1. About SatchelPay
Updated – May 26, 2017
1.1. SatchelPay Ltd is a company incorporated under the laws of England and
Wales with registration number 09808376, whose registered office is at Garden
Suite Barham Court, Teston, Maidstone, ME18 5BZ, United Kingdom. We are
regulated by the Financial Conduct Authority (FCA) under the Payment Service
Regulations 2009 for the provision of payment services. Our FCA registration
number is 735365.

1.2. SatchelPay Ltd offers payment services as a Small Payment Institution and
it is not offering banking services.
2. Scope of these Terms and Conditions
2.1. These Terms and Conditions are prepared and shall be governed by and
interpreted in accordance with the laws of England and Wales. These Terms and
Conditions state the basic rights and obligations of the contractual relationship
between SatchelPay Ltd and individual Clients. This document is a part of any
contractual relationship between SatchelPay Ltd and the Clients and in relation to
the Contract, or other documents governing the terms of cooperation between
the Client and SatchelPay Ltd by general provisions.
These Terms and Conditions also include provisions of using Payment Cards.
2.2. You are advised to read these Terms and Conditions carefully as it is
obligatory for all parties to this contract from the date of the first expression of
the intentions of Clients to establish a contractual relationship with SatchelPay
Ltd.
2.3. You are also advised to print and/or download and keep a copy of these
Terms and Conditions for future reference. You can always view the current
Terms and Conditions on this Website.
2.4. It is considered, that you agree to the applicable in this document Terms and
Conditions, if you are using any account or service provided by SatchelPay Ltd.

2.5. English is the original language of these Terms and Conditions. The original
version may be translated into other languages. In case of discrepancy or
contradictions between the original version and any other translated version of
these Terms and Conditions, the English language version shall prevail.
2.6. No person other than you shall have any rights under these Terms and
Conditions. The provisions of the Contracts (Rights of Third Parties) Act 1999 are
excluded.
2.7. Any dispute under these Terms and Conditions or otherwise in connection
with your SatchelPay account will be brought under exclusive jurisdiction of the
courts of England and Wales with the exception of the cases prohibited by EU
law.
2.8. If any part of these Terms and Conditions is recognized invalid, unlawful or
unenforceable by a court of competent jurisdiction, such part shall be severed
from the remainder of the Terms and Conditions, which shall continue to be valid
and enforceable to the extent permitted by law.
3. SatchelPay account
3.1. SatchelPay account is user account that enables you to make money
transfers.
3.2. SatchelPay offers accounts to both individual and corporate Clients as long
as they meet its requirements.
3.3. You can open and operate a SatchelPay account in a currency of your
choice, as selected by you from the available currencies.
3.4. You will not be eligible to open an account with SatchelPay, if you are under
the age of 18.
3.5. You will not be eligible to open an account with SatchelPay, if you are a
citizen of the United States of America.
3.6. We will provide you with a copy of these Terms and Conditions, when you
apply to open an account. You will need to read, agree and accept all of the
conditions contained therein, sign it and return to us. Agreement to these Terms

and Conditions is confirmed by the returning the Application Form from your
side.
3.7. Before the opening of an account we:
3.7.1. Process an Application Form;
3.7.2. Verify your personal and/or business information and related documents;
3.7.3. Receive from you a fee for the account opening.
3.8. We can call upon other procedures for verifying the identity of the account
holder. In case the officials of SatchelPay Ltd request certain information during
the verification process, you will be required to cooperate with them.
3.9. You have to inform SatchelPay Ltd of any changes to the information you
provided in an Application Form e.g. legal name, nature of business, details on
owners or directors of the business, contact details, including telephone and fax
numbers, email and mailing addresses. All the changes must be provided in
writing via email or letter.
3.10. SatchelPay account is personal to the Client and the Client may not assign
any rights under these Terms and Conditions to any third party. Among other
things, it means, that we receive the instructions regarding an account only from
the signatory.
3.11. In case of death or bankruptcy of the signatory, SatchelPay will follow the
directions of the one who is authorised by the account holder. SatchelPay may
close or redeem the signatory's account as instructed, only after the verification
of the authorized person’s competency.
3.12. SatchelPay reserves the right to not open an account and/or close an
account without providing a reason.
4. Operation with SatchelPay accounts
4.1. A fund transfer, whether external or internal cannot be cancelled. There is
only a possibility to change an instruction of transfer and/or to provide new
instructions. We cannot be liable for any loss resulted by failure or inability to

