Inquire. You are welcome!


Inquire. You are welcome!

KogoPAY Policy

Terms and Conditions


”Smile Money Ltd”is a company registered in England and Wales (No. 10288745) with registered address of ZRS – Building 3, Oakleigh Road South, London, England, N11 1NP.

KogoPAY UAB is license as an EMI (Electronic Money Institution) in the EEA via the Bank of Lithuania. Company number 304956760 and EMI license no. 83

KogoPAY UK regstered as an SPI and licensed in the UK via the FCA. Company number 08439416 and SPI reg number 616300

Contact details for KogoPAY:


Supervisory authority, Bank of Lithuania (BoL), located at Gedimino pr. 6, LT-01103, Vilnius, Lithuania, telephone no. +370 800 50 500. ( 

Lithuanian Financial Intelligence Unit (FIU) – Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania is located at Sermuksniu g. 3, LT-01106 Vilnius, Lithuania, telephone no. +370 527 17 594. You can find more information about the FIU here: (

These T&C’s apply to all relationships between the Company and the Consumer that arise from the provision of services.

KogoPAY is the licensed owner of the KogoPay website, and all other digital media under the KogoPAY brand such as the KogoPay Mobile App.

‘KogoPAY’ reserves the right, at its sole discretion to modify this policy from time to time taking into consideration new technology, changes to our operations, practices and new laws and regulations. Any proposed changes will be provided in written notice two months before they are due to take effect.

Note that changes to this policy which are more favourable to you; required by law; or related to the addition of a new service, extra functionality to the existing Service; or changes which neither reduce your rights nor increase your responsibilities, will come into effect immediately if they are stated in the change notice. Changes to exchange rates shall come into effect immediately without prior notice and you shall not have the right to object to such a change.

The latest version of the Terms & Conditions shall be published on the website.


To make sure that you share our understanding of the key terms in this document, we have defined them below:

Account’ – the electronic money account that you have opened, or are about to open, with us which is used for Transfers

“Affiliates” means any third party legal entity directly or indirectly controlled or owned by KogoPAY (including KogoPAY (UK) Limited).

‘Account Statement’ – a document we provide which includes information about Transfers executed during a specific period of time

‘Authentication’ – a procedure which allows us to verify your identity or the validity of the use of a specific Payment Tool, including its personalised security credentials

‘Commission Fee’ – a charge we apply for our services, as shown in the price list and specific agreement for service provision

‘Consumer, you’ – you as a private person acting for purposes other than your trade, business or profession under these T&C’s

‘Customer’s Account’ – the collection of details, transactions and profile settings that make up your personal profile with us, allowing you to create transfer orders, monitor your transactions and communicate with us

‘Device’ – a personalised device(s) and/or set of procedures which you use to, for example, initiate a Transfer

‘E-money’ – an electronic alternative to cash; monetary value that is stored electronically on receipt of funds, and which is used for making Payment transactions

‘Funds’ – banknotes and coins, scriptural money or electronic money

“KogoPAY”, or KogoPAY UK in this Agreement refers to the Smile Money Limited company (including all its Affiliates) offering the relevant service under these Terms and Conditions (T&C / T&C’s) to you.

Mobile App (also known as mobile application – refers to the KogoPAY software installed on a mobile phone or device that provides access to your e-wallet accounts.

‘Parties’ – you and us

‘Receiver’ – a private or legal person who is meant to receive the funds as per the Transfer Order

‘Payer’ – (also referred to as ‘you’ in this agreement) a private or legal person who allows a Transfer Order from the payment account, or, if there is no payment account, a private or legal person who submits a Transfer Order

‘Payment Tool’ – a personalised device(s) and/or set of procedures which you use to, for example, initiate a Transfer Order

‘Transfer’ – the act, initiated by the payer or on his behalf or by the payee, of placing/ transferring/withdrawing funds

‘T&C / T&C‘s’ – these Terms and Conditions and its annexes, if any

‘Website’ – our website on the internet:

Web Browser App (also known as Web Browser Application) – refers to an Internet Browser-based access mechanism that provides access to your e-walllet accounts

‘Working Day’ – a day when we provide services. This is not a Saturday, Sunday or national holiday as specified by legal acts in the Republic of Lithuania or in the receiver’s or payer’s country


This Agreement is between KogoPay and you.

These Terms and Conditions apply to for the following:

  1. the use of the KogoPAY website, and
  2. the use of KogoPAY services including API, Mobile App & Social Media platforms
  3. c) your e-wallet account (business accounts and individual accounts – refer to section 9.0), and
  4. d) the purchase or sale of currency.

If you do not accept these Terms and Conditions, you are not entitled to access our website and any use of our services. These Terms and Conditions must be read in conjunction with any other applicable terms and conditions governing:

  1. a) the use of our website;
  2. b) information on fees and charges;
  3. c) e-wallet accounts and transaction types;
  4. d) special regulatory requirements;
  5. e) features and the user guide provided under the KogoPay website.

You must be 18 years old or over in order to register for services with KogoPAY. If the e-wallet account is in a company’s name you must be authorised to conduct transactions on behalf of your company. 

We reserve the right to amend these terms and conditions from time to time. Amendments will be effective immediately upon notification on our website. Your continued use of our website following such notification will represent an agreement by you to be bound by the terms and conditions as amended.


You are responsible for the safety of the devices you use to log in. Please do not leave them unattended or within other people’s reach.

