Restrictions on Financial Institutions

Regulated financial institutions, including banks, electronic money institutions, payment institutions, money service businesses and similar regulated entities, are restricted to first-party payment activity only.

This means:

• The regulated financial institution must be the direct customer.

• Payments must be made solely for the institution’s own operational or corporate purposes.

• The institution must act on its own behalf and for its own account.

The following activities are not permitted:

• Acting as an intermediary, agent, correspondent, processor, gateway or platform for third-party merchants, clients or end users.

• Collecting, receiving, holding, pooling, settling or forwarding funds on behalf of underlying customers or beneficiaries.

• Operating as a payment facilitator, programme manager, sponsor or pass-through payments provider.

If a financial institution wishes to use the full scope of Align’s services, including third-party settlements and virtual accounts, its underlying customers (both individuals and businesses) must be onboarded directly with Align and become direct Align customers.