Compliance & Fund Security

OrbitLink Pay places high importance on regulatory compliance and risk management. ORBITAL TECHNOLOGIES LTD has registered with FinCEN in the United States as a Money Services Business under registration number 31000305990729, and OrbitLink Pay has completed FINTRAC MSB registration in Canada.

These registrations support the basic compliance framework for cross-border payment-related business, but they do not mean that OrbitLink Pay is a bank, deposit-taking institution, or provider of deposit insurance.

OrbitLink Pay has established compliance mechanisms based on its actual business operations, including anti-money laundering policies, internal control procedures, risk-based customer identity verification, and customer risk rating.

OrbitLink Pay maintains transaction monitoring mechanisms and may route unusual transactions for manual review and investigation.

During customer onboarding, OrbitLink Pay may use third-party tools to screen customers, beneficial owners, and relevant counterparties against sanctions lists.

OrbitLink Pay conducts internal compliance reviews and may engage external professional advisers to evaluate and improve the compliance framework.

OrbitLink Pay provides anti-money laundering training so relevant personnel understand regulatory requirements and operating procedures.

OrbitLink Pay has not yet launched public customer transaction processing and does not currently hold or process customer funds as part of a live payment service.

OrbitLink Pay is in contact and discussion with licensed U.S. banks and intends to establish formal fund-custody cooperation. This bank cooperation remains in the application and negotiation stage, and the timing is uncertain. Once formal cooperation is reached, OrbitLink Pay will disclose relevant information to customers and implement fund-protection measures according to the requirements of the partner bank.

As of July 2026, ORBITAL TECHNOLOGIES LTD holds U.S. FinCEN MSB registration number 31000305990729 and has completed FINTRAC MSB registration in Canada.

OrbitLink Pay has not yet executed a formal U.S. bank fund-custody agreement, has not publicly launched customer transaction processing, and does not currently hold or process customer funds as part of a live payment service.

Initial banking and PSP onboarding remains subject to partner due diligence, regulatory review, approved service boundaries, and final agreements.

OrbitLink Pay maintains a written AML program structure, internal controls, customer due diligence procedures, risk-based review steps, sanctions screening expectations, suspicious activity escalation procedures, and recordkeeping controls.

Designated BSA Officer details are maintained internally and will be disclosed to banking, PSP, legal, or compliance partners during due diligence where appropriate. Public placeholder names or placeholder emails are not displayed on this website.

Independent AML program testing is planned before first customer onboarding and live transaction processing.

OrbitLink Pay operates under federal FinCEN MSB registration and maintains a state-by-state money transmission licensing review process. This status list is provided for transparency only and does not constitute legal advice or a commitment to provide services in any state.

Federal: FinCEN MSB registration 31000305990729 active.

Colorado: registered; not yet accepting money-transmission licensed activity.

New York: not accepting customers.

California: not accepting customers.

Texas: not accepting customers.

Florida: not accepting customers.

Illinois: not accepting customers.

New Jersey: not accepting customers.

Massachusetts: not accepting customers.

All other 42 U.S. states: under review / not accepting customers.

The intended future fund-flow model remains subject to banking partner agreement, compliance approval, and final operating procedures.

Expected future flow: customer funds would move from the customer to a segregated trust or custodial account at a U.S. licensed bank partner to be confirmed, then through the approved correspondent banking or payment network to the beneficiary, subject to compliance review and partner requirements.

OrbitLink Pay does not currently accept or process customer funds through this model and does not currently commingle customer funds with operating funds.

OrbitLink Pay's screening vendor set includes ComplyAdvantage, Refinitiv World-Check, and Dow Jones RiskCenter, subject to final production configuration and partner requirements.

Screening is expected to cover customers, beneficial owners, relevant counterparties, and transaction parties against OFAC SDN, Sectoral Sanctions, Non-SDN Menu-Based sanctions, OFAC 50 Percent Rule considerations, EU, UN, and HMT UK sanctions lists where applicable.

Screening should occur during onboarding, ongoing customer review, and relevant transaction review. List updates and escalations will follow vendor feeds, internal escalation procedures, and applicable compliance requirements.

The AML program requires suspicious activity escalation, internal review, and SAR filing with FinCEN within applicable regulatory timelines where required after detection of suspicious activity.

CTR filing procedures will apply to reportable cash transactions where applicable. OrbitLink Pay's intended operating model is business-focused cross-border payment activity, and actual CTR obligations depend on the final product model and applicable transaction activity.

Compliance records, customer due diligence files, transaction review records, and related AML records should be retained for at least five years or longer where required by applicable law or partner obligations.

OrbitLink Pay expects to apply a risk-based customer rating model that considers industry, ownership structure, geography, counterparties, expected volume, payment purpose, documentation quality, sanctions exposure, and transaction behavior.

Low-risk customers should be reviewed periodically, medium-risk customers at least semi-annually, and high-risk customers at least quarterly or upon material risk events, subject to final compliance procedures.

Enhanced due diligence may apply to higher-risk industries, complex ownership structures, PEP exposure, FATF high-risk jurisdictions, cash-intensive businesses, unusual transaction behavior, or other elevated-risk indicators.

Relevant personnel should complete onboarding AML training, annual refresher training, and role-specific training for operations, support, compliance, and administrative functions.

Training should include customer due diligence, sanctions screening, suspicious activity escalation, recordkeeping, privacy, data security, and internal reporting procedures.

Training completion, assessment results, and remediation records should be retained for at least five years or longer where required.

OrbitLink Pay is preparing an information security program aligned with appropriate administrative, technical, and organizational safeguards for financial technology operations.

Qualified individual and responsible security contact details are maintained internally and may be disclosed during partner due diligence where appropriate, rather than displayed as public placeholders.

The intended control set includes encrypted transmission, encrypted storage where appropriate, MFA for production access, role-based permissions, access logging, incident response procedures, vendor due diligence, and periodic security review before production launch.

OrbitLink Pay itself is not a bank and is not a deposit-taking institution.

OrbitLink Pay aims to provide cross-border payment services to business customers under applicable compliance requirements. Actual business scope, settlement timing, supported services, and availability remain subject to final review, partner readiness, and approved disclosures.

OrbitLink Pay welcomes potential banking partners to conduct due diligence on its compliance framework, operating practices, and risk-control capabilities.

OrbitLink Pay is committed to maintaining transparency during cooperation and actively supporting applicable regulatory and partner requirements.