The moment you become aware of the loss, theft, misappropriation or fraudulent use of a device used to access KogoPay services, you must immediately notify us (or any other entity designated by us) through your Customer’s Account, and at the same time, either send us an e-mail from the e-mail address you have registered in our system.

At this point we may take additional steps to make sure it’s you. If you notice any suspicious activity on your Customer’s Account, or you think a third person(s) might have logged into it, you must:

  1. tell us immediately, and ask us to block your Customer’s Account, and
  2. change your password

You could be held liable for any losses incurred with respect to unauthorised payment transactions if you fail to properly protect access to your account or any negligent activity relating to your account

If your account is used for any sort of misconduct (e.g. fraud, crime, terrorism or other offences), you will be legally liable.


1.1.1 Accounts. KogoPAY e-wallet accounts (accounts) are virtual accounts operated through KogoPAY’s services – online at the KogoPAY website, our mobile app, and our call centre.

1.1.2 Bank of Lithuania. KogoPAY e-wallet accounts are issued by KogoPAY’s Payment Service (KogoPAY) which is authorised and regulated by the Bank of Lithuania for issuing of our EMI Licence under the registration No. 304956760 in the Republic Lithuania.

1.1.3. Licensed Platform. While the license allows KogoPAY to operate client e-wallet accounts, issue, hold, and redeem (pay) e-money; it is not a mainstream bank providing clearing, lending or investment to clients. It provides a platform to hold balances in a multiple of currencies; conduct currency exchanges; to make and receive payments on Client instructions.

1.1.3. Opening your Account. Upon registration and being accepted, an e-wallet account will be opened for you, the balance of e-money in your account will be held at any first-class bank in a pooled client account (safeguarding account). Your e-wallet account can be accessed via your username and password credentials and viewed on our website or mobile app available 24/7, 365 days basis subject to any downtimes for maintenance or to comply with legal requirements. We allow only one individual and one business account per customer. If additional accounts are requested by the customer, special consideration and a final decision will be made by the Company with no obligation for explaining the decision.

1.1.5. Transfers and Interest. Your KogoPAY e-wallet account allows electronic access to your funds for currency exchange; transfers and payments. Your e-wallet account does not earn any interest.

1.1.6. Currencies. Subject to your type of account, your account may hold balances in multiple currencies and conduct currency exchange transactions.

1.1. Deposits and Withdrawals. You may deposit and withdraw funds from your account to the extent available, net of any pending obligations and fees, by using the facilities provided in your account pages after you have securely logged in to your account.


1.2.1 Registration Types. To register for a new e-wallet account, you must complete your registration details in the manner described on our website and agree to these terms and conditions and submit electronically after completion. There are two types of e-wallet accounts: business and individual which are explained in 9.0.

1.2.2 Tariffs. Information about the e-wallet account types, limits and restrictions applicable and general tariff structure are in Annexure 1. Individual terms agreed on case to case will be communicated individually and they will override default terms.

During the online application process, you will be asked to provide your registration details as follows.

1.2.3 Business Accounts. To identify your business, we’ll ask you to provide information about your business and personal documentation (this may not be limited to just a single document). We can only conclude our agreement once you have provided this information.

You shall provide your business details as follows:

  1. a) registration number,
  2. b) registered corporate name and any trading names used,
  3. c) registered address and any principal trading address,
  4. d) director names,
  5. e) beneficial owners and shareholders,
  6. f) nature of its business,
  7. g) business and currency trading volume

For each director and beneficial owner:

  1. i) passport, or
    ii) driving licence, or
    iii) national ID


One of the following, not more than 3 months old

  1. iv) a local council/corporation tax bill/statement; or
    v) a utility bill (for a fixed service, i.e., not a mobile phone bill); or
    vi) a financial institution statement; or
    vii) a correspondence between you and a government authority; or

viii) a property rental/lease agreement; or

  1. ix) a mortgage agreement/statement; or
  2. x) a certificate of voter registration

1.2.4 Individual Accounts.

To identify you, we’ll ask you to provide personal information and documentation (this may not be limited to just one document). This includes (but is not limited to) your name, surname, a Live Selfie, aim and purpose of opening of an Account. We can only conclude our agreement once you have provided this information.

You will be asked to provide the following valid personal documentation:

  1. i) passport, or
    ii) driving licence, or
    iii) national ID.


One of the following, not more than 3 months old

  1. iv) a local council/corporation tax bill/statement; or
    v) a utility bill (for a fixed service, i.e., not a mobile phone bill); or
    vi) a financial institution statement; or
    vii) a correspondence between you and a government authority; or

viii) a property rental/lease agreement; or

  1. ix) a mortgage agreement/statement; or
  2. x) a certificate of voter registration

1.2.5 Registration Documents. Your documents may be scanned and sent by email; captured by a mobile phone; sent by post; or handed over at any of our offices, branches or authorised agents. KogoPAY may at its sole discretion in some cases require each copy of these documents to be certified as “original seen” by an authorised KogoPAY staff member or such certification from one of the following in the local country of residence of the applicant: lawyer, banker, accountant, doctor or a local civil servant.

1.2.6 Account Acceptance. You will be notified of the approval/rejection of your application. We also may place further special conditions on your e-wallet account from time to time depending on the operation of your e-wallet account and/or legal requirements. You will be notified about such conditions.

1.2.7 Account Termination. We reserve the right to suspend or terminate your e-wallet account at any time: if you breach these terms and conditions or for any other reason. We are not obliged to provide any reasons to you.

