Disclosures and counterparty information
What we are, what we are not, who provides each part of the service, and what you can ask us for in writing. Version 1.0, effective 20 September 2026.
What we are, and what we are not
The statements a counterparty needs before anything else. They are first because they are the ones that decide whether the rest is worth reading.
Mikupay is a financial technology company. It is not a bank.
We do not accept deposits, we do not lend, and we do not hold ourselves out as a bank in any jurisdiction.
Your balance is not a bank deposit and carries no deposit insurance.
Your balance is a record in your account ledger with us, and represents what we owe you under your agreement. It is not held on deposit for you at a bank, and it is not covered by the Federal Deposit Insurance Corporation, by any other deposit guarantee scheme, or by any government compensation programme.
Digital assets are not legal tender and are not covered by any compensation scheme.
USDT is issued by a private company, not by a government. Its value can fall, and its issuer’s arrangements are outside our control.
We provide accounts to business clients only, on an invitation basis.
We do not open accounts for consumers, and there is no self-service sign-up.
We do not publish client numbers, processed volumes or performance statistics.
Any figure of that kind would be unverifiable by the person reading it, so we do not publish one.
Nothing on this site is investment advice, a recommendation, or an offer of regulated services in any jurisdiction where making one would be unlawful.
Who provides each part of the service
For each product: who is on the other side of it, and where the governing document says so.
| Product | Provided by | Detail |
|---|---|---|
| Account, ledger and statements | Mikupay | Your account, the ledger of movements on it, the statements we produce from it, and the portal you read them in are operated by us directly. |
| USD funding | Mikupay, with banking services provided through a bank1 | You fund your account by bank wire to the receiving details allocated to your business. The bank at which those funds are held, and the basis on which they are held, are stated in your Account Agreement and confirmed to you in writing during onboarding. |
| USD to USDT conversion | Mikupay | Conversion is effected by us at the rate quoted for the transaction, together with the applicable fee. We do not add a spread to the underlying reference rate. |
| Settlement and payouts | Mikupay2 | Payouts are made by us, in USDT over TRC-20 or by bank transfer. Every request is reviewed by a person before it is processed, and a request can be declined. |
| Virtual cards | Issued under a card programme3 | We review applications and set the monthly limit. The entity that issues your card, and the terms that apply to it, are set out in the cardholder agreement provided to you before the card is used. |
| Identity and business verification | Mikupay | Verification is documentary and is carried out by our own compliance team. We do not use an automated identity vendor for the decision, and no automated system decides whether your account is opened. |
| Read-only ledger API | Mikupay | The API is operated by us and reads the same ledger your portal reads. A credential is scoped to one account and can read nothing else. |
Registered particulars
- Legal entity
- Mikupay
- Regulatory status
- Authorised to provide the services described in your service agreement.
The particulars above are the ones we publish. Anything not shown here — including a registration number or a supervisory authority where we have not listed one — is stated in your Account Agreement, and we will confirm it in writing on request rather than assert it on a web page.
Information available on request
If you are onboarding us as a counterparty, this is the list to work from. All of it is available before you commit to anything.
Certificate of incorporation and current registration extract
Confirms the legal entity, its registration number and its registered address.
Ownership and control structure
Directors, ultimate beneficial owners and the basis on which control is exercised.
Licences and registrations
Any money transmission, virtual asset or payment registration we hold, with reference numbers.
Anti-money laundering policy
Our full internal policy, alongside the published summary on this site.
Account Agreement and fee schedule
The complete terms that would govern your account, for review before you commit to anything.
Banking arrangements confirmation
Which institution holds client funds, in what capacity, and on what basis.
Data protection: sub-processors and transfers
The current sub-processor list, what each one does, and where the data is held.
Security questionnaire responses
Answers to a standard vendor security questionnaire (CAIQ or SIG), completed for your review.
Insurance in force
Details of any professional indemnity or crime cover we hold, where cover is in place.
Financial information
Where we are able to share it, and subject to a confidentiality agreement.
Sanctions, restricted jurisdictions and prohibited activity
Stated so that a prospective client can tell whether we can serve them before beginning onboarding.
We screen clients, their beneficial owners and their counterparties against sanctions lists before an account is opened and throughout the relationship. The lists we screen against include those published by the United States Office of Foreign Assets Control, the European Union, His Majesty’s Treasury in the United Kingdom, and the United Nations Security Council.
We do not open accounts for, and we will not process a payment to or from, any person or entity that is designated under those lists, or that is owned or controlled by a designated person. Where a match is identified we may freeze or refuse a transaction, and we may be required to report it without telling you.
We do not serve clients established in jurisdictions subject to comprehensive sanctions, and we do not process payments to or from those jurisdictions.
Applications from other jurisdictions are considered individually. Whether we can serve a particular business depends on its activity, its ownership and where its payments go — not only on where it is registered. We will tell you during onboarding if we cannot proceed, and why.
Activity we do not accept
- Trade in goods or services that are themselves unlawful in the jurisdictions involved.
- Activity intended to evade sanctions, or to conceal the identity of a party to a payment.
