Regulatory & Legal Disclosures

1. About DAT PAY

DAT PAY is a financial technology and financial infrastructure platform operated by HACHTHER SARL, a company incorporated and registered in the Republic of Cameroon under RCCM No. RC/DLA/2019/B/1809, with Unique Identification Number (UIN) M041914224584L.

DAT PAY provides technology, software, connectivity, interfaces and infrastructure that may facilitate access to financial, payment and digital asset services.

DAT PAY is designed to operate within a regulated financial ecosystem and may connect users with appropriately authorised financial institutions, payment providers, digital asset service providers and other specialised service providers.

2. Regulatory Perimeter

HACHTHER SARL does not represent itself as a bank, credit institution, payment institution, electronic money issuer, money transfer institution, custodian, securities firm, investment manager or other regulated financial institution unless and to the extent that it holds the applicable authorisation.

Where a particular service constitutes a regulated activity under applicable law, that activity is performed by the relevant authorised institution or service provider.

The availability of a service through DAT PAY does not mean that HACHTHER SARL itself holds the licence or authorisation required to provide that service.

The legal and regulatory status of a particular service depends on:

• the nature of the service;
• the jurisdiction involved;
• the location and status of the customer;
• the relevant financial institution;
• the applicable regulatory framework;
• the structure through which the service is delivered.

3. Technology and Infrastructure Role

DAT PAY’s role may include providing:

• software;
• account interfaces;
• payment connectivity;
• API connectivity;
• transaction interfaces;
• financial data interfaces;
• workflow infrastructure;
• compliance technology;
• authentication infrastructure;
• digital asset infrastructure;
• reporting tools;
• transaction management functionality.

DAT PAY may facilitate communication and operational workflows between users and authorised financial institutions.

Providing technology that enables access to a regulated service does not, by itself, mean that DAT PAY performs the regulated activity.

4. Regulated Financial Services

Certain services accessible through the DAT PAY platform may involve regulated activities.

Depending on the product and jurisdiction, these may include:

• payment services;
• money transmission;
• electronic money services;
• banking services;
• foreign exchange;
• custody;
• digital asset services;
• card services;
• account services;
• settlement;
• other regulated financial activities.

Where authorisation is required, the relevant service is provided by an appropriately authorised institution.

The applicable institution may independently:

• onboard the customer;
• perform customer due diligence;
• assess risk;
• approve or reject transactions;
• hold funds or assets;
• execute payments;
• provide settlement;
• determine transaction limits;
• suspend or terminate services;
• perform regulatory reporting.

5. CEMAC and Cameroon

DAT PAY is operated by a company incorporated in Cameroon.

Financial and payment activities in the Central African Economic and Monetary Community are subject to applicable regional and national laws and regulations.

The CEMAC regulatory framework includes specific rules governing payment services and related activities. (Beac)

DAT PAY does not use its technology platform to represent that HACHTHER SARL is itself authorised to conduct a regulated activity for which it does not hold the required authorisation.

Where a service cannot lawfully be provided to a customer in Cameroon or another CEMAC jurisdiction without a specific licence, authorisation or regulatory structure, DAT PAY may:

• restrict access;
• decline onboarding;
• restrict particular products;
• restrict particular transaction types;
• require the service to be provided by an appropriately authorised institution;
• apply additional compliance controls;
• discontinue availability of the relevant service.

6. Jurisdictional Availability

DAT PAY services are not necessarily available in every country or territory.

Availability may depend on:

• local laws;
• licensing requirements;
• sanctions;
• regulatory restrictions;
• financial crime risk;
• service provider availability;
• customer residence;
• customer nationality;
• transaction destination;
• transaction origin;
• asset type;
• currency;
• product-specific restrictions.

DAT PAY may establish jurisdictional restrictions at any time where reasonably necessary to comply with applicable law, regulatory requirements or risk controls.

A service being displayed on the DAT PAY website does not constitute an offer to provide that service in every jurisdiction.

7. Restricted Jurisdictions and Persons

DAT PAY may restrict or prohibit access from certain jurisdictions, territories, persons or counterparties.

Restrictions may arise from:

• applicable sanctions;
• embargoes;
• AML/CFT requirements;
• regulatory restrictions;
• local licensing requirements;
• elevated financial crime risk;
• restrictions imposed by financial institutions;
• restrictions imposed by service providers;
• internal risk policies.

