Regulatory information

Sezvo is the brand under which financial services are offered by UAB Aušra Pay, a private limited liability company incorporated and registered in the Republic of Lithuania. When you open an Sezvo account, hold a balance, make a payment or receive funds, your contractual counterparty is UAB Aušra Pay. "Sezvo", "we", "us" and "our" throughout our legal documents refer to UAB Aušra Pay unless a specific service is expressly stated to be provided by a third party.

UAB Aušra Pay is a licensed electronic money institution (EMI), authorised and supervised in Lithuania. Our services are operated from the European Union and offered to eligible customers across the European Economic Area (EEA) and, on a country-by-country basis, in selected markets across more than 160 countries where local law permits us to operate.

Payments and accounts use Lithuanian (LT) IBANs. Our business identifier code for SWIFT/BIC purposes is OCENLT22. This means inbound and outbound international payments addressed to your account are routed to a Lithuanian-domiciled, EU-regulated institution.

UAB Aušra Pay holds an electronic money institution licence granted by the Bank of Lithuania (Lietuvos bankas), the national competent authority responsible for the prudential supervision and conduct oversight of payment and electronic money institutions in Lithuania. The licence authorises us to issue electronic money and to provide the associated payment services set out in the Lithuanian Law on Electronic Money and Electronic Money Institutions, which implements the EU Electronic Money Directive (Directive 2009/110/EC) and the Payment Services Directive (Directive (EU) 2015/2366, commonly known as PSD2).

The authorisation covers, among other things:

• the issuance, distribution and redemption of electronic money;
• the execution of payment transactions, including credit transfers, direct debits and card-based payments;
• the operation of payment accounts and services enabling cash to be placed on and withdrawn from a payment account;
• the issuing and acquiring of payment instruments, such as the virtual and physical cards we provide; and
• money remittance and related ancillary services.

Our activities are conducted in accordance with the conditions of that licence and the ongoing requirements imposed by the Bank of Lithuania, including capital, governance, reporting and safeguarding obligations described later in this notice.

Because UAB Aušra Pay is authorised in an EU member state, we benefit from the single-market passport for financial services. Under the freedom to provide services and, where applicable, the freedom of establishment, we are able to offer our e-money and payment services to customers across the European Economic Area without obtaining a separate licence in each country.

Passporting is administered through the Bank of Lithuania, which notifies the host-state competent authorities of the EEA countries in which we intend to operate. In every passported market your relationship remains with a Lithuanian-licensed institution, and the Bank of Lithuania remains our home-state regulator for prudential supervision. Local conduct rules and consumer protection law may also apply in your country of residence, and where they do, we comply with them.

Availability of specific products varies by country. Some features — for example certain card programmes, investing, lending or particular currencies — may not be offered in your jurisdiction. The features available to you are those shown inside the Sezvo app at the time you use it.

An electronic money institution is a regulated financial institution authorised to issue electronic money and provide payment services. Electronic money is monetary value stored electronically that represents a claim on the issuer, is issued on receipt of funds, and is accepted as a means of payment. When you top up your Sezvo account, we issue you e-money of equivalent value, which you can then spend, send or redeem.

It is important to understand how this differs from a bank:

• We do not lend out your money. A bank takes deposits and uses them to fund lending and other activities, operating on a fractional-reserve basis. As an EMI, we are not permitted to use customer funds for our own account. The money you hold with us is not a deposit; it is e-money fully backed by safeguarded funds.
• Your money is safeguarded, not deposited. Customer funds are held separately from our own money in dedicated safeguarding accounts (see below), rather than forming part of our balance sheet to lend against.
• The protection model is different. EMI safeguarding and a bank deposit guarantee scheme are distinct mechanisms. We explain how each applies to Sezvo below — being accurate about this distinction matters.

Where we describe Sezvo in everyday language — "account", "balance", "savings" — we use those words for clarity. They do not change the legal nature of the service, which is the issuance of electronic money by a licensed EMI.

Protecting your money is the single most important obligation we have as an EMI. In line with the Electronic Money Directive and PSD2, the funds you hold with Sezvo are safeguarded and kept entirely separate from UAB Aušra Pay's own corporate funds.

We safeguard customer funds by:

• placing them in segregated safeguarding accounts held at one or more regulated credit institutions, ring-fenced from our operating money; and/or
• where permitted, covering them with an equivalent insurance policy or comparable guarantee from an authorised provider.