When you are using our Services, you are prohibited from (including, but not limited to):

  1. not complying with these T&C’s, any amendments to them, and legal acts
  2. refusing to provide information or take other actions that we reasonably request
  3. executing or receiving transfers of illegally acquired funds that you either are, or should be, aware of
  4. using our Services in a way which causes losses, responsibility or other negative legal consequences or damage to our business reputation
  5. spreading computer viruses and taking other actions that could cause our system malfunctions, information damage or destruction, and any other damage to our system, equipment or information
  6. disclosing your passwords and other Personalized security measures on your Customer’s Account to anyone else (third party).

You shall reimburse all direct damages, fines and other monetary sanctions that we incur if you violate or fail observe these terms, including (but not limited to) those mentioned above. For more information, please refer to our Acceptable Use Policy.

1.2.8 Changes to Circumstances. You agree to ensure that your registration details are true and accurate at all times. Specifically, you must notify us of any change to your registration details as originally supplied. You agree to keep KogoPAY up-to-date with your relevant details we hold about you. False representation provided during registration or during updates to us may lead to civil or criminal action to be taken against you in accordance with the law; including against any party assisting a civil wrong or a criminal offence such as one of your associates or an attesting signatory.

If you move residence to a different country, you agree to notify us of your new address and residence immediately. You may be allocated a new e-wallet account number or your e-wallet account may be closed due to any regulatory reasons.

You may be requested to update or confirm the details held by us.


1.3.1 Account Access. The e-wallet account can be accessed through our website and web browser application or mobile application. You will need your security access details such as your username and password to login.

The user guide on the KogoPAY website provides detailed information for you to view and conduct transactions with your e-wallet accounts.

1.3.2. Account Details. On accessing your e-wallet account, the page will provide details of your e-wallet account number and the net balance on your account.

1.3.3 Currency Exchange. You can conduct currency exchange transactions with your e-wallet account.

1.3.4. Account Statement. In the e-wallet accounts statement page, the balances available in each currency will be shown in a summarised form. Your net account balance will be shown. This is calculated as the sum total of your currency balances equivalent in the home currency at prevailing exchange rates.

As a default view, your account ledger will show the entries made during the current month with opening and closing balances; however, all other entries will be available for viewing through an archive facility by entering required criteria. The ledger is a view only facility and you cannot make any entries.

The net balance on your e-wallet account is dynamic. If your e-wallet account holds multiple currency balances then your net balance will be updated regularly to take into account the changes in the applicable currency rates.

You have to hold a sufficient balance in a currency that you wish to transact in. You will not be able to send any transactions with a negative balance.

1.3.5 Single Currency Transfers. All new KogoPAY e-wallet accounts are denominated in a ‘single currency’ by default and this depends on where you are registered unless specifically agreed by KogoPAY. This means that your money is held in your home currency e.g., British Pounds (GBP) for UK account holders.

If you transfer funds from a single currency account to another single currency account but with a different denominated currency, the recipient’s account will be credited in the denominated currency of the recipient’s account by an automatic currency conversion by us at prevailing rates.

1.3.6 Multi-Currency Transfers. Our multi-currency account service allow you to hold balances in a multiple of currencies and the range of currencies is listed by KogoPAY.

If you transfer funds from a multi-currency account to another multi-currency account, the recipient’s account will be credited in the same currency as it was sent unless that currency was not supported by the recipient member.

The transfer is executed even if the sending account did not have the necessary balance in that currency, as long as the net balance in the multi-currency account determined as the sum total of the balances of all the currencies has adequate funds to cover the transaction or a suitable credit limit has been authorised by KogoPAY.

1.3.7 Negative Balances. KogoPAY will require a negative balance to be cleared by you within 60 days from the commencement of a negative balance. This may be done by depositing your funds into the negative balance currency, or by performing a suitable currency exchange credit to your KogoPAY account. KogoPAY shall have the right to convert any available positive balance to clear the negative balance. This will be implemented at the prevailing rates in the system.

As per international standards, the transaction date plus two days will apply to currency exchange settlement; same day settlement is not guaranteed. This standard applies to all transactions which involve a currency exchange.


2.1 Deposits. Deposits (also known as Top-Up’s) can be made into your individual or business e-wallet account by paying into any of the bank accounts nominated for this purpose the details of which are available in the web browser application or the mobile app.

Deposits into your account will be appropriated first towards transaction fees, then to bank transfer fees and finally the balance if any to random receipts. Each transaction has its own reference code that must be entered by the payer for remittance in the reference field and is used for both tracking and auditing.

2.2 3D Checks. All debit card holders are subject to validation checks and authorisation by the card issuer. If the issuer of your payment card refuses to authorise payment to us, your deposit will not be accepted.

3D Secure is a payment verification protocol used by major debit card companies/issuers, branded as ‘Verified by Visa’ and ‘MasterCard Secure Code’ to prevent debit card fraud.

Cards registered with 3D Secure require the user to enter a password for validation purposes. This password will have been created by you when you were registered for 3D Secure. If in doubt, please contact your card issuer.

3D Secure verifies card details, offering the country of issue and other card holder details to the proposed vendor.

The system is completely automated and KogoPAY does not store any of the data provided by the 3D secure system.

2.3 Transfers (also known as payments/ payouts) , You can make payments and transfers from your account.

Payments out of your account will be made as per availability of funds in your account prioritised as follows: dues towards Transaction fees; Bank transfer fees; any other fees and charges; Transfer and Payment instructions. Consent/authorisation is given by you and accepted by KogoPAY as given by you for the bank transfer to be sent when you Confirm Send Money on the KogoPAY App or Confirm on the KogoPAY web browser application.