DAT PAY may also restrict transactions involving certain jurisdictions even where an account itself remains accessible.

8. Sanctions Compliance

DAT PAY maintains controls designed to prevent the platform from being used in violation of applicable sanctions and restrictive measures.

Screening may apply to:

• customers;
• beneficial owners;
• directors;
• authorised representatives;
• beneficiaries;
• counterparties;
• payment information;
• transaction information;
• digital asset wallet addresses;
• relevant jurisdictions.

Transactions may be rejected, delayed, blocked or subjected to additional review where necessary to comply with applicable sanctions requirements.

Where disclosure is prohibited by law, DAT PAY may not disclose the existence or details of a particular screening process or investigation.

9. Anti-Money Laundering and Counter-Terrorist Financing

DAT PAY operates with a risk-based approach to financial crime prevention.

Our controls may include:

• customer identification;
• customer due diligence;
• enhanced due diligence;
• beneficial ownership verification;
• source of funds verification;
• source of wealth verification;
• sanctions screening;
• PEP screening;
• adverse media screening;
• transaction monitoring;
• fraud monitoring;
• suspicious activity detection;
• ongoing customer risk assessment.

The exact controls applied may depend on the product, customer, jurisdiction, transaction and relevant Service Provider.

FATF standards recognise that virtual asset activities require risk-based AML/CFT measures and that relevant providers may be subject to licensing, registration, supervision and monitoring requirements. (FATF)

10. Customer Due Diligence

DAT PAY may require customers to provide information necessary to establish:

• identity;
• legal capacity;
• residence;
• business activity;
• ownership;
• beneficial ownership;
• source of funds;
• source of wealth;
• purpose of the relationship;
• expected transaction activity.

Additional information may be requested during the customer relationship.

Completion of onboarding does not prevent further due diligence from being conducted later.

DAT PAY may conduct ongoing monitoring where required by applicable law, contractual requirements or risk management procedures.

11. Enhanced Due Diligence

Additional controls may apply where a customer, transaction, jurisdiction or counterparty presents elevated risk.

Enhanced due diligence may be required because of:

• complex ownership structures;
• high-value transactions;
• unusual transaction patterns;
• high-risk jurisdictions;
• sanctions exposure;
• PEP status;
• adverse media;
• unusual source of funds;
• unusual source of wealth;
• digital asset exposure;
• transactions involving unhosted wallets;
• other financial crime indicators.

Additional documentation or explanations may therefore be required before a service can be provided.

12. Transaction Monitoring

Transactions processed through or connected to DAT PAY may be subject to monitoring.

Monitoring may consider:

• transaction value;
• transaction frequency;
• transaction patterns;
• origin and destination;
• counterparties;
• jurisdiction;
• payment information;
• digital asset information;
• wallet addresses;
• customer profile;
• expected activity;
• historical activity;
• risk indicators.

Monitoring may generate alerts requiring additional investigation or review.

A monitoring alert does not necessarily mean that a customer has committed wrongdoing.

13. Suspicious Activity

Where required by applicable law, DAT PAY or the relevant authorised institution may report information concerning suspected financial crime to competent authorities.

Such reporting may occur without prior notice to the customer where disclosure is prohibited by law.

DAT PAY may also preserve relevant records and restrict activity while an investigation is ongoing.

14. Digital Assets

DAT PAY may provide technology supporting access to digital asset functionality.

Digital assets may include cryptocurrencies, stablecoins, tokens and other blockchain-based assets where supported by the applicable service.

Digital asset services may involve risks that differ materially from traditional financial services.

These risks may include:

• price volatility;
• liquidity risk;
• blockchain network failure;
• transaction irreversibility;
• smart contract vulnerabilities;
• private key loss;
• cyberattacks;
• fraud;
• sanctions exposure;
• regulatory uncertainty;
• asset-specific restrictions.

The availability of digital asset functionality through DAT PAY does not mean that HACHTHER SARL itself is authorised as a virtual asset service provider in every jurisdiction.

Where licensing or registration is required, the relevant regulated activity must be performed by an appropriately authorised entity.

15. Blockchain Transactions

Blockchain networks operate independently of DAT PAY.

DAT PAY does not control:

• blockchain consensus;
• validators;
• network congestion;
• confirmation times;
• network fees;
• network upgrades;
• forks;
• protocol changes;
• blockchain availability.

Blockchain transactions may be irreversible.