Segregation means that, in the unlikely event of our insolvency, safeguarded customer funds do not form part of our general estate and are not available to our creditors. They are reserved for the benefit of customers and distributed to them in priority, in accordance with the applicable insolvency and safeguarding rules. This is the core protection that an EMI structure provides.

We reconcile safeguarded balances against customer liabilities on a regular basis to ensure that the amount safeguarded always corresponds to the e-money outstanding. Safeguarding applies to the balance held in your current account and savings vaults. It does not extend to investments or crypto-assets, which are subject to the separate arrangements described later.

We want to be precise here, because the distinction is often misunderstood. Sezvo is an electronic money institution, not a bank, and e-money is not itself a deposit. The primary protection for the money you hold with us is safeguarding, described above, rather than a deposit guarantee scheme.

Where eligible deposits are protected under the applicable deposit guarantee scheme, that protection applies up to €100,000 per eligible depositor per participating institution. The scope of any such scheme, and whether it applies to your particular balance, depends on how and where the relevant funds are held. Safeguarding under the EMI regime and a deposit guarantee scheme are separate mechanisms and should not be conflated: safeguarding protects e-money holders through segregation, whereas a deposit guarantee scheme compensates eligible depositors of a failed credit institution.

Neither mechanism protects against investment losses or the loss of value of crypto-assets. The value of investments can fall as well as rise, and crypto-assets are unregulated and volatile.

When you add money to your Sezvo account, we issue electronic money equal to the amount received, at par value. We do not issue e-money at a discount, and we do not grant interest purely for holding e-money — any returns shown on savings products are described and governed separately under the terms for those products.

You have a statutory right of redemption. At any time, you may redeem the monetary value of the e-money you hold — in whole or in part — at par value. In practice, this means you can withdraw your available balance back to an external account in your name, send it by transfer, or spend it. We will not impose disproportionate charges for redemption, and any conditions or fees that do apply are set out transparently in our fees schedule and the framework contract.

Redemption may be subject to standard checks, including identity verification, fraud and sanctions screening, and applicable limits. Where we are required by law to delay or decline a transaction — for example, because of an anti-money-laundering or sanctions obligation — we will act in accordance with those requirements, which may temporarily prevent immediate redemption.

As a regulated financial institution, UAB Aušra Pay operates a comprehensive anti-money-laundering (AML) and counter-terrorist-financing (CFT) programme, built to meet Lithuanian law implementing the EU Anti-Money Laundering Directives and the standards of the Financial Action Task Force (FATF). Compliance with these obligations is overseen by the Bank of Lithuania and the relevant Lithuanian authorities.

Our framework includes:

• Customer due diligence (CDD) and "know-your-customer" checks at onboarding, including identity verification and, where relevant, verification of beneficial ownership for business accounts;
• Enhanced due diligence for higher-risk customers, relationships and transactions, including politically exposed persons;
• Ongoing monitoring of transactions to detect unusual or suspicious activity, supported by automated screening and rules;
• Sanctions screening of customers and payments against applicable EU, United Nations and other relevant sanctions lists, and the freezing or rejection of transactions where required;
• Reporting of suspicious activity to the competent Financial Crime Investigation Service / Financial Intelligence Unit as required by law; and
• record-keeping, staff training and independent assurance over the effectiveness of these controls.

We may be required to request additional information or documents from you at any time, to delay, decline or reverse a transaction, or to suspend or close an account, in order to meet these obligations. Where the law permits us to explain such an action we will, but in some cases — particularly suspicious activity reporting — we are legally prohibited from disclosing the reason.

Sezvo offers commission-free investing in thousands of stocks and exchange-traded funds (ETFs), including fractional shares from as little as £1. These investing services are made available under the applicable investment-services framework and are separate from your e-money account. They are governed by their own terms, and may be provided by or together with an authorised investment-services partner where required by local law.

Capital is at risk. The value of investments and the income from them can go down as well as up, and you may get back less than you invested. Past performance is not a reliable indicator of future results. Fractional shares, currency movements where you invest in assets denominated in another currency, and market volatility can all affect outcomes. We do not provide investment advice or personal recommendations; you are responsible for your own investment decisions.

Investor-protection arrangements differ fundamentally from the safeguarding that applies to your e-money balance. Where an investor compensation scheme applies, it generally protects against the failure of the firm holding your assets — not against the loss of value of an investment that performs poorly. Investments are typically held in a custody arrangement designed to keep client assets separate from the firm's own assets. The specific protections, custodian and scheme that apply to your investments are set out in the investing terms available in the app.

