Compliance & AML

Last updated: 16 July 2026

ZoPay is designed to support wallet screening, transaction monitoring, configurable risk decisions, audit records and payment-exception handling. This page describes how those controls are designed to work.

ZoPay is in pre-launch development. The controls below describe the platform's design and sandbox behaviour; the final compliance programme will be published before any live launch and is subject to review by Georgian legal counsel.

Merchant onboarding (KYB)

Before live access is granted, every merchant passes a know-your-business review: company registration documents, directors, beneficial owners, business activity and website. Each merchant receives a risk rating that drives the controls applied to its payments. High-risk categories, such as licensed gaming operators, receive enhanced due diligence and tighter transaction controls.

Transaction screening (KYT)

Every incoming transfer is screened by ZoPay's monitoring engine using blockchain-analytics data before funds are credited. Screening evaluates the sending wallet's exposure to sanctioned entities, mixers, stolen funds and darknet markets, and produces a documented risk score and decision for each payment.

High-risk transactions

Payments that exceed the configured risk threshold are placed on hold and are not credited to the merchant. A compliance officer reviews each held payment and approves, rejects or escalates it. Every decision is recorded with the reviewer, time and reason.

Sanctions alerts

A potential sanctions match freezes the payment immediately. Confirmed matches are escalated internally and reported to the relevant authorities as required by applicable law. Frozen funds are not released without a documented compliance decision.

Key management

Private keys are generated and stored encrypted inside an isolated signing service. Application code, merchants and support staff never have access to key material. Outgoing transfers pass policy checks — hot-wallet limits and destination controls — before signing.

Record keeping

Transaction records, screening results, ledger entries and administrator actions are stored in append-only form and are designed to be retained for the periods required by applicable Georgian law.

Regulatory export

For any payment, a complete dossier can be exported in one step: the event timeline, the blockchain transaction, the screening result, ledger entries, settlement references and all administrator actions.

Contact

Compliance questions: legal@zopay.io.