Regulatory Notice

This Regulatory Notice explains the role of Novolut, the nature of the services described on this website, and the regulatory and infrastructure conditions that apply to access, availability and use.

This notice applies to the Novolut website, platform materials, product descriptions, use cases, partnership materials, request forms and related public communications.

1. Novolut’s role

Novolut provides a financial infrastructure operating layer for international business.

The Novolut platform is designed to help qualified businesses and approved partners coordinate access, workflows, records, routing, reporting and reconciliation across connected financial infrastructure.

Novolut may support workflows involving accounts, payments, FX, liquidity coordination, approved settlement flows, corporate cards, payment acceptance, reporting and operational controls through one controlled platform environment.

Novolut does not provide all underlying regulated financial services directly. The underlying regulated infrastructure may be provided by approved banking, payment, EMI, issuing, acquiring, custody, settlement, liquidity, FX, compliance or other infrastructure partners, depending on the product, jurisdiction, use case and approval status.

2. Novolut’s regulatory boundaries

Unless expressly stated in a separate written agreement, Novolut is not:

• a bank;
• an electronic money institution;
• a card issuer;
• an acquirer;
• a custodian;
• a digital asset exchange;
• a broker-dealer;
• a payment institution for all routes or services;
• a provider of banking, custody, acquiring, issuing or settlement services in every jurisdiction.

Novolut does not present itself as replacing the role, license, regulatory responsibility, onboarding decision, safeguarding obligation or compliance approval of any regulated infrastructure partner.

Where regulated services are required, such services are provided by the relevant approved infrastructure partner under its own licensing, regulatory, contractual and compliance framework.

3. Infrastructure partner services

Products and workflows described on the website may depend on third-party infrastructure partners.

These partners may include banking providers, EMIs, payment providers, card issuers, acquirers, custody providers, liquidity providers, OTC desks, settlement providers, compliance providers or other regulated infrastructure participants.

Each infrastructure partner may apply its own:

• onboarding requirements;
• KYB, KYC and UBO checks;
• sanctions and PEP screening;
• transaction monitoring standards;
• documentation requests;
• business activity restrictions;
• jurisdictional limitations;
• operating limits;
• pricing and fee structures;
• approval, rejection, suspension or termination decisions.

Approval by Novolut does not automatically mean approval by any infrastructure partner. A client, partner, product, account, route, wallet structure, card program, merchant profile, settlement workflow, corridor or transaction may be accepted by one infrastructure partner and restricted, reviewed or declined by another.

4. Access is subject to approval

Access to Novolut products, workflows, platform functionality, partner infrastructure or commercial arrangements is not automatic.

Access may be subject to:

• company-level onboarding;
• KYB, KYC and UBO verification;
• director and ownership checks;
• sanctions and PEP screening;
• business activity review;
• source-of-funds or source-of-activity review;
• expected-flow assessment;
• transaction purpose review;
• jurisdictional assessment;
• wallet screening where applicable;
• infrastructure partner approval;
• contractual approval;
• technical approval;
• compliance and risk review.

Novolut may decline, pause, review, restrict, suspend or terminate access to any client, partner, user, transaction, payment route, wallet record, merchant profile, card program, settlement workflow, corridor, product, service or infrastructure layer where required.

5. No public offer or guaranteed service

Information on the Novolut website is provided for general informational purposes only.

Nothing on this website constitutes:

• a public offer;
• a binding commitment to provide services;
• a guarantee of onboarding;
• a guarantee of product availability;
• a guarantee of account opening;
• a guarantee of payment execution;
• a guarantee of settlement, custody, issuing, acquiring or liquidity access;
• financial, investment, legal, tax or regulatory advice;
• an invitation to engage in prohibited or unsupported activity.

All product descriptions, use cases, availability statements, supported markets, currencies, rails, settlement options and infrastructure references are subject to change and may depend on onboarding results, infrastructure coverage, provider requirements, contractual terms and compliance approval.

6. Availability may vary by jurisdiction and use case

The availability of Novolut products and workflows may vary by jurisdiction, client type, business activity, ownership structure, transaction profile, currency, market, payment route, payment method, infrastructure partner coverage and compliance result.