Wallet to wallet transfers are instantaneous if no network issues are present that could cause a delay. Transfers sent from the wallet to the payee can take up to 30 minutes processing, however transfer times may be longer depending on the receiving bank’s processing time.


3.1 Anti-Money Laundering. As part of our Anti Money Laundering procedure when you complete a transfer, your registered address details (as the sender) and your beneficiary’s details (receiver), will be exchanged between the sending and receiving Hosts i.e., in the outbound message from the sending Host we send the sender’s details and in the response from the receiving Host we return the receiver’s details. These details include:

  1. a) name,
  2. b) company,
  3. c) address details,
  4. d) contact details,
  5. e) gender,
  6. f) date of birth, and
  7. g) identity details.

3.2 Your security details. In the account details page, you can view your current registered details and change your password and security number.

3.3 Negative Balance. If you have more than one account and one of the e-wallet accounts goes into a negative balance, e.g., from transaction fees, then we reserve the right to amend the balance from another of your e-wallet accounts according to section 1.3.7.

3.4 Cleared Funds. Unless otherwise agreed, in all transactions you shall provide sufficient funds in your account with KogoPAY, to the full value of the currency sold. Payment obligations from you are complete only when cleared funds in full have been made available in your account with KogoPAY.

KogoPAY is not obliged to pay you any amount in respect of any withdrawal or payment requests from your account with KogoPAY without their being sufficient funds in your account to clear any request and the fees associated with that request.

3.5 Clearing Times. KogoPAY will make all reasonable effort to make payment to you based on your instructions within three working days of receipt of instructions for payment from you unless otherwise agreed; KogoPAY will not be responsible for any delays or costs caused by circumstances beyond our control. In the event of a failure on the part of KogoPAY, we will not accept liability in any circumstances beyond the charges associated with the transaction. You must notify KogoPAY as soon as possible of any payment not made by KogoPAY or received by the nominated beneficiary within reasonable time and we will look into the matter and resolve the issue.

3.6 Payment Demands. Payments out of your account beyond the cleared and/or actual available funds on your account will be your liability irrespective of any errors or omissions by you or KogoPAY. Such liability will be payable by you upon first demand from KogoPAY according to sections 2.1, 2.3, 3.7 and 3.8.

Requests made by you will be regarded as final instructions and any amendments requested will be attempted to be implemented and any costs incurred in doing so will be charged to your account. It should be noted that KogoPAY will not be responsible for any losses incurred by you in this regard should the amendment process not be successful for any reason.

Unauthorised payments if detected will be cancelled and refunded to your account with your account temporarily suspended and reported to theFIU pending a decision from FIU on further actions. If funds are sent from a third party this will result in your account being temporarily blocked and pending FIU’s decision on further actions.

3.7 Fees and charges. Applicable fees and charges will be published on our website from time to time. The charge and the currency will be clearly indicated against each type of transaction.

These rates are subject to change with 60 days’ notice. If in our opinion a change that is being made is material, we will send you an email at least 60 days before making the change, unless a more immediate change is required by law or other valid reason. Otherwise, we will notify you of any other changes within 60 days of making the change.

3.8 Account closure. Your account will remain active, unless it has been closed by KogoPAY for any reason or where you have given 30 days written notice to close the account.

When your account is closed by KogoPAY under sections 1.2.7, 3.8, 4.10, 6.7, then all money – less any fees, obligations and charges on your account – will be returned to you via a designated account that belongs to you as the account holder. You agree to keep your banking details up-to-date at KogoPAY so that any funds can be returned. Terms and conditions apply to you from when you click to agree on the Terms & Conditions until your account is closed.

3.9 Assignment. KogoPAY will not reassign accounts due to an execution of a Will; assignment deed; transfer deed; inheritance; or any other such document or deed: unless required by law. Such actions will cause your account to close, subject to any legal constraints. Similarly, for business e-wallet accounts, KogoPAY will not reassign accounts due of mergers, acquisitions, settlement, administrative orders or any other such automatic transfer documents or procedures unless required by law. You agree to keep your business details up-to-date at KogoPAY.

3.10 Transfer. Notwithstanding anything contained in any of the clauses in these terms and conditions, we may assign the benefit and burden of these Terms and Conditions to another company at any time, on giving you at least 30 days prior notice of this. If we do this, your rights will not be affected.

3.11 New Service Provider. We may also transfer your unused balance to a new e-wallet account for you at a new service payment provider at any time. Before we do this, we will give you at least 30 days’ notice of the new account arrangements and the Terms and Conditions. Unless you advise us within the 30-day period that you do not want your new e-wallet account from the new provider, you agree that we can automatically transfer your unused balance on your account to a new account provided by the new service provider.

You will need to provide random details as required by the operator from your security number for identification.

Instructions once given by you cannot be cancelled or rescinded or amended by you without the written consent of KogoPAY.

KogoPAY may also require you in certain circumstances to confirm the instructions in writing in such form as it thinks fit to avoid ambiguities or for any other reason whatsoever. KogoPAY may record and keep transcripts of recordings made of the dealings and instructions by you over the telephone and use the same to resolve disputes.


4.1 Complaints. If you are unhappy in any way with your e-wallet account or service provided by us or the way it is managed, tell us by using the email enquiry facility on our website or email us at, so we can investigate the circumstances for you. Any complaints you have will be dealt with quickly and fairly.

