SECRECY AND CONFIDENTIALITY

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Under the laws of Gibraltar, Electronic Money Institutions (EMIs), payment service providers, and partner banks operating IBAN account structures are subject to strict banking secrecy, data protection, and confidentiality obligations. All customer-related information, including personal and corporate identification data, IBAN and account details, transaction records, balances, payment history, as well as KYC, AML, and compliance documentation, is treated as confidential and protected under applicable Gibraltar law and regulatory requirements.

Such information may not be disclosed to any third party except where disclosure is required by applicable laws or regulations, mandated by a court order, requested by a competent authority such as a regulatory, supervisory, judicial, or law enforcement body, necessary for compliance with anti-money laundering, counter-terrorist financing, sanctions, or regulatory reporting obligations, or expressly authorised by the customer.

These confidentiality obligations are applied in accordance with the regulatory framework of the Gibraltar Financial Services Commission (GFSC) and relevant data protection and financial services legislation. Banking secrecy does not prevent the lawful exchange of information between regulated entities, service providers, correspondent partners, or technology platforms where such exchange is required for operational purposes, regulatory compliance, or risk management, provided that appropriate legal, technical, and organisational safeguards are in place.

Under Swiss law, secrecy and confidentiality are fundamental principles, particularly within the banking, fiduciary, and legal sectors. Switzerland has long been recognized for its strict privacy protections, which are designed to safeguard the personal and financial information of individuals and corporations.

Established under Article 47 of the Swiss Banking Act, banking secrecy prohibits banks and financial institutions from disclosing any client-related information to third parties without the client’s explicit consent. Violating banking secrecy is a criminal offense and can lead to fines or imprisonment. The law applies to all employees, agents, and anyone with access to confidential banking data. Swiss secrecy laws remain among the most respected in the world. While modern transparency standards have slightly narrowed their scope, confidentiality and client privacy continue to be core pillars of the Swiss legal and financial system.

Under the laws of Singapore, banks, payment institutions, and fintech service providers operating accounts, wallets, or payment structures are subject to strict banking secrecy, data protection, and confidentiality obligations. All customer-related information, including personal and corporate identification data, account or wallet details, transaction records, balances, payment history, and KYC, AML, and compliance documentation, is treated as confidential and protected under applicable Singapore law and regulatory requirements. Such information may not be disclosed to any third party except where disclosure is required by applicable laws or regulations, mandated by a court order, requested by a competent authority such as the Monetary Authority of Singapore (MAS) or other regulatory, supervisory, judicial, or law enforcement bodies, necessary for compliance with anti-money laundering, counter-terrorist financing, sanctions, or regulatory reporting obligations, or expressly authorised by the customer.

These confidentiality obligations are applied in accordance with the regulatory framework of the Monetary Authority of Singapore, including the Payment Services Act, the Banking Act, and applicable data protection legislation such as the Personal Data Protection Act (PDPA). Banking secrecy does not prevent the lawful exchange of information between regulated entities, service providers, correspondent partners, or technology platforms where such exchange is required for operational purposes, regulatory compliance, or risk management, provided that appropriate legal, technical, and organisational safeguards are in place.

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