A product, route, feature or workflow described on the website may not be available to all clients or partners.

Access to one product or workflow does not automatically create access to all other products, routes, currencies, payment methods, settlement flows, card programs, acquiring channels or infrastructure partners.

Novolut may modify, suspend, withdraw or discontinue access to any product, workflow, provider route, settlement method, market, currency or infrastructure arrangement in response to legal, regulatory, operational, commercial, partner, risk-management or security requirements.

7. Digital asset and stablecoin-related workflows

Where digital asset or stablecoin-related workflows are described, they are intended only for approved business, treasury, settlement or operational use cases where supported.

Novolut does not support unrestricted digital asset activity, anonymous activity, undocumented flows, speculative retail trading, prohibited transactions, payment laundering, sanctions exposure or activity inconsistent with an approved business profile.

Stablecoin settlement workflows, wallet-related records, digital asset flows or conversion pathways may be subject to separate onboarding, wallet screening, source-of-funds review, transaction monitoring, infrastructure approval and documentation requirements.

Digital asset custody, settlement, execution or liquidity services, where applicable, may be provided by approved third-party infrastructure partners under their own terms, licensing position, risk controls and compliance requirements.

8. Client funds and safeguarding

Novolut does not hold client funds on its own balance sheet unless expressly stated in a separate written agreement and permitted under applicable law.

Fiat funds, where supported, may be held or safeguarded through approved banking, payment or EMI infrastructure partners under their applicable regulatory and contractual frameworks.

Client balances or records displayed inside the Novolut platform may represent operational visibility, records, workflow status or reporting data. They do not necessarily mean that Novolut acts as a bank, EMI, custodian or holder of client assets.

The exact safeguarding, custody, account, settlement and legal treatment of funds or assets may depend on the infrastructure partner, jurisdiction, currency, product, client status, contractual terms and applicable regulatory requirements.

9. Partner and commercial arrangements

Novolut may enter into different commercial arrangements with approved clients, infrastructure partners, flow partners, referral partners or strategic partners.

Such arrangements may include direct platform access, referral arrangements, flow partnerships, infrastructure partnerships or dedicated commercial contours.

No partnership, referral, revenue share, dedicated contour, infrastructure integration or commercial model is created by viewing the website, submitting a request form or discussing a potential opportunity.

Any partnership or commercial arrangement is subject to separate review, due diligence, compliance checks, infrastructure feasibility, commercial approval and written agreement.

10. Compliance, monitoring and restrictions

Novolut may apply risk-based controls across platform access, onboarding, workflows, transactions, reporting, reconciliation and ongoing monitoring.

Novolut does not support:

• anonymous activity;
• undocumented flows;
• misleading business activity;
• unauthorized third-party processing;
• transaction miscoding;
• payment laundering;
• sanctions exposure;
• illegal activity;
• prohibited goods or services;
• unrestricted digital asset activity;
• activity inconsistent with an approved company profile;
• attempts to bypass provider, compliance or regulatory restrictions.

Novolut may request additional information, documents, transaction rationale, source-of-funds evidence, wallet ownership details, counterparty information, invoices, supplier details or other supporting materials before allowing a workflow to proceed.

11. Website information may change

Novolut may update, amend or remove website content, product descriptions, use case descriptions, infrastructure references, legal notices, availability statements, compliance requirements, policies or terms at any time.

Website content may not always reflect the latest onboarding requirements, infrastructure partner conditions, regulatory changes, commercial arrangements or product availability.

The applicable terms for any approved client, partner or infrastructure arrangement will be set out in the relevant written agreement and onboarding materials.

12. Contact

Questions about this Regulatory Notice may be submitted through the Novolut request form.

Novolut reviews legal and regulatory inquiries according to the nature of the request, the applicable service context and the relevant infrastructure arrangement.

Submission of a request does not create platform access, onboarding approval, service eligibility or any commercial relationship with Novolut.

For legal or regulatory matters, contact: [email protected]