Compliance Statement

Effective Date: 28 February 2026  
Version: 2.0
THRIFTPAY® is committed to maintaining high standards of governance, compliance, risk management, and operational integrity.

As a financial infrastructure provider, we support licensed financial institutions with technology, operational frameworks, and digital capabilities that help expand sustainable MSME financial access at scale.

THRIFTPAY® does not provide regulated financial services directly to consumers or businesses unless permitted by applicable law.

Our Compliance Philosophy

THRIFTPAY® believes that sustainable financial inclusion requires strong governance, regulatory accountability, responsible innovation, and transparent operating standards.

Our infrastructure is designed to help licensed financial institutions serve MSMEs more efficiently while maintaining compliance with applicable regulatory requirements.

We support a compliance-first approach that promotes trust, resilience, and long-term financial ecosystem growth.

Regulatory Structure & Operating Model

THRIFTPAY® operates as a technology and infrastructure provider.

The company:

  • Develops and provides financial infrastructure solutions for licensed institutions
  • Does not accept customer deposits
  • Does not hold or safeguard client funds
  • Does not originate loans directly to end-users unless specifically authorized
  • Does not act as a regulated financial institution where licensing is required

Financial products and regulated services made available through the THRIFTPAY® ecosystem are provided by appropriately licensed financial institutions operating within their respective jurisdictions.

THRIFTPAY® provides technology, operational support, analytics, and digital infrastructure that enable those institutions to expand financial access responsibly.

Financial Crime Prevention & Risk Management

THRIFTPAY® supports efforts to combat financial crime and strengthen financial system integrity.

We encourage our institutional partners to maintain robust risk management frameworks and comply with applicable anti-money laundering (AML), counter-terrorist financing (CTF), sanctions, and fraud prevention requirements.

THRIFTPAY® supports compliance through:

  • Risk-aware platform design
  • Secure operational processes
  • Transparent partner onboarding standards
  • Internal governance and oversight controls
  • Ongoing monitoring of operational risks

We do not tolerate the misuse of our infrastructure for unlawful or harmful activities.

Responsible Customer Due Diligence

Customer onboarding, identity verification, and regulatory due diligence are the responsibility of the licensed financial institutions providing regulated services.

THRIFTPAY® supports these institutions by enabling:

  • Digital onboarding workflows
  • Data management and record-keeping capabilities
  • Secure identity verification integrations
  • Risk assessment and monitoring tools
  • Compliance reporting infrastructure

All Know Your Customer (KYC), Customer Due Diligence (CDD), and ongoing monitoring obligations remain under the control and supervision of the licensed financial institution responsible for the customer relationship.

Governance & Internal Controls

THRIFTPAY® maintains governance processes designed to promote:

  • Ethical business conduct
  • Accountability and transparency
  • Operational resilience
  • Effective risk management
  • Responsible decision-making
  • Continuous improvement of compliance standards

We seek to align our governance framework with internationally recognized best practices while supporting sustainable growth across the financial ecosystems we serve.

Data Protection & Information Security

Protecting information and maintaining secure infrastructure are fundamental to THRIFTPAY® operations.

We implement appropriate administrative, technical, and organizational safeguards designed to:

  • Protect sensitive information
  • Prevent unauthorized access
  • Support data confidentiality and integrity
  • Enhance operational resilience
  • Promote secure digital financial services

Where applicable, THRIFTPAY® complies with relevant data protection laws and regulatory requirements in the jurisdictions in which it operates.

Risk Disclosure

THRIFTPAY® provides technology and infrastructure services and does not provide financial, investment, tax, or legal advice.

The performance, availability, and regulatory obligations of financial products offered through partner institutions remain the responsibility of the relevant licensed financial institution.

Users, partners, and stakeholders should conduct their own due diligence before entering into financial arrangements.

Ethical Conduct

THRIFTPAY® is committed to conducting business with integrity, fairness, and accountability.

We strive to:

  • Avoid conflicts of interest
  • Act transparently in partner relationships
  • Promote responsible financial innovation
  • Respect applicable laws and regulations
  • Support sustainable financial inclusion objectives

These principles guide how we engage with regulators, partners, investors, and stakeholders across all markets.

Regulatory Engagement

THRIFTPAY® supports constructive engagement with regulators, policymakers, and industry stakeholders.

We believe collaboration between technology providers, licensed financial institutions, and regulatory authorities is essential for expanding secure and sustainable MSME financial access.

Where appropriate, we seek to contribute to industry dialogue, regulatory cooperation, and the development of responsible financial infrastructure frameworks.

Partner With THRIFTPAY® To Expand Sustainable MSME Financial Access

Enable licensed financial institutions to deliver scalable digital financial services, strengthen operational efficiency, and extend responsible access to underserved MSMEs through modern financial infrastructure.