Compliance & Sanctions

1. What we are, and what we are not

Settle provides software that helps merchants request, display, and reconcile payments made on public blockchain networks. We are not a bank, money transmitter, money services business, virtual asset service provider acting on your behalf, payment processor, custodian, exchange, broker, or financial institution, and we do not hold ourselves out as any of these.

At no point do we take possession or control of funds. We never hold a private key, never sign a transaction on your behalf, never pool customer money, and never stand between payer and payee in the flow of value. A payment made through Settle is a direct wallet-to-wallet transfer that would occur identically without us; our role is limited to generating the request and observing the public chain to confirm it happened.

This is not legal advice. Regulatory treatment of non-custodial payment software differs by jurisdiction and continues to evolve. Nothing here is a determination about your obligations. You should take your own legal advice about how the rules in your jurisdiction apply to your business.

2. Sanctions

You may not use Settle if you are, or if you are acting for the benefit of, a person or entity that is the target of economic or trade sanctions administered by the United States (including OFAC’s Specially Designated Nationals list), the United Kingdom, the European Union, or the United Nations. You may not use the service to facilitate payments to or from comprehensively sanctioned jurisdictions.

By using the service you represent that you are not a sanctions target and that you will not use Settle to evade sanctions. Where we become aware of a credible sanctions concern we will suspend or terminate access and, where legally required, make a report to the appropriate authority. Because we hold no funds, we cannot and do not freeze assets.

3. Anti-money-laundering and merchant responsibility

You are responsible for your own compliance with anti-money-laundering, counter-terrorist-financing, know-your-customer, tax, consumer protection, and licensing obligations applicable to your business. If your activity requires registration or a licence in your jurisdiction, obtaining and maintaining it is your obligation, not ours.

We do not perform KYC on your customers and do not represent that any payer has been screened. If your business is required to identify its customers, you must do so through your own processes.

4. Our own controls

We operate proportionate risk controls for a non-custodial software provider: acceptance of merchants is subject to our Acceptable Use Policy; public endpoints are rate limited; we investigate credible abuse reports; and we retain the right to suspend accounts presenting unacceptable legal or reputational risk. We may request information about your business, its beneficial owners, or a specific transaction where we have a reasonable basis to do so, and may suspend access if it is not provided.

5. Tax

Settle does not provide tax advice and does not withhold, collect, or remit tax on your behalf. Receiving stablecoins may create income, VAT, sales tax, or capital-gains obligations depending on where you operate. Transaction records are exportable from the dashboard so you or your accountant can meet your reporting obligations.

6. Stablecoin and network risk

Stablecoins are issued by third parties over whom we have no control. An issuer may freeze tokens at a specific address, redeem or migrate a token, or fail to maintain its peg to the referenced currency. Blockchain networks may experience congestion, outages, or reorganisations that delay or, in rare cases, reverse a transaction that appeared confirmed. Settle does not underwrite these risks and is not liable for losses arising from them.

7. Jurisdictional availability

The service is not offered where its provision would be unlawful. We may restrict availability in a jurisdiction at any time, including in response to regulatory change. You are responsible for ensuring that your use of Settle is lawful where you are.

8. Contact

Compliance enquiries, information requests, and law-enforcement contact should be directed to [email protected]. We respond to properly served legal process and will tell you about a request affecting your account unless we are legally prohibited from doing so.