Users are responsible for verifying the destination address, network, asset and amount before submitting a transaction.

Where a transaction is sent to an incorrect address or incompatible network, recovery may be impossible.

16. Unhosted Wallets and Counterparty Risk

Digital asset transactions may involve hosted or unhosted wallets.

Depending on the applicable regulatory framework and risk assessment, DAT PAY or a relevant Service Provider may require additional information concerning transactions involving unhosted wallets.

Transactions may also be subject to additional screening or restrictions where the counterparty cannot be appropriately identified or where the transaction presents elevated financial crime risk.

FATF’s current virtual asset framework specifically addresses transactions involving unhosted wallets, counterparty VASP due diligence and Travel Rule implementation. (FATF)

17. Travel Rule and Transaction Information

Where applicable to a particular service, digital asset transfers may be subject to Travel Rule requirements or equivalent regulatory information-sharing obligations.

This may require information concerning:

• originators;
• beneficiaries;
• originating institutions;
• beneficiary institutions;
• transaction details.

DAT PAY or the relevant Service Provider may request additional information before a transfer is processed.

A transfer may be delayed, rejected or restricted if legally required information cannot be obtained or verified.

FATF’s 2026 update reports continued global implementation of the Travel Rule and identifies implementation gaps as an ongoing regulatory concern. (FATF)

18. Payment Services

Where DAT PAY facilitates access to payment services, the relevant payment activity may be performed by an authorised financial institution or payment service provider.

The relevant provider may be responsible for:

• execution;
• settlement;
• safeguarding;
• payment account administration;
• regulatory reporting;
• transaction monitoring;
• customer funds handling.

DAT PAY’s technology layer does not itself constitute a payment licence.

19. Banking and Account Services

Where the DAT PAY interface displays banking or payment account information, the underlying account may be provided and maintained by a separate financial institution.

The legal relationship governing the underlying account may therefore be between the customer and the relevant financial institution.

DAT PAY does not guarantee that every account, balance or financial service displayed through its interface constitutes a deposit or financial product provided by HACHTHER SARL.

20. Custody and Safeguarding

Where funds or digital assets are held or safeguarded by an authorised third party, the applicable institution remains responsible for the relevant custody or safeguarding function within the scope of its authorisation.

DAT PAY does not represent that it provides custody unless expressly authorised and contractually designated to do so.

Users should review the terms governing the underlying custody or safeguarding arrangement.

21. Foreign Exchange

Where foreign exchange or currency conversion functionality is available, the relevant activity may be performed by DAT PAY or by an authorised financial or payment institution depending on the applicable product structure and jurisdiction.

The availability of currency conversion functionality does not constitute a representation that HACHTHER SARL is authorised to provide foreign exchange services in every jurisdiction.

Exchange rates may vary and may include applicable spreads or fees.

22. Cards and Payment Instruments

Where DAT PAY provides access to card or other payment instruments through an authorised partner, the relevant issuer or regulated institution remains responsible for the regulated issuance and operation of the payment instrument.

Terms governing the card or payment instrument may therefore be separate from DAT PAY’s general Terms of Use.

23. Third-Party Regulatory Status

DAT PAY may work with financial institutions, payment providers, technology providers and other specialised service providers operating under different legal and regulatory frameworks.

The regulatory status of a particular provider does not automatically extend to HACHTHER SARL.

Likewise, the existence of a regulated relationship between DAT PAY and a third party does not mean that HACHTHER SARL itself holds the third party’s licence.

Customers should review the regulatory disclosures applicable to the specific service they use.

24. No Regulatory Licence by Implication

Nothing on the DAT PAY website, application, client console, documentation, marketing materials or communications should be interpreted as:

• a representation that HACHTHER SARL holds a banking licence;
• a representation that HACHTHER SARL holds a payment institution licence;
• a representation that HACHTHER SARL is an electronic money issuer;
• a representation that HACHTHER SARL is a money transfer institution;
• a representation that HACHTHER SARL is a custodian;
• a representation that HACHTHER SARL is a licensed investment manager;
• a representation that HACHTHER SARL is a securities broker;
• a representation that HACHTHER SARL is a virtual asset service provider in every jurisdiction.

The regulatory status of each service must be assessed according to the actual service structure and applicable law.

25. No Circumvention of Regulation

DAT PAY does not intend to use technology, contractual structures, third-party integrations or other arrangements to circumvent applicable financial regulation.