  1. You have also the right to have your complaint investigated by Alternative Dispute Resolution and to apply to the Financial Ombudsman ( to settle a dispute with us in accordance with the following terms and procedures:
  2. Before applying to Financial Ombudsman you must apply to us at as described above—and no later than 3 months from the day on which you became aware that your rights might have been violated.
  3. If you are not satisfied with our reply, or if you do not receive it within the 15 or 35 days described above, you can apply to the Financial Ombudsman Service (FOS) online at, via email at, via mail to The Financial Ombudsman Service Exchange Tower, London, E14 9SR or via phone 0800 023 4 567 (free), 0300 123 9123, weekdays from 8:00am-8:00pm (GMT), and on Saturday from 9:00am-1:00pm (GMT), outside of UK call +44 20 7964 0500 within 6 months of receiving our final response. After those 6 months, you lose the right to apply to the Financial Ombudsman Service (FOS)to resolve the dispute.

4.2 Compensation. Your e-wallet account is an electronic money product and although it is a product regulated by the Financial Conduct Authority, it is not covered by the Financial Services Compensation Scheme. No other compensation scheme exists to cover losses claimed in connection with your e-wallet account.

This means that in the unlikely event that KogoPAY becomes insolvent your funds may become valueless and unusable: as a result, you may lose your money. Notwithstanding the aforementioned, your funds are kept in first class bank accounts and are segregated in Client Fund accounts to cover the full value of the balances in your e-wallet account.

Hence in the unlikely event that KogoPAY becomes insolvent, the funds held in the pooled client account in the bank cannot be attached or encumbered and will be used to return your funds.

4.3 Disclaimer. We do not accept responsibility for any loss or damage, however caused (including through negligence), which you may directly or indirectly suffer in connection with your use of our website or any linked website; nor do we accept any responsibility for any such loss arising out of your use of, or reliance on, information contained on or accessed through this website and mobile application.

We offer no warranties in relation to the currencies or services sold or listed pursuant to the trading process. We also offer no warranty in relation to the availability of the trading service.

To the extent permitted by law, any condition or warranty which would otherwise be implied into these terms and conditions is hereby excluded. Where legislation implies any condition or warranty, and that legislation prohibits us from excluding or modifying the application of, or our liability under, any such condition or warranty, that condition or warranty will be deemed included but our liability will be limited for a breach of that condition or warranty to one or more of the following:

If an undisputed breach of contract by us relates to the sale or purchase of currency, then we promise:

  1. i) replacement of the currency or the supply of currency of an equivalent value; or
    ii) payment of the cost of replacing the currency or of acquiring equivalent currency. If such a breach relates to services, then we promise to:

iii) supply the same services again; or
iv) payment of the cost of benefiting the same services supplied again.

For the avoidance of doubt, our liability will be limited to the lower of the amount of such loss or damage and the additional cost caused by exchange rate fluctuations of carrying out the necessary rectifying transaction.

4.4 Exception to Disclaimer. This disclaimer set out in these terms and conditions does not attempt or purport to exclude liability arising under statute if, and to the extent, such liability cannot be lawfully excluded.

4.5 Liability and Indemnity. Like any other third-party dependent payment arrangements, we cannot guarantee a merchant will service payments, or that we will necessarily authorise any particular transaction. This may be because of a systems problem, lack of liquidity with that merchant or something outside our reasonable control. Accordingly, we shall not be liable in any event that a retailer refuses to accept your transaction, or if we do not authorise a transaction, or if we cancel or suspend use of your e-wallet account. Unless otherwise required by law, we shall not be liable for any direct or indirect loss or damage you may suffer as a result of your total or partial use or inability to use your e-wallet account.

You agree that we will be under no liability to you in respect of any loss or damage (including indirect, special or consequential loss damage or profit including loss of business, loss of reputation, loss of opportunity) which may be suffered or incurred by you or which may arise directly or indirectly in respect of currency or other services including foreign exchange services supplied pursuant to the service offered over this website and mobile application. Any information provided in the website or links to any sites should not be construed as advice for investment. KogoPAY is not in the business of offering investment advice.

You release and indemnify us against all actions, claims and demands (including the cost of defending or settling any action, claim or demand) which may be instituted against us arising out of a failure by us to comply with these terms and conditions or satisfy the requirements of a sale or purchase.

You also release and indemnify us against all actions, claims and demands (including the costs of defending or settling any action, claim or demand) which may be instituted against us arising out of any act or omission on your part, including but not limited to a failure by you to comply with your obligations under these terms and conditions.

4.6 Access. You must ensure that your access to or use of our web browser application and our mobile application is not illegal or prohibited under relevant law.

4.7 Anti-virus Protection. You must take your own precautions to ensure that the process which you employ for accessing our website or our mobile application does not expose you to risk of viruses or other form of interference which may damage your own computer system or mobile phone. For the avoidance of doubt, we do not accept responsibility for any interference or damage to your own computer or mobile phone which arises in connection with you accessing our website or any linked website or our mobile application.

4.8 Accuracy. Whilst we have no reason to believe that any information contained on our website is inaccurate, we do not warrant the accuracy; adequacy or completeness of such information; nor do we undertake to keep our website updated. We do not accept responsibility for loss suffered as a result of reliance by you upon the accuracy or currency of information contained on our website, web browser application or on our mobile application.