- Businesses operating without a licence where one is required for their activity.
- Unlicensed gambling, unlicensed money transmission, and the sale of controlled substances.
- Terrorist financing, human trafficking, fraud, and the proceeds of any of them.
- Use of an account to hold or move funds belonging to a third party who has not been verified by us.
Who else can touch your data
The complete list of third parties that process client data on our behalf.
| Provider | Purpose | Data | Location |
|---|---|---|---|
| Tencent Cloud | Hosting of the platform, the database and uploaded documents | All account, transaction and identity data held by us | Silicon Valley, United States |
| Resend | Delivery of transactional email (account notices, request outcomes) | Name, email address and the content of the notice | United States |
Where your data is held
Account records, transaction history and uploaded identity documents are stored on infrastructure operated by Tencent Cloud in Silicon Valley, United States. That is where the data physically sits, and it is the fact that matters for any transfer assessment you have to make.
How we protect it →What we do not do with it
- We do not sell client data, and we do not share it for advertising or analytics.
- We do not use client data to train machine learning models, ours or anyone else’s.
- We do not store full card numbers, card verification values or PINs — card applications do not collect them.
- We do not transfer client data to a sub-processor that is not on the published list without telling affected clients first.
- We do not make identity decisions by automated means alone.
How to complain, and what happens next
A complaint is handled as a complaint however it reaches us. You do not have to use a particular form.
If something has gone wrong, tell us. A complaint is handled as a complaint whether it arrives by email, through your account manager or through the portal — you do not have to use a particular form for it to be treated as one.
We acknowledge a complaint within 5 business days, and we give a substantive response, or explain why more time is needed, within 4 weeks. If we need longer, we tell you how much longer and why, and we give a final response within 8 weeks.
Where a complaint concerns a payment, include the reference shown on your statement for the transaction. That is usually the difference between resolving it in days and spending weeks establishing which payment is in question.
The process
- 1Send the complaint to the compliance address, marked as a complaint. Whether you send it to us directly or through your account manager, it is recorded and tracked the same way.
- 2We review what happened, which includes the internal record of the decisions taken on your account and who took them.
- 3We give you our outcome in writing, with the reasoning. If we got something wrong, we say so and say what we are doing about it.
- 4If you remain dissatisfied, we will tell you what further options are available to you, including any external body with jurisdiction over the matter.
Accessibility statement
What we have done, what we have not claimed, and how to report a barrier.
We aim to meet the Web Content Accessibility Guidelines 2.1 at level AA. We have not claimed formal conformance, because a claim of conformance is only worth making when it has been tested and holds for the whole site.
What we have done: semantic HTML with a logical heading order on every page; keyboard-operable navigation, forms and dialogs; form controls with associated labels; colour combinations chosen to meet the contrast thresholds in the guideline; and text that remains usable when the browser font size is increased.
If you meet a barrier — a control you cannot reach, text you cannot read, or a flow that does not work with your assistive technology — tell us at the support address. Describe the page and what happened, and we will treat it as a defect to fix rather than a preference.
Trademarks and affiliations
Which third-party marks appear on this site, who owns them, and what their use does and does not mean.
Mikupay and the Mikupay mark are used by Mikupay.
Visa and the Visa logo are registered trademarks of Visa International Service Association. Mastercard and the Mastercard brand marks are registered trademarks of Mastercard International Incorporated. They are used on this site only to identify the card network a card may be issued on. Their use does not imply any endorsement, sponsorship or affiliation.
USDT and Tether are trademarks of Tether Limited. TRC-20 and TRON are trademarks or registered trademarks of the TRON Foundation. SWIFT is a trademark of S.W.I.F.T. SCRL. These marks are used only to describe the networks and systems a payment is made through.
We are not affiliated with, endorsed by, or sponsored by any of the organisations named above, other than where a licence or programme agreement is expressly stated.
Notes
- 1Funds sent to your receiving details are credited to your ledger once they have settled. The account number is what identifies whose funds they are. Until a wire is credited, it is not part of your balance and is not available to you.
- 2A payout instruction that has been broadcast to a blockchain network cannot be recalled by us or by anyone else. Check the destination address and network before confirming a request.
- 3Card programmes are operated under licence from the relevant card network. Visa and Mastercard are registered trademarks of their respective owners, and are used only to describe the network a card is issued on.
Related documents
These disclosures sit alongside the agreement that governs an account. Where the two differ on the terms of a service, your Account Agreement prevails; this page is a description of the service, not a substitute for the contract.
Take the disclaimer seriously
Holding a balance with a payments company is not the same as holding money in a bank. If we fail, your balance is a claim against us as an unsecured creditor, and there is no deposit insurance or compensation scheme standing behind it.
That is true of every platform that is not itself a bank. What can be checked is who the entity is, what it is authorised to do, who holds the funds, and what the contract says about all three — which is what the rest of this page is for.
Mikupay provides accounts to business clients and does not offer services to the general public. This page is published as version 1.0, effective 20 September 2026. Earlier versions are available on request. Where a statement on this page conflicts with the Terms of Service or an Account Agreement, the agreement prevails.