KYC/AML Policy

General Provisions

Nylo LLC (hereinafter "NYLO", "we", "us", or "our"), a company incorporated under the laws of Georgia (Law of Georgia “On Entrepreneurs”) with registration number 412790154 and registered address at 88 Avtomshenebeli St, Kutaisi Free Zone, Land Plot 01/298, Kutaisi, Georgia, is committed to maintaining the general standards of anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance.

NYLO facilitates payment transactions between end users (“Users”) and merchants, acting solely as a technical intermediary. NYLO does not offer wallet, custodial, or account services and does not conduct direct KYC/AML screening of Users. However, we maintain oversight responsibilities as part of our compliance framework and reserve the right to act in cases of suspicion related to financial crime.

Responsibility for KYC/AML Compliance

All identity verification (KYC) and AML procedures are conducted by the Payment Provider chosen by the User to perform the transaction and the Merchant user purchasing goods or services from. These Payment Providers are licensed and regulated financial institutions, subject to the applicable laws in their respective jurisdictions. They are solely responsible for collecting, verifying, and storing personal data required for AML/CTF compliance.

NYLO does not directly collect or verify documents or information for AML/KYC purposes, nor does it provide onboarding or screening services to Users. The User’s identity, transaction behaviour, and source of funds are assessed by the Payment Provider prior to executing the payment.

NYLO’s Oversight and Right to Request Information

While NYLO does not conduct initial onboarding, it retains the right to request additional KYC data or explanations from the User under the following conditions:

• Where there is a reasonable suspicion that a transaction may be related to money laundering, terrorist financing, fraud, or other criminal conduct;
  
  
• When required to fulfil obligations under applicable legal or contractual frameworks (e.g., in cooperation with the Payment Provider, payment institutions, or law enforcement authorities);
  
  
• In cases of discrepancies, risk flags, or inconsistencies identified through transaction monitoring or internal risk-based reviews performed by the Payment Provider or Merchant.

The requested information may include, but is not limited to:

• Proof of identity;
  
  
• Source of funds and/or source of wealth;
  
  
• Clarification of the purpose of the transaction.
  
  

Failure to provide such information may result in the suspension or rejection of the transaction or termination of access to NYLO’s services.

Monitoring and Cooperation

NYLO applies limited transaction monitoring on a risk-based basis to detect anomalies and respond to red flags reported by the Payment Provider or Merchant. NYLO does not block or freeze funds but may withhold settlement to the merchant or suspend its own processing if a transaction appears suspicious and further inquiry is required.

NYLO cooperates with the Payment Provider, Merchants, and competent authorities to address suspicious activity. This includes, when legally obligated, reporting suspicious behaviour or responding to law enforcement inquiries in accordance with applicable AML/CTF laws.

Prohibited Activities and Jurisdictions

In line with industry standards and legal obligations, NYLO prohibits the use of its platform by Users involved in or associated with:

• Money laundering or terrorist financing;
  
  
• Fraud, cybercrime, identity theft and other criminal offences;
  
  
• Sanctioned individuals or entities, including those listed by the EU, UN, OFAC, or other competent authorities;
  
  
• Countries and territories are recognised as Prohibited Jurisdictions in our Terms of Use.
  
  

NYLO reserves the right to restrict access to the platform for Users from prohibited jurisdictions or those engaging in prohibited activities.

Data Protection

Any personal data provided during AML-related inquiries is processed in accordance with our Privacy Policy, the General Data Protection Regulation (GDPR) (where applicable), and the Law of Georgia on Personal Data Protection (2023). Data is handled securely and disclosed only when legally required or to fulfil compliance obligations.

Final Statement

By using NYLO’s services, the User acknowledges and agrees to the described AML/CTF measures and understands that transactions may be subject to review, delay, or refusal in case of compliance concerns. NYLO aims to support a safe and transparent environment and reserves the right to update this policy to reflect regulatory developments or internal risk assessments.

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