Sezvo provides an on-chain, self-custodial crypto wallet across nine networks: Ethereum, Arbitrum, Polygon, BNB Chain, Optimism, Base, Avalanche, Bitcoin and TRON. Please read these disclosures carefully before using it.

• Crypto-assets are unregulated. Our crypto-asset services are not the same as our regulated e-money and payment services. Crypto-assets generally fall outside the protections that apply to e-money or investments — they are not safeguarded as e-money, are not covered by a deposit guarantee scheme, and are not covered by an investor compensation scheme.
• The wallet is self-custodial. You control the private keys and therefore the assets. We do not hold custody of your crypto-assets and cannot move, freeze or recover them on your behalf. If you lose access to your keys or recovery phrase, or send assets to the wrong address or network, the funds may be permanently and irretrievably lost. Blockchain transactions are generally irreversible.
• Crypto-assets are highly volatile. Their value can fall sharply and rapidly, and you may lose all of the money you put in. Network fees, liquidity, smart-contract risk and the risk of scams or malicious contracts all apply.
• You are responsible for compliance and tax. Treatment of crypto-assets varies by jurisdiction, and you are responsible for understanding the rules and any tax obligations that apply to you.

Do not invest in crypto-assets money you cannot afford to lose. If you do not fully understand the risks, you should not use the wallet.

As a licensed EMI, UAB Aušra Pay is required to hold and maintain a minimum level of regulatory own funds (capital), calculated in accordance with the methods set out in the applicable Lithuanian and EU rules and reported to the Bank of Lithuania. This capital sits separate from, and in addition to, the safeguarded customer funds described above; the two serve different purposes and are never commingled.

We maintain governance and internal-control arrangements appropriate to a regulated institution, including:

• a management body responsible for the firm's strategy, risk appetite and control framework;
• independent risk management and compliance functions, and internal audit assurance over the control environment;
• documented policies covering operational resilience, information security, business continuity and the protection of personal data; and
• regulatory reporting to, and supervision by, the Bank of Lithuania.

These arrangements are designed to ensure that we can meet our obligations to customers in normal conditions and in stress, and that customer funds remain protected.

We maintain a conflicts-of-interest policy designed to identify, prevent and manage conflicts that could arise in the course of providing our services — for example, between Sezvo and a customer, between two customers, or between Sezvo and a third-party partner.

Where a conflict cannot be avoided, we manage it through organisational and administrative measures so that customers are treated fairly, and where appropriate we disclose the nature and source of the conflict so that you can make an informed decision. We do not provide personal investment advice, and our pricing — including commission-free investing — is disclosed transparently so you understand how each service is funded. Any payments we receive from, or make to, partners are governed by this policy and applicable law.

If something goes wrong, we want to put it right. You can raise a complaint at any time through 24/7 in-app support or via the contact details on our website. We will acknowledge your complaint, investigate it and respond within the timeframes required by applicable law, explaining our decision and the reasons for it.

If you are not satisfied with our final response, or if we do not respond within the applicable time limit, you may be able to refer your complaint to the Bank of Lithuania, which handles out-of-court resolution of disputes between consumers and financial market participants it supervises. Depending on your country of residence within the EEA, an alternative national dispute-resolution or ombudsman scheme may also be available to you. The European Commission's Online Dispute Resolution platform may additionally be used for disputes relating to services bought online.

Referring a complaint to an external body does not affect your other legal rights, including the right to take court action.

We encourage you to confirm our status independently. You can do this by checking the relevant public registers:

• Home-state regulator: the Bank of Lithuania (Lietuvos bankas), which authorises and supervises UAB Aušra Pay as an electronic money institution. The Bank of Lithuania maintains a public list of licensed financial market participants.
• EU-wide register: the European Banking Authority (EBA) operates a central register of authorised payment and electronic money institutions, drawing on data supplied by national competent authorities, which can be used to confirm our authorisation and passporting status across the EEA.
• Legal entity: UAB Aušra Pay, registered in the Republic of Lithuania. Our SWIFT/BIC is OCENLT22 and accounts use Lithuanian (LT) IBANs.

If you ever receive a communication claiming to be from Sezvo that you are unsure about, do not act on it. Contact us through the official Sezvo app or our published channels and verify our details against the registers above. We will never ask you for your full password, your card PIN, your crypto recovery phrase or one-time security codes.

This page is provided for information only and is a summary of our regulatory status; it does not vary the legally binding terms that apply to your account. Where this notice and our framework contract or product terms differ, those terms prevail. We may update this information from time to time to reflect changes in our authorisations, products or applicable law.