4.9 Service. We do not warrant that the service will be available at all times or at any specific times. We are not responsible in the event that a transaction or trade is not processed due to technical difficulties affecting our system. In the event of any down time; failure or malfunction of any computer equipment or software or of any telephone line or other communication system; we will not be held liable in any circumstances for any transaction attempted by you. We do not undertake to retain listings or to retain records of specific transactions.

We are not responsible for ensuring that warranty obligations are honoured.

4.10 Termination. You acknowledge that your failure to comply with these terms and conditions entitles us to terminate your e-wallet account status. We may determine at our discretion whether such a failure has occurred.


5.1 Copyright. Copyright of our website and mobile application (including text, graphics, logos, icons, sound recordings and software) is owned or licensed by us. Other than as expressly authorised by these terms and conditions, you may not in any form or by any means:

  1. adapt,
  2. reproduce,
  3. store,
  4. distribute,
  5. print,
  6. display,
  7. perform,
  8. publish,
  9. create derivative works from any part of this website.

 or without our prior written consent:

  1. commercialise any information,
  2. products or services obtained from any part of this website or mobile application.

A limited license is granted to you so that you may view our website contents using normal web browsers. This may involve downloading web pages and their contents to your device.

5.2 Trade Marks. Except where otherwise specified, any word or device to which is attached the ™ or ® symbol is a registered trade mark. If you use any of our trademarks in reference to our activities, products or services, you must include a statement attributing that trademark to us. You may not use any of our trademarks:

  1. a) in or as the whole or part of your own trademarks;
  2. b) in connection with activities, products or services which are not ours;
  3. c) in a manner which may be confusing, misleading or deceptive;
  4. d) in a manner that disparages us or our information, products or services.

    3 Restricted Use. Unless we agree otherwise in writing, you are provided with access to this website only for your personal use or business use of your KogoPAY account. You are authorised to print a copy of any information contained on this website for such uses, unless such printing is expressly prohibited. Without limiting the aforementioned, you may not, without our written permission, sell information obtained from our website.

5.4 Linked Websites. Our website may contain links to other websites (‘linked websites”). These links are provided for convenience only and may not remain current or be maintained. We are not responsible for the content or privacy practices associated with linked websites.

Our links with linked websites should not be construed as an endorsement approval or recommendation by us of the owners or operators of those linked websites; or of any information, graphics, materials, products or services referred to or contained on those linked websites, unless and to the extent stipulated to the contrary.

5.5 Termination of Access. Access to this website may be terminated at any time by us without notice. Our disclaimer will nevertheless survive any such termination.


6.1 Information. KogoPAY is required, under the Money Laundering & Terrorist Financing Regulations, to seek certain information from you.

For a business account, the usual documentation is your company’s most recent audited accounts and a copy of the Certificate of Incorporation.

For an individual or a partnership, the usual documentation required is a copy of the relevant pages of your passport or each partner’s passport to include photographs, passport number and personal information; and a copy of a Proof of Address. Here are the guidelines for acceptable Proof of Address documentation:





Document types (please select one):

  • Utility Bill
    • Electricity Bill 
    • Water Bill 
    • Gas Bill 
  • Landline Phone Bill 

Internet Bill

Requirements: Mobile phone bills are not accepted as the service is not specifically supplied to the household and therefore doesn’t prove you live at that address. Disconnect/Cease notice/letter of a utility is not accepted. Joint names on a bill can be accepted Issued within the last 3 months.

Financial Institution Statement

  • Personal bank account 
  • Personal credit card account 
  • Investment account letter or statement 
  • Pension account 
  • Insurance statement

Requirements: Statement must show first name, last name, current address, date and account number issued within the last 3 months

Correspondence between the customer and a government authority

  • Any unemployment benefits, housing benefits, disability assistance, student assistance, pension etc.

Requirements: Issued by the government authority in the area where the person lives within the last 6 months

Tax Statement / Bill / Letter

  • Council Tax
  • Income Tax
  • Tax Return Letter

Requirements: Issued by the government authority for their current address within the last 12 months

Property Rental / Lease Agreement

  • Current residence ONLY with length of rental agreement, signatures of renter & owner and date

Requirements: Issued within the last 12 months

Mortgage Agreement /Statement

  • Current residence ONLY

Requirements: Issued by a bank or credit institute within the last 12 months

Certificate of voter registration

  • Must include first name, last name and current address

Requirements: Issued by the government authority in the area where the person lives within the last 12 months

6.2 Reporting. KogoPAY is an electronic money institution established and authorised under the regulations of the UK Financial Conduct Authority. We are subject to the money laundering regulations of 2017.

6.3 Force Majeure. We accept no liability for any failure to comply with these terms and conditions where such failure is due to circumstances beyond our reasonable control. If we waive any rights available to us under these terms and conditions on one occasion, this does not mean that those rights will automatically be waived on any other occasion.

If any of these terms and conditions is held to be invalid, unenforceable or illegal for any reason, the remaining terms and conditions shall nevertheless continue in full force.


7.1 Visitors. We may collect website or mobile application visitors contact information (like their email addresses). Unless you object, this information may be used:

  1. to send news, information about our activities and general promotional material which we believe may be useful to you;
  2. to monitor who is accessing our website and mobile application, or using services offered on our website and mobile application; and
  3. to profile the type of people accessing the website or and mobile application.

If you do not wish to have your personal information used in this manner or for any other specific purpose, you should email us accordingly at

7.2 Cookies. We utilise “cookies” which enable us to monitor traffic patterns and to serve you more efficiently if you revisit the site. A cookie does not identify you personally but it does identify your computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. For additional information please refer to our Cookie Policy.

