Our compliance framework.

Regulatory Framework

NXPR operates within the regulatory framework of the European Union and the Republic of Cyprus. Our operations are designed to comply with:

• Directive (EU) 2015/2366 (PSD2), operating under the Article 3(b) exemption
• Directive (EU) 2015/849 (4AMLD) and Directive (EU) 2018/843 (5AMLD), AML/CFT framework
• Regulation (EU) 2016/679 (GDPR), data protection
• Cyprus Companies Law (Cap. 113), corporate governance
• Cyprus VAT Law, tax compliance

PSD2 Article 3(b) Positioning

The commercial agent exemption set out in Article 3(b) of PSD2 excludes from the scope of the directive payment transactions from the payer to the payee through a commercial agent authorised via an agreement to negotiate or conclude the sale or purchase of goods or services on behalf of only the payer or only the payee.

NXPR's activities have been structured to fall squarely within this exemption. The company acts solely on behalf of the buyer, as the buyer's commercial agent, and does not hold or transmit funds. This positioning is supported by an independent legal opinion prepared by qualified EU counsel and is available to authorised parties upon request.

AML/KYC Framework

While NXPR is not a regulated obliged entity under the AML directives in its capacity as a commercial agent, the company applies AML/KYC-aligned controls as a matter of good governance:

• Counterparty due diligence on engagements
• Cooperation with regulated PSPs in their transaction monitoring obligations
• Documentation of business relationships
• Cooperation with regulated PSPs in their AML/KYC obligations
• Internal policies prohibiting business relationships with sanctioned parties or jurisdictions
• Regular review of EU and UN sanctions lists

Sanctions Compliance

NXPR maintains internal policies prohibiting any business relationship or transaction with:

• Persons or entities listed on the EU Consolidated List of Sanctions
• Persons or entities listed on the UN Security Council Sanctions List
• Persons or entities subject to OFAC sanctions where extraterritorial application applies
• Counterparties domiciled in jurisdictions identified as high-risk by the Financial Action Task Force (FATF)

Data Protection (GDPR)

NXPR processes personal data in accordance with Regulation (EU) 2016/679 (GDPR) and the Cyprus Processing of Personal Data (Protection of the Individual) Law of 2018. Detailed information regarding categories of data, processing purposes, retention periods, and data subject rights is available in our Privacy Policy.

Tax Compliance

NXPR is tax-resident in the Republic of Cyprus and meets its corporate income tax, VAT, and reporting obligations in accordance with Cyprus law. The company is registered for Cyprus VAT under number CY 60177007V and applies VAT to its activities in accordance with applicable rules, including the EU One Stop Shop scheme where relevant.

Legal Opinion on Regulatory Status

NXPR's regulatory positioning under PSD2 Article 3(b) is supported by an independent legal opinion prepared by qualified EU counsel. The opinion is available to authorised counterparties on written request.