigation concerning Payouts remitted to Partners in connection with an Orno Engagement;
6. The Brand shall indemnify Orno against any tax, fine, penalty, interest, disgorgement, or other liability arising out of the Brand’s violation of this Policy.

Each Partner covenants, represents, and warrants to Orno that, with respect to every Engagement in which the Partner participates:

1. The Partner shall accept Payouts exclusively through a Permitted Payout Rail into an account held in the Partner’s verified legal name (or, for corporate Partners, the Partner’s verified business name);
2. The Partner shall not solicit, request, encourage, or accept a Payout via any Prohibited Instrument, whether from the Brand, the Brand’s agents, or any intermediary;
3. The Partner shall not direct funds to a third-party account, nominee account, family-member account, or “friend account,” regardless of the instrument used;
4. The Partner shall maintain current and accurate payment-method records in the Partner portal, including bank-account details, routing information, and required tax-residency documentation (Form W-9 for U.S. persons; Form W-8BEN or W-8BEN-E for non-U.S. persons, as applicable);
5. The Partner shall disclose to Orno any offer or attempted offer from a Brand to remit consideration via a Prohibited Instrument, via a side-channel payment, or otherwise in violation of this Policy;
6. The Partner shall not characterize any Prohibited Instrument offer, if one is made, as “a favor,” “a gift,” or “off-platform” to evade this Policy.

A “side-channel payment” is any transfer of value from a Brand (or any person acting on the Brand’s behalf) to a Partner (or any person acting on the Partner’s behalf) that relates to an Engagement but that is not routed through the Orno invoice, approval, and disbursement workflow. Side-channel payments are categorically prohibited regardless of the instrument used, the stated purpose, or the parties’ characterization.

Side-channel payments unwind the compliance posture of every Engagement they touch and expose the parties to tax, FTC, and AML liability for which Orno bears no responsibility. Any side-channel payment discovered by Orno, whether through audit, self-report, platform signal, or third-party report, shall be grounds for immediate termination of the Brand’s or Partner’s participation, forfeiture of pending Payouts, and referral to tax authorities where applicable.

Upon any violation, or reasonably suspected violation, of this Policy, Orno may, in its sole and absolute discretion and with or without prior notice, exercise any one or more of the following remedies:

• Suspend or permanently terminate the Brand’s or Partner’s access to the Orno platform;
• Freeze, withhold, offset, claw back, or forfeit any pending or future Payout otherwise payable to the offending party;
• Assess liquidated damages of Five Thousand U.S. Dollars (US $5,000) per instance of non-compliance, which the parties agree represents a reasonable forecast of compensatory damages and not a penalty; Orno may assess the greater of that per-instance amount or three (3) times the value of the Prohibited Payout in cases of willful or repeated violation;
• Report the transaction to the Internal Revenue Service (including by issuance of corrected information returns), the applicable state tax authority, FinCEN, OFAC, FINTRAC, or any other competent authority where required;
• Notify the payment provider of the Prohibited Instrument and request reversal or freeze of the transaction where available;
• Publish an internal or external advisory identifying the non-compliant party as having violated this Policy;
• Pursue injunctive relief, damages, disgorgement, restitution, pre- and post-judgment interest, attorneys’ fees, costs, and any other relief available at law or in equity.

Orno does not grant blanket exceptions to this Policy. Individualized alternative arrangements (for example, for Partners in jurisdictions where traditional banking is impracticable) may be considered only upon written request to payments@orno.io, and only where (i) the proposed rail is operated by a regulated financial institution or money-services business, (ii) the proposed rail settles into an account in the Partner’s verified legal name, (iii) the proposed rail supports KYC, AML screening, and tax-reporting artefacts at a standard equivalent to the Permitted Payout Rails, and (iv) the Orno finance and compliance teams issue a written approval specific to the requesting Partner or Brand. No exception is effective unless and until such written approval has issued; oral assurances, email acknowledgements short of a written approval, and “grandfathered” prior dealings do not constitute an exception.

Orno reserves the right, at its sole and absolute discretion, to amend, restate, supplement, or supersede this Policy at any time and from time to time. Amendments become effective upon publication of the amended Policy at https://orno.io/legal/payout-methods or, in the case of material amendments, upon such additional notice as Orno reasonably determines. Continued participation in the Orno platform following the effective date of any amendment constitutes full and unconditional acceptance of the amended Policy.

If any provision of this Policy is held invalid, illegal, or unenforceable by a court or tribunal of competent jurisdiction, such provision shall be severed from the Policy, the remaining provisions shall continue in full force and effect, and the severed provision shall be reformed only to the minimum extent necessary to render it enforceable, consistent with the original intent. The obligations set forth in Sections 4, 5, 6, 7, 8, 9, 10, 12, 13, 14, and 15 shall survive the termination, expiration, or rescission of any agreement between Orno and any Brand or Partner for so long as any Payout or associated obligation remains outstanding or for seven (7) years, whichever is longer.

Payout setup, exception requests, policy interpretation, and reports of suspected violations should be directed to:

By initiating or accepting an Engagement facilitated by Orno, each Brand and each Partner acknowledges receipt of, consents to, and is bound by every term of this Policy.