Where a regulated activity requires authorisation, DAT PAY will seek to ensure that the relevant activity is conducted through an appropriately authorised structure.

DAT PAY may modify, restrict or discontinue a product where regulatory requirements change or where a particular structure is no longer considered appropriate.

26. Regulatory Cooperation

DAT PAY may cooperate with:

• financial regulators;
• central banks;
• competent authorities;
• law enforcement agencies;
• tax authorities;
• courts;
• financial institutions;
• payment institutions;
• compliance service providers.

Cooperation may include responding to lawful requests, providing information, preserving records and supporting investigations.

27. Record Keeping

DAT PAY may maintain records necessary to:

• operate the platform;
• comply with applicable law;
• satisfy AML/CFT requirements;
• support regulatory examinations;
• investigate fraud;
• resolve disputes;
• protect the platform;
• maintain audit trails;
• meet accounting and tax obligations.

Records may be retained after an account has been closed where required by law or legitimate regulatory requirements.

28. Regulatory Change

Financial regulation evolves continuously.

DAT PAY may change, suspend or discontinue services where necessary because of:

• new legislation;
• regulatory guidance;
• licensing requirements;
• supervisory decisions;
• sanctions;
• AML/CFT requirements;
• changes in financial crime risk;
• changes in digital asset regulation;
• changes in the availability of regulated partners.

A service that is available today may therefore become unavailable in a particular jurisdiction in the future.

29. No Offer or Solicitation

Information published by DAT PAY is provided for general informational purposes unless expressly stated otherwise.

Nothing on the website constitutes:

• an offer to provide a regulated financial service where such service requires an authorisation that has not been obtained;
• an offer of securities;
• investment advice;
• financial advice;
• a solicitation to invest;
• a recommendation to buy or sell a financial instrument or digital asset.

Specific product terms govern any service made available to an eligible customer.

30. Risk Disclosure

Financial and digital asset services involve risks.

Depending on the product, these may include:

• market risk;
• liquidity risk;
• foreign exchange risk;
• counterparty risk;
• settlement risk;
• operational risk;
• cyber risk;
• regulatory risk;
• legal risk;
• blockchain risk;
• technology risk.

Customers should evaluate the risks associated with a service before using it.

31. Jurisdictional Restrictions

Certain DAT PAY services may not be offered to residents, citizens, entities or counterparties located in particular jurisdictions.

Restrictions may apply based on:

• applicable law;
• regulatory licensing;
• sanctions;
• financial crime risk;
• product restrictions;
• partner requirements;
• internal risk policies.

DAT PAY reserves the right to determine eligibility for each service subject to applicable law.

32. Customer Responsibility

Customers are responsible for ensuring that their use of DAT PAY is lawful in their jurisdiction.

Customers must not use DAT PAY where doing so would violate:

• local law;
• sanctions;
• licensing requirements;
• tax obligations;
• financial regulations;
• restrictions applicable to digital assets;
• contractual restrictions.

The fact that DAT PAY makes a service technically accessible does not establish that the service is legally available to every customer.

33. Relationship With Other Legal Documents

This Regulatory & Legal Disclosures page should be read together with:

• DAT PAY Terms of Use;
• DAT PAY Privacy Policy;
• DAT PAY Cookie Policy;
• applicable product-specific terms;
• applicable financial institution disclosures;
• applicable service provider terms.

Where a product-specific agreement contains more specific regulatory terms, those terms may apply to that product.

34. Updates to Regulatory Disclosures

DAT PAY may update this page when:

• applicable laws change;
• regulatory requirements change;
• products change;
• service structures change;
• new jurisdictions are added;
• jurisdictions become restricted;
• regulatory authorisations change;
• third-party financial arrangements change.

The latest version will be published on the DAT PAY website.

35. Contact

Regulatory and legal enquiries may be submitted through the official contact channels published on the DAT PAY website.

HACHTHER SARL DAT PAY Republic of Cameroon

36. Legal Entity

DAT PAY is a financial technology and infrastructure platform operated by HACHTHER SARL, a company incorporated and registered in the Republic of Cameroon under RCCM No. RC/DLA/2019/B/1809, with Unique Identification Number (UIN) M041914224584L.

HACHTHER SARL provides technology, software, connectivity and infrastructure and may facilitate access to financial services provided by appropriately authorised third parties.