7.3 Third Parties. We will not sell or otherwise provide your personal information to a third party, or make any other use of your personal information, for any purpose which is not necessary for your use of our website. For the avoidance of doubt, personal information will not be used for any purpose which a reasonable person in your position would not expect. If you request us not to use personal information in a particular manner or at all, we will adopt all reasonable measures to observe your request but we may still use or disclose that information if:

  1. i) We subsequently notify you of the intended usage, or disclosure, and you do not object to that use or disclosure;
  2. we believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or an agency responsible for government or public security in the performance of their functions; or
  3. we are required by law to disclose the information;

We will preserve the content of any email you send us if we believe we have the legal requirement to do so.

Your email message content and your mobile message may be monitored by us for troubleshooting or maintenance purposes or if any form of email or text abuse is suspected.

7.4 Aggregation. Personal information which we collect may be aggregated for analysis but in such circumstances, we would ensure that individuals would remain anonymous.

7.5 Confidentiality. All personal information which we collect (including your contact details and, if relevant, debit card details) is kept confidential to the best of our ability. You will appreciate, however, that we cannot guarantee the security of transmission.

7.6 Access. You are entitled to have access to any personal information relating to you which you have previously supplied to us over our website or mobile application by contacting us at You are entitled to edit or delete such information unless we are required by law to retain it.

7.7 Unauthorised Access. Individuals should not attempt to trace or investigate the identity or status of any other customer by any means including the use of third parties and illegal entry to secure database of the website or mobile application by ‘hacking’. You should not attempt to write to, telephone, text or otherwise contact any other individual if the identity becomes known for any reason. If you are found to have indulged in these practices, we will terminate your account and legal action may follow.


8.1 Claim. If you wish to make a claim on us under this Agreement, you must notify us at and give us such details of the loss as we may request as soon as you have identified it and in any case within seven days after you become aware or should reasonably have become aware of the event or omission on which your claim is based. If you do not do so we will not be liable to you. If you suspect fraud, unauthorized transaction or security threat to your registered email address or phone number, please use an alternative email address and provide an alternative phone number and security questions will be asked to verify you and your claim.

  1. If you think a Transfer has gone through that was unauthorised or wrongly executed, you must tell us in writing within 13 months of the funds being debited. Not doing so confirms that you approve of a Transfer.
  2. If you notify us of the loss, theft, misappropriation or fraudulent use of a device as described, you will not incur any financial consequences from the improper use of a lost, stolen, or misappropriated device (unless you have acted fraudulently).
  3. As soon as we learn that you didn’t authorize a Transfer, we’ll return the amount of that Transfer to you—no later than by the end of the next Working Day—and, where applicable, restore your Account balance (unless we suspect fraud). If we do suspect fraud, we’ll inform the FIU.
  4. You will have to pay the first 35 GBP of losses incurred through:
  5. usage of a lost or stolen device
  6. misappropriation of a device.
  7. You will not have to cover any losses if:
  8. you could not notice the phone was lost, stolen or misappropriated before the Transfer was made (unless you act fraudulently), or
  9. the unauthorised Transfer was our fault.
  10. You will cover all losses incurred by you acting fraudulently, or if you fail to fulfil your security obligations (see section 1.2.8) intentionally or through gross negligence. If we do suspect fraud, we’ll inform the FIU.
  11. If we do not ask for your personal information and documentation, you will only have to bear the losses of unauthorised Transfers if you have acted fraudulently.
  1. When we carry out a Transfer the Receiver details are considered correct. We have the right (but are not obligated) to check whether the security details correspond to the account holder’s name and surname. If we find a clear mismatch, we can refuse to execute the Transfer.
  2. If a Transfer that you have correctly initiated is incorrectly executed (or not at all), we will (at your request) immediately try to trace the Transfer and let you know the results of our search, free of charge. When we carry out a Transfer according to incorrect data that you have provided, we are not responsible if the Transfer is wrong or incomplete. We will try to recover the funds of incorrect Transfers and, if we cannot, we’ll give you all the relevant information we have (in writing or any other Durable Medium) so that you can file a legal claim to recover the funds.
  3. If the mistake is ours and we are liable for wrong or incomplete Transfers, we will refund you without undue delay and, where applicable, restore the balance of the Account that was debited.
  4. We will also compensate you for any charge you incur from faulty or incomplete Transfers caused by our mistake.
  5. We are not liable for indirect losses incurred by you due to fault or incomplete Transfers. We are only liable for your direct losses.
  6. If you choose to use our Services to pay third parties for their goods and services, you are doing so at your own risk. We have no control over the quality, safety, legality or delivery of those goods and services.
  7. Limitations of our liability will not be applied if prohibited by law.
  8. If you notice that funds that do not belong to you have been credited to your Account, you must inform us immediately.
  9. If an amount is incorrectly credited to your Account, we may debit it without your separate consent. If you no longer have the funds in your Account to cover such a debit, you must repay us within 3 Working Days of receiving our request.

After receiving your claim, we will confirm it with you and give a time limit for our reply. This varies according to the complexity of your claim, but we will do our best to get back to you as quickly as possible, and within no more than 15 Working Days. If we do not think we can reply within that time frame, then we will let you know when to expect our reply, which will be within 35 Working Days. If you have a complaint about the way your claim was handled, refer to section 4.1.

8.2 Third Party Rights. No term of this Agreement shall be enforceable by virtue of the Contracts (Rights of Third Parties) Act 1999 by any person who is not a party to this Agreement.

