Platform

Compliance and governance

A white-label programme only works if the division of regulatory responsibility is unambiguous. This page states it plainly.

Read this first
Otaro Pay Ltd is a technology provider, not a bank. It does not hold a banking or e-money licence, does not take deposits, does not extend credit and does not issue cards in its own right. Every card programme described on this site is issued by a licensed institution under that institution's permissions.

Who is responsible for what

ObligationIssuing institutionZen Card
Holding the licence and permissionsAccountableNone
Customer due diligence and KYCAccountable, performsTechnical integration
AML programme and policyAccountable, ownsTooling and monitoring surfaces
Sanctions screening policyAccountable, setsApplies exclusion list at programme level
Suspicious activity reportingAccountable, filesSupplies evidence and data
Transaction monitoring thresholdsSetsOperates the engine
Dispute and chargeback handlingCustomer decisionScheme process and evidence
Data protection as controllerAccountableActs as processor
Regulatory reportingAccountable, filesProvides programme data
Scheme rule adherenceOverseesOperates to Visa requirements

What the platform provides

Transaction monitoring

Rule-based screening at authorisation with configurable thresholds, so patterns that breach your policy are surfaced rather than discovered later.

Alerting and anomalies

Automated alerts on anomalous spending behaviour, with severity so your team triages rather than reads everything.

Case management

A case surface for investigation, with the transaction evidence, device and session context attached.

Jurisdiction controls

Country exclusion list applied at programme level for scheme, sanctions and regulatory compliance, reviewed on an ongoing basis.

Merchant risk

Merchant risk assessment and fraud rate visibility for programmes with an acquiring or gateway component.

Audit trail

Programme actions are logged and exportable for internal audit and regulatory submissions.

Frequently asked questions

Is Zen Card a regulated financial institution?+

No. Zen Card is a technology and programme-management provider. It does not hold a banking or e-money licence, does not take deposits, and does not issue cards in its own right. Cards are issued by licensed institutions that hold the relevant permissions in their jurisdictions.

Who performs KYC and AML on cardholders?+

The issuing institution, under its own regulated process and its own risk appetite. Zen Card provides technical hooks so the outcome of your process gates issuance and funding, but the decision and the regulatory responsibility remain yours.

How are sanctions and prohibited jurisdictions handled?+

A country exclusion list is maintained for scheme, sanctions and regulatory compliance, and is applied at the programme level. The list is reviewed on an ongoing basis and any material change is communicated with prior notice.

What transaction monitoring is available?+

The platform provides transaction monitoring, rule-based alerting, anomaly detection and case management surfaces. These support your compliance function; they do not replace it, and monitoring thresholds are configured to your policy.

Request the compliance pack

Institutions evaluating a programme can request the detailed responsibility matrix, data-processing terms and control documentation.

Zen CardZen Card

Crypto-funded cards on the Visa network, and the white-label issuing platform behind them.

Corporate information. This website is operated by Otaro Pay Ltd, FINTRAC M23150730, Suite 250 - #1585 997 Seymour St, Vancouver BC V6B 3M1. Contact: info@otaropay.com.

Regulatory notice. Otaro Pay Ltd is a FINTRAC MSB. It is not a bank and does not itself issue cards, take deposits, extend credit or provide investment services. Cards, accounts, credit and yield-bearing products described on this site are provided by licensed financial institutions, subject to their terms, their approval, and the regulations of the relevant jurisdiction. Availability varies by country. Digital assets are volatile and capital is at risk. Nothing on this website constitutes an offer, a solicitation, financial advice or investment advice.

© 2026 Otaro Pay. All rights reserved.

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