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Compliance Statement

EvoPay LLP

Effective Date: January 1, 2026

Last Updated: January 23, 2026

1. Introduction

EvoPay LLP (BIN 240440034473) ("EvoPay," "we," "us," or "our") is committed to operating with the highest standards of legal and regulatory compliance. This Compliance Statement outlines our dedication to adhering to applicable laws, regulations, and industry best practices in the Republic of Kazakhstan and internationally. As a regulated payment service provider and escrow agent, we prioritize transparency, security, and ethical conduct in all our operations.

2. Regulatory Framework

EvoPay operates under the legal and regulatory framework of the Republic of Kazakhstan, including but not limited to:

  • The Law of the Republic of Kazakhstan "On Payments and Payment Systems."
  • The Law of the Republic of Kazakhstan "On Counteracting the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism" (AML/CFT).
  • The Law of the Republic of Kazakhstan "On Personal Data and Their Protection."
  • The Civil Code of the Republic of Kazakhstan.
  • Regulations issued by the National Bank of the Republic of Kazakhstan and other relevant authorities.

We are registered and licensed in accordance with the requirements of Kazakhstani legislation and maintain ongoing dialogue with regulatory bodies to ensure full compliance.

3. Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT)

3.1. Our Commitment

We have a zero-tolerance policy towards money laundering, terrorist financing, and other illicit financial activities. Our AML/CFT program is designed to detect, prevent, and report suspicious activities.

3.2. Key Measures

  • Customer Due Diligence (CDD): We verify the identity of all users through a robust Know Your Customer (KYC) process.

  • Enhanced Due Diligence (EDD): Applied to high-risk customers, transactions, or jurisdictions.

  • Transaction Monitoring: We employ automated and manual systems to monitor transactions for unusual patterns.

  • Sanctions Screening: All users and transactions are screened against global sanctions lists (UN, OFAC, EU, etc.).

  • Reporting: We promptly report suspicious transactions to the Financial Monitoring Agency of the Republic of Kazakhstan.

  • Record Keeping: We maintain comprehensive records as required by law for at least seven (7) years.

3.3. Prohibited Activities

EvoPay services must not be used for:

  • Transactions involving prohibited goods or services.
  • High-risk activities without appropriate authorization.
  • Any activity that violates international sanctions.

4. Data Protection and Privacy

We adhere strictly to the Law of the Republic of Kazakhstan "On Personal Data and Their Protection" and other relevant data privacy regulations. Our Privacy Policy and Data Processing Agreements ensure that personal data is:

  • Collected lawfully and transparently.
  • Used only for specified, legitimate purposes.
  • Stored securely with appropriate technical and organizational measures.
  • Retained only as long as necessary.
  • Processed in accordance with users' rights.

Our Data Protection Officer (DPO) oversees compliance and can be contacted at dpo@evopay.kz.

5. Financial and Operational Compliance

5.1. Secure Fund Handling

  • Client funds are held in segregated accounts with reputable financial institutions.
  • We maintain sufficient liquidity to meet all obligations at all times.
  • Regular internal and external audits are conducted to ensure financial integrity.

5.2. Escrow Compliance

  • Our escrow service operates under a strict fiduciary framework.
  • Funds are released only according to the terms agreed upon by all parties.
  • Dispute resolution processes are fair, transparent, and documented.

5.3. Consumer Protection

  • We provide clear terms of service and pricing.
  • We maintain a dedicated customer support team to resolve issues.
  • Users have access to transparent transaction histories and records.

6. Ethical Business Conduct

EvoPay is committed to:

  • Integrity: Honest and transparent dealings with all stakeholders.

  • Fairness: Equitable treatment of all users.

  • Confidentiality: Protecting sensitive business and user information.

  • Anti-Corruption: Prohibiting bribery, corruption, and conflicts of interest.

All employees and partners are required to adhere to our Code of Conduct and undergo regular compliance training.

7. International Compliance

While based in Kazakhstan, we recognize the global nature of digital payments. We therefore:

  • Monitor and, where applicable, comply with international regulations such as the EU's GDPR for users in the European Economic Area (EEA).
  • Implement cross-border compliance measures for transactions involving foreign jurisdictions.
  • Cooperate with international regulatory bodies where legally required and appropriate.

8. Compliance Governance

8.1. Compliance Officer

Our designated Compliance Officer oversees the implementation and effectiveness of all compliance programs.

8.2. Internal Controls

We maintain a system of internal controls, including:

  • Regular risk assessments.
  • Independent compliance audits.
  • Incident reporting and management procedures.

8.3. Training

All relevant staff receive ongoing training on AML/CFT, data protection, and ethical standards.

9. Reporting and Transparency

We are committed to transparency in our compliance efforts. This includes:

  • Publishing annual transparency reports (where applicable).
  • Responding to legitimate information requests from authorities.
  • Maintaining open channels for user inquiries regarding compliance.

To report a compliance concern or suspected violation:

Email: compliance@evopay.kz

All reports are treated confidentially.

10. Continuous Improvement

Compliance is an ongoing commitment. We regularly:

  • Review and update our policies and procedures.
  • Monitor changes in legislation and regulatory expectations.
  • Implement improvements based on audits, incidents, and industry developments.

This Compliance Statement is a public declaration of our principles and commitments. It does not create third-party rights or constitute legal advice.