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Fiat Provider Compliance Documentation

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Overview

Nova Wallet integrates with 5 licensed third-party fiat on-ramp/off-ramp providers to enable users to buy and sell cryptocurrency using traditional payment methods. All providers are fully licensed and regulated financial services companies that handle their own KYC/AML compliance. Important: Nova Wallet does not process payments directly. All fiat transactions are handled by the third-party providers via their hosted checkout flows.

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Fiat Providers

All providers perform their own:

• Identity verification (KYC)
• Anti-money laundering (AML) checks
• Transaction monitoring
• Sanctions screening

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Country Availability by Provider

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MoonPay (169 Supported Countries)

Supported Countries: Blocked Countries (42): Why These Countries Are Blocked:

• Sanctions Compliance: Countries under OFAC (Office of Foreign Assets Control) sanctions including Iran, North Korea, Syria, Cuba, Russia, Belarus
• Regulatory Restrictions: Countries where cryptocurrency regulations prohibit or restrict fiat on-ramp services (China, Bangladesh, Pakistan)
• Compliance Requirements: Countries where MoonPay cannot meet local regulatory requirements or lacks necessary licenses
• Risk Management: Countries with high financial crime risk or unstable regulatory environments

References:

• MoonPay Terms of Service
• MoonPay Licenses & Registrations

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Mercuryo (199 Supported Countries)

Supported Countries: Mercuryo supports a comprehensive list of 199 countries and territories. Availability is determined dynamically based on real-time compliance checks. Generally supported regions include: Note: Mercuryo performs real-time sanctions screening and may restrict access from countries subject to OFAC, EU, or UN sanctions, even if not explicitly listed as blocked. Why Countries May Be Blocked: Mercuryo determines blocked countries based on their internal compliance policies and real-time sanctions screening. Restrictions are typically applied for:

• OFAC and EU sanctions compliance
• Local regulatory requirements
• Risk assessment and AML policies
• Real-time sanctions list updates

References:

• Mercuryo Legal
• Mercuryo Licenses

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Banxa (Dynamic Country List)

Banxa supports approximately 100+ countries and determines availability dynamically based on:

• User’s IP address geolocation
• Payment method availability
• Local regulatory requirements

Generally Supported Regions:

• Europe (EU/EEA)
• United Kingdom
• Australia & New Zealand
• Canada
• United States (select states)
• Southeast Asia
• Latin America

Why Availability Varies:

• State-Level Regulations (US): Different US states have varying cryptocurrency regulations, affecting availability
• Payment Method Restrictions: Some payment methods (credit cards, bank transfers) may not be available in all countries
• Regulatory Compliance: Banxa must comply with local financial services regulations in each jurisdiction
• Licensing Requirements: Availability depends on Banxa’s licensing status in each country

References:

• Banxa Terms of Service
• Banxa Regulatory

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Transak (Dynamic Country List)

Transak supports approximately 150+ countries with real-time availability checks based on:

• User location
• Cryptocurrency type
• Payment method

Generally Supported Regions:

• Europe (EU/EEA)
• United Kingdom
• United States (select states)
• India
• Southeast Asia
• Latin America
• Africa

Why Availability Varies:

• Cryptocurrency-Specific Restrictions: Some cryptocurrencies may be restricted in certain countries due to regulatory concerns
• Payment Method Availability: Different payment methods have different country coverage
• Real-Time Compliance: Transak performs real-time checks against sanctions lists and regulatory requirements
• State-Level Regulations: US state regulations affect availability within the United States

References:

• Transak Terms of Service
• Transak Compliance

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Paybis (Hardcoded Country List)

Supported Countries (180+): Paybis supports over 180 countries and territories worldwide. Generally supported regions include: Restricted Countries (22) - OFAC & Conflict Zones: Why These Countries Are Blocked:

• OFAC Sanctions: Countries subject to US Treasury Department sanctions (Iran, North Korea, Syria, Cuba, Russia, Belarus, etc.)
• Armed Conflicts: Countries experiencing active armed conflicts that pose compliance and operational risks
• Disputed Territories: Regions with unclear sovereignty or territorial disputes
• Regulatory Compliance: Paybis blocks these countries to comply with international sanctions and maintain regulatory compliance

References:

• Paybis Terms of Service
• Paybis Regulatory Info

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Swap/DEX Feature Restrictions

For decentralized exchange (DEX) swaps, the app restricts access only from OFAC-sanctioned countries: Users from these regions see: “Swaps are not available in your region due to regulatory restrictions.” Why These Restrictions Exist:

• OFAC Compliance: US Treasury Department sanctions prohibit US persons and entities from engaging in financial transactions with these countries
• Apple App Store Guidelines: Compliance with Apple Guideline 3.1.5 regarding financial services and regional restrictions
• Regulatory Requirements: Ensuring compliance with international sanctions regimes

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How Restrictions Are Enforced

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1. IP-Based Geolocation

• User’s IP address is detected on API requests
• Backend determines country via IP geolocation service
• Providers check if country is in their allowed list

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2. Provider-Level Enforcement

Each provider maintains their own country allowlist and blocklist, which is checked before allowing any transaction to proceed.

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3. Per-Asset Restrictions

Some cryptocurrencies have additional country restrictions beyond the provider level, based on regulatory concerns or licensing requirements.

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4. Real-Time Sanctions Screening

All providers perform real-time sanctions screening during:

• Account creation
• Each transaction
• Periodic re-verification

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KYC/AML Compliance

All KYC/AML verification is handled by the third-party providers: Nova Wallet does not collect, store, or process any user identity documents. All providers are licensed financial services companies that comply with:

• FATF (Financial Action Task Force) recommendations
• Local AML/CFT regulations in their jurisdictions
• Sanctions screening against OFAC, UN, EU, and other sanctions lists
• Transaction monitoring for suspicious activity

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Error Messages

Users in restricted regions see appropriate error messages:

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Compliance Verification

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Provider Licenses & Registrations

MoonPay:

• FCA (Financial Conduct Authority) - UK: FCA Register
• FinCEN (Financial Crimes Enforcement Network) - US: MSB Registration
• AUSTRAC (Australian Transaction Reports and Analysis Centre) - Australia: Registration

Mercuryo:

• Estonian FIU (Financial Intelligence Unit) - Estonia: Mercuryo Licenses

Transak:

• FinCEN (Financial Crimes Enforcement Network) - US: MSB Registration
• Transak Compliance

Banxa:

• AUSTRAC (Australian Transaction Reports and Analysis Centre) - Australia: Registration
• FINTRAC (Financial Transactions and Reports Analysis Centre) - Canada: Registration
• FCA (Financial Conduct Authority) - UK: Registered as BNXA UK VASP
• MiCA (EU) - Netherlands: EU Internet Ventures B.V.

Paybis:

• FinCEN (Financial Crimes Enforcement Network) - US: MSB Registration #31000224635628
• Poland VASP - Revenue Administration Chamber in Katowice: RDWW-805
• Paybis Regulatory Info

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Regulatory Compliance

All providers comply with:

• Anti-Money Laundering (AML) regulations in their jurisdictions
• Know Your Customer (KYC) requirements
• Counter-Terrorism Financing (CFT) regulations
• International sanctions (OFAC, UN, EU)
• Data protection regulations (GDPR, CCPA, etc.)

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Contact Information

For compliance inquiries:

• MoonPay: [email protected]
• Mercuryo: [email protected]
• Transak: [email protected]
• Banxa: [email protected]
• Paybis: [email protected]

Nova Wallet Compliance: [email protected]

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