provide new instructions in order to cancel or change a funds’ transfer from your
side.
4.2. If the Client has multiple SatchelPay accounts, we can merger these as and
when we see fit. One SatchelPay account may receive credit for an amount, that
SatchelPay is indebted to the other SatchelPay account hold by the same Client.
4.3. In case of receiving an inquiry related to the ability of a Client to complete
certain transactions, SatchelPay will respond to it in a general manner, and only
after receiving the Client’s written consent.
4.4. SatchelPay can transfer the right to claim or any other rights to a third party
at any time. In this case, we report details of the Client's account as we regard as
necessary, to this party.
4.5. If there are reasonable grounds, SatchelPay will be able to limit the access to
the account and/or withdrawals, close an account of any Client at any time and
at its sole discretion for any or for no reason with no foregoing notification and
payment of any funds held in custody.
These reasonable grounds are assumed under, but are not limited to the
following:
4.5.1. Failing to observe any part of these Terms and Conditions;
4.5.2. Violation of any current laws and/or regulations;
4.5.3. Submitting false, counterfeited or changed documents in process of
verification;
4.5.4. Returning an incoming money transfer caused by insufficient funds in the
account or an incorrect bank routing, name or number of account;
4.5.5. Using SatchelPay account in order to contribute to fraudulent activity
and/or receive potentially fraudulent funds;
4.5.6. If there are reasons to believe, that SatchelPay account has been
compromised;
4.5.7. If there are reasons to think, that SatchelPay account has been using an
unauthorized or unusual method;
4.5.8. When there is an abuse of the charge back (reversal) process;

4.5.9. In case of using an anonymous proxy;
4.5.10. In case of receiving excessive customers' complaints about a particular
account, business or service;
4.5.11. If Clients send unsolicited emails or post referral links on websites, where
they are prohibited;
4.5.12. For any other security reasons.
4.6. When we reasonably suspect, that SatchelPay account has been used or is
being used fraudulently, we will notify the Client before the suspension. In case
the preceding notification is impossible, we will notify the Client straight after the
suspension.
4.7. SatchelPay Ltd will use all the acceptable efforts in order to investigate
cases, where SatchelPay accounts are subject to access limitations until the final
decision reached. SatchelPay Ltd will retain all funds for a period until the
problem is resolved.
4.8. SatchelPay Ltd stores the personal information about the Client and history
of transactions as required by law, but not less than five years. Closing a
SatchelPay account does not result into the annulation of such data.
4.9. SatchelPay Ltd reserves the right to suspend or restrict the operation of the
account or the provision of any other services immediately, at its sole discretion
and without prior notification in the next cases:
4.9.1. We became aware of the Client's or his guarantor’s death, lack of legal
capacity, bankruptcy or an insolvency;
4.9.2. We became aware of the dispute over the operation of Client's account or
Client's ownership of funds on the account;
4.9.3. We became aware that a third party claimed an interest in Client's account;
4.9.4. We have grounds to think that Client or third persons have used or are still
using account illicitly or fraudulently;
4.9.5. We have grounds to believe that Client or third persons behave incorrect
e.g. in a frightening, threatening or aggressive manner towards the officials of
SatchelPay Ltd;

4.9.6. We have grounds to think that Client or third persons have used or are still
using corporate accounts, while the competency of the person, that represents
particular legal entity raises doubts;
4.9.7. We became aware that the Client violated these Terms and Conditions;
4.9.8. We have reasons to believe that the Client, or payments in or out of his
account, are subject to an international payments sanction regime;
4.9.9. Client's account has never been used, or has not been used for an
extended period of time;
4.9.10. Client is failing to provide to SatchelPay Ltd the information and/or
documentation required under these Terms and Conditions to enable the
provision of the services either when required or in a form, which is acceptable to
SatchelPay Ltd;
4.9.11. We have the reasonable information, that the Client have committed an
offense involving dishonesty;
4.9.12. We have reasons to believe that there is a legal requirement to do so, or a
court or any other authority requires suspending or restricting the operation of
the account or the provision of any other services.
4.10. In cases mentioned above, SatchelPay Ltd reserves the right to expect a
requirement or an authorization of the corresponding Authority or a Court order,
before ending the suspension or restriction of operating of Client account’s
operation or the provision of any other product or service.
4.11. The Client takes responsibility to supply updates of documents required for
the account operating. The outdated or invalid documents may cause the
measures designated in points 4.5., 4.9.
5. Prohibited transactions
5.1. We intend to be and to stay a serious, trustworthy, compliant and reputable
Payment Institution. In order to meet this goal we avoid any suspicious or risky
Clients. SatchelPay Ltd deals only with the Clients without any doubtful activities
and cases involved in any suspicious transactions. Therefore, all incoming or

outgoing payments, related to the activities mentioned below or as consideration
for the sale or supply of the following goods or services are prohibited:
5.1.1. Drugs or drug paraphernalia e.g. narcotics, steroids and other controlled
substances presenting a risk to safety of a Client;
5.1.2. Definite kinds of firearms, ammunition, weapons or knives;
5.1.3. Child pornography or related hardcore content or services of any kind;
5.1.4. Trading of items or support of organizations that promote hate, violence,
or racial intolerance;
5.1.5. Illegal gambling;
5.1.6. Forex, involving or not binary options and binary options trading platforms,
using currency exchangers or aggregation, unless approved by SatchelPay Ltd;
5.1.7. Any activities with cumulative incoming transfers from individuals, unless
in the ordinary or normal practice of the declared business and approved by
SatchelPay Ltd;
5.1.8. Government identification documents and licenses, including replicas and
novelty items;
5.1.9. Illegal downloads or any other goods and services infringing intellectual
property rights of a third party (e.g. trademark, patent, copyright);
5.1.10. Illegal or stolen goods or services;
5.1.11. Other goods or services violating applicable laws, statutes, ordinances or
regulations.
5.2. We have the right to add categories of prohibited transactions by updating a
list of such categories in these Terms of Conditions at sole discretion.
5.3. If the Client conducts or attempts to conduct any transaction in violation of
the prohibitions mentioned above, SatchelPay Ltd has the right to:
5.3.1. Reverse transaction;
5.3.2. Close or suspend account;
5.3.3. Report the transaction to the relevant law enforcement authority;
5.3.4. Claim damages from the Client;

