What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2026-06-08 compared with 2026-04-22 · 36 added, 31 removed, 122 unchanged (35% of the section changed)

2 unchanged sentences

Management and Strategy

Company has adopted a cybersecurity risk management framework designed to identify, assess, and manage material risks arising from cybersecurity

threats to its information systems, client data, and financial technology infrastructure.

Company has adopted a cybersecurity risk management framework designed to identify, assess,

and manage material risks arising from cybersecurity threats to its information systems,

client data, and financial technology infrastructure.

Key elements of our framework include:

12 unchanged sentences

risk management.

We rely on certain third-party service providers for technology infrastructure, cloud computing, and payment

We assess the cybersecurity practices of material vendors as part of our onboarding and ongoing monitoring processes;

however, we cannot guarantee that third parties will maintain adequate safeguards at all times.

We rely on certain third-party

service providers for technology infrastructure, cloud computing, and payment processing.

We assess the cybersecurity practices of

material vendors as part of our onboarding and ongoing monitoring processes;

however, we cannot guarantee that third parties will

maintain adequate safeguards at all times.

with enterprise risk management.

1 unchanged sentence

Material cybersecurity risks are reported to senior management and escalated to the Board of Directors as warranted.

Company’s regulated subsidiaries are subject to cybersecurity and data protection requirements under applicable financial services

regulations, including requirements imposed by the MFSA, FCA, and ASIC.

Compliance with these frameworks is reviewed as part of each

subsidiary’s ongoing regulatory supervision.

of December 31, 2025, we are not aware of any cybersecurity incidents that have materially affected, or are reasonably likely to materially

Company’s regulated subsidiaries are subject to cybersecurity and data protection requirements

under applicable financial services regulations, including requirements imposed by the MFSA,

FCA, and ASIC.

Compliance with these frameworks is reviewed as part of each subsidiary’s

ongoing regulatory supervision.

December 31, 2025, we are not aware of any cybersecurity incidents that have materially affected, or are reasonably likely to materially

affect, our business, results of operations, or financial condition.

3 unchanged sentences

for a discussion of cybersecurity-related risks.

The Board of Directors is responsible for overseeing the Company’s cybersecurity risk management.

Senior management

provides the Board with periodic updates on the cybersecurity threat environment, the status of the Company’s security posture,

significant vulnerabilities or incidents, regulatory developments, and the effectiveness of remediation efforts.

The Board reviews and

approves the Company’s overall risk management framework, within which cybersecurity risk is addressed, and engages with management

on cybersecurity matters as circumstances warrant.

Primary responsibility for cybersecurity risk management rests with the Company’s Chief Executive Officer, Mitchell M.

Eaglstein, who also serves as the Company’s principal technology and operations executive and Chief Financial Officer, Imran Firoz,

who serves as the Company’s principal finance and controller executive.

of Directors is responsible for overseeing the Company’s cybersecurity risk management.

Senior management provides the Board with periodic updates on the cybersecurity threat environment,

the status of the Company’s security posture, significant vulnerabilities or incidents,

regulatory developments, and the effectiveness of remediation efforts.

Board reviews and approves the Company’s overall risk management framework, within

which cybersecurity risk is addressed, and engages with management on cybersecurity matters

as circumstances warrant.

Primary responsibility

for cybersecurity risk management rests with the Company’s Chief Executive Officer, Mitchell M.

Eaglstein, who also serves as the

Company’s principal technology and operations executive and Chief Financial Officer, Imran Firoz, who serves as the Company’s

principal finance and controller executive.

Eaglstein and Mr.

Firoz have over 20 years of experience

each in financial technology and SEC-reporting companies, with extensive involvement in information systems, regulatory compliance, and

operational risk management.

Day-to-day cybersecurity activities are coordinated by our technology team across our operating subsidiaries,

with support from external IT security consultants where specialized expertise is required.

Management reports cybersecurity matters

to the Board through regular updates and, for potentially material incidents, through immediate escalation.

Firoz have over 20 years of experience each in financial technology

and SEC-reporting companies, with extensive involvement in information systems, regulatory compliance, and operational risk management.

Day-to-day cybersecurity activities are coordinated by our

technology team across our operating subsidiaries, with support from external IT security consultants where specialized expertise is

Management reports cybersecurity matters to the Board through regular updates and, for potentially material incidents, through

immediate escalation.

Operating Leases

31 unchanged sentences

The down payment for the lease was approximately $6,300.

The lease is for one year and is

renewable two months prior to the term’s end in June 2025.

This agreement is classified as a residential rental contract rather

than a commercial lease and does not create a Right-of-Use (ROU) asset under ASC 842.

for one year and is renewable two months prior to the term’s end in June 2025.

This agreement is classified as a residential rental

contract rather than a commercial lease and does not create a Right-of-Use (ROU) asset under ASC 842.

Cyprus Lease, Europe (ATECH Office)

62 unchanged sentences

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K/A

Item 1B. Unresolved Staff Comments