Regulatory Compliance by Jurisdiction

ProofPay is committed to the responsible and compliant deployment of its financial technology platform. As part of our global rollout strategy, the ProofPay platform will launch in phases across multiple jurisdictions, including (but not limited to): United States, European Union, Singapore, United Arab Emirates, Hong Kong, India, China, South Korea, Japan, Panama, Brazil, South Africa, Canada, and Ukraine.

This strategy reflects the complexities of national and regional financial regulations governing digital payments, stablecoins, programmable money, and cross-border value transfers.

Key jurisdiction-specific considerations include:

• United States: Subject to money transmitter licensing (MTL), oversight by FinCEN, state-level approvals, and CFPB consumer protection rules. Guidance from the SEC and CFTC may further shape platform features.
• European Union: Requires compliance with MiCA, the E-Money Directive, PSD2, and GDPR obligations for data privacy.
• Singapore: Regulated under the Payment Services Act (PSA), with licensing by MAS for digital token services, e-money issuance, and AML/CFT compliance.
• United Arab Emirates: Governed by the VARA and ADGM frameworks, including virtual asset sandbox testing and phased rollouts.
• Hong Kong: Requires regulatory approval from the HKMA and SFC in alignment with Hong Kong’s stablecoin regulation roadmap.
• India: Requires compliance with RBI directives, FEMA, data localization rules, and regulatory sandbox participation where applicable.
• China: Deployment depends on PBoC policy, cross-border pilot zones, and restrictions on private stablecoins.
• South Korea: Subject to VASP registration, AML compliance under the Specific Financial Transaction Information Act, and FSC supervision.
• Japan: Governed by the Payment Services Act, requiring registration as a funds transfer service provider or classification under prepaid instruments.
• Panama, Brazil, South Africa, Canada, Ukraine: Engagement with relevant financial authorities such as Brazil’s CVM & Central Bank, South Africa’s IFWG, Canada’s FINTRAC, and Ukraine’s National Bank is ongoing. Each market has unique AML/CFT and stablecoin licensing requirements.

ProofPay’s phased rollout ensures that no feature or product is launched without full compliance in each applicable region. Timelines and feature availability will vary by jurisdiction, reflecting the status of licensing, regulator consultation, and legal validation.

ProofPay reserves the right to defer or modify product availability in any country based on emerging legal, regulatory, or policy developments.