5.3.5. Charge the Client an administration fee of up to GBP 10,000 in case of
applying any of the above mentioned.
5.4. Client and only the client assumes the liability to ensure that he or she only
sends or receives payments from persons or legal entities for the sale or supply
of goods and/or services that he or she may provide or receives in compliance
with any applicable laws and regulations. The mere fact that a person or legal
entity accepts payments through SatchelPay Ltd is not an indication of the
legality of the supply or provision of their goods and services. Therefore, if you
are in doubt as to the legality of a supply or purchase, you should not continue
with your payment.
5.5. SatchelPay Ltd has the right to return to the sender with all fees charged to
the Client’s account any incoming payment deemed to be suspicious for any
reason. The fees are those of a usual wire transfer as well as a SWIFT
confirmation to ascertain the sending account number and to allow the funds to
be returned to the same account number. The cost of the transfer may be
additionally applied depending on the destination and currency and if applies
foreign currency conversion.
6. Limitation of liabilities
6.1. SatchelPay Ltd cannot be held liable for any failure to fulfil its
responsibilities under these Terms and Conditions caused by fail to function
normally and/or satisfactorily of the equipment or systems utilised by our
affiliates or us.
6.2. We are not liable for any failure, damage, delay or loss in the transmission,
receipt or execution of your payments, orders, deliveries or information caused
by the events beyond our control, including the actions or omissions of third
parties, which may affect operations or services e.g. the actions or omissions of
correspondent financial institutions, political unrest, war or natural disaster etc.

6.3. SatchelPay Ltd is not liable for any loss resulted from the provision of
incorrect information by the Client, at the moment of opening an account or
further.
6.4. SatchelPay Ltd is also not liable for any losses or inconvenience in result of
damage or loss of a SatchelPay Payment Card, through a personal identification
number (PIN) or compromising of credentials in Internet Transfer Services.
6.5. By signing these Terms and Conditions, you agree not to violate any law or
regulation. Using services of SatchelPay Ltd, and you meet all liability that might
arise from the use of these services.
6.6. By signing these Terms and Conditions, you agree to release, indemnify and
hold our harmless against any claim brought against us by a third party and
caused by your use of our services in respect of all losses, actions, proceedings,
claims, damages, expenses or liabilities, whatsoever suffered and howsoever
incurred, by SatchelPay Ltd in consequence of your violation of these Terms and
Conditions.
7. Identification and anti-money laundering provisions
7.1. By signing these Terms and Conditions, you understand and agree to the
following:
7.1.1. International sanctions may prevent the free transfer of funds and delivery
of products and/or services to and from specific states, legal entities and
individuals. Such international sanctions may affect our services and your
business operations;
7.1.2. Applicable laws, rules and policies that concern money laundering;
7.1.3. SatchelPay Ltd possess irrevocable right to refuse of providing service
that may violate any relevant law or anti-money laundering regulation.
7.2. We adhere “Know Your Customer” (KYC) policy and we collect full
information about our Clients in order to be certain about their identity. Therefore,
we reserve the right:
7.2.1. To ask our Clients to answer all related questions;

7.2.2. To apply any Clients' identification procedure to meet this legal objective;
7.2.3. To apply "face to face" identification procedure;
7.2.4. To apply control of the passport or other identification documents to
confirm that these documents carry security marks and features, and that they
are undoubtedly authentic.
7.3. SatchelPay Ltd accepts to open an account remotely. However, by signing
these Terms and Conditions, you accept to go through a "face to face"
identification procedure within 6 months from the date of SatchelPay account
opening or at any time we request you to do so.
7.4. By signing these Terms and Conditions, you also consent to submit yourself
to a physical identification procedure. In order to perform this procedure you can
either be required to have a meeting with a SatchelPay Ltd representative and
use online identification tool with our official who will process to the
identification procedure with a video call. Therefore, in order to be identified
through a video call, you accept to have access to a computer and a webcam.
You are required hold your passport or other Identification Documents in your
hands and show them to our indentification agent. You are also obliged to help
us (or our trusted partners) to check the security features of your Identification
Document by tilting it, if necessary.
7.5. You give us a consent to record voice and video at any time we will ask to
identify it. This way we fight against theft of Identification Documents and
operation of accounts by third persons. Only authorized and identified Clients
have the right to manage their SatchelPay accounts. Failure to satisfy a "face to
face" or "video call" identification procedure as well as refusal to be identified
entails such consequences as suspension of the account and freezing of funds.
SatchelPay Ltd reserves the right to cease the identification process and to
report a fraudulent action to competent authorities, when the face of Client and
the photo in the Passport or other Identification Documents do not match or are
significantly different.