8.3 Whole Agreement. This Agreement contains our entire agreement. No warranty shall be implied or have any effect unless specifically included in this Agreement and in any changes subsequently notified or the additional conditions.

8.4 Governing Law. These terms and conditions are governed by the laws in force in Lithuania. 


9.1 Individual. This e-wallet account is designed for individual customers who wish to open an e-wallet account. Once a customer submits their details on KogoPAY mobile application and all necessary supporting documents, an account will be opened.

To increase your maximum e-wallet account balance and transaction limits you may be requested to provide further information as deemed necessary. This could, but is not limited to, include further proof of identity or address, proof of source of funds, proof of income, proof of reasons for funds transfer, proof of ID for recipients.

Individual e-wallet account holders may contact customer services for special requirements, which will be reviewed on a case-by-case basis.

9.2 Business. This e-wallet account is designed for business customers who wish to open a e-wallet account.

A Business e-wallet account is a virtual multi-currency e-wallet account. The benefits of a Business account include:

  1. a) Negotiable maximum balance and transaction limits (based on the nature of the business).
  2. b) A multi-currency e-wallet account, allows you to have multiple currencies to be held in one e-wallet account (a monthly fee may be charged).


10.1 Introduction. This section sets out the obligations of KogoPAY with regards to data protection and your rights under the Data Protection Act (2018) (“the Act”), UK GDPR and GDPR from time to time in force.

This Policy sets out procedures which are to be followed when dealing with your personal data. The procedures set out herein will be observed by us, our employees, contractors, agents, consultants, partners or other parties working on our behalf.

10.2 The Data Protection Principles. We observe relevant data protection law as follows –

All personal data:

  1. a) must be processed fairly and lawfully (and shall not be processed unless certain conditions are met);
    b) must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes;
    c) must be adequate, relevant and not excessive with respect to the purposes for which it is processed;
    d) must be accurate and, where appropriate, kept up to date;
    e) must be kept for no longer than is necessary in light of the purpose(s) for which it is processed or applicable law;
    f) must be processed in accordance with the rights of data subjects under the Act;
    g) must be protected against unauthorised or unlawful processing, accidental loss, destruction or damage through appropriate technical and organisational measures; and
    h) must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

10.3 Rights of Data Subjects. You have the following rights:

  1. a) the right to be informed that your personal data is being process;
    b) the right to access your personal data held by us;
    c) the right to prevent the processing of your personal data in limited circumstances; and
    d) the right to rectify, block, erase or destroy incorrectly held personal data about you.

10.4 Personal Data. Personal data is defined by the Act as data which relates to a living individual who can be identified from that data or any other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

The Act also defines “sensitive personal data” as personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.

KogoPAY only holds personal data which is directly relevant to our dealings with you. That data will be held and processed in accordance with the data protection principles and with this Policy. The following data may be collected, held and processed by the Company from time to time:

a) personal details;
b) products and services;
c) financial details;
d) employment details.

10.5 Processing Personal Data. Any and all personal data collected by KogoPAY (including that detailed in this Policy) is collected in order to ensure that we can facilitate efficient transactions with third parties including, but not limited to, our customers, partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. Personal data shall also be used by us in meeting any and all relevant obligations imposed by law.

Personal data may be disclosed within KogoPAY. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will your personal data be passed to any department or any individual within the Company that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.

The Company shall ensure that:

  1. all personal data collected and processed for and on behalf of KogoPAY by any party is collected and processed fairly and lawfully;
  2. you are made fully aware of the reasons for the collection of your personal data and are given details of the purpose for which that data will be used;
  3. your personal data is only collected to the extent that is necessary to fulfil the stated purpose(s);
  4. all of your personal data is accurate at the time of collection and kept accurate and up-to-date while it is being held and / or processed;
  5. none of your personal data is held for any longer than necessary
  6. all of your personal data is held in a safe and secure manner, taking all appropriate technical and organisational measures to protect the data;
  7. all your personal data is transferred using secure means, electronically or otherwise. Frequency of transferred personal data varies on the purpose of transfer and is sent in English
  8. none of your personal data is transferred outside of the UK or EEA (as appropriate) without first ensuring that appropriate safeguards are in place in the destination country or territory; and
  9. some of your personal data might be transferred outside the UK and EU in order to comply with Payments;
  10. You may exercise your rights under data protection law.


10.6 Data Access

  1. You may make a subject access request at any time to see the information which we hold about you;
  2. SARs may be made in writing,.
  3. You may request a copy of these terms and conditions once agreeing to them when registering, they will be sent via electronic email once the request is received.

The following applies to your requested personal data:

  1. The form can be downloaded by KogoPAY Website. The form must be delivered through the members section of the website.
  2. Customer Service will make the request and send to the designated Officer who will make the decision whether the request can be processed.
  3. Upon receipt of a request KogoPAY shall have a maximum period of 28 days within which to respond.

10.7 Data retention time. We shall keep your data during all the time you remain with a business relation with KogoPAY. We might erase the data after five years of your account being closed; unless legal requirements require us to retain the data for a longer period.

10.8 Communication. Any enquiries regarding the KogoPAY service can be answered by contacting the Main KogoPAY Customer Centre by email at:


  1. These T&C will take effect after we approve your application and register you. They will remain valid indefinitely, unless we come to a separate agreement with you.
  2. You may renounce these T&C’s within 14 days of agreeing to them, free of charge. You can do this in writing or via email to At which point all access to the KogoPAY services shall be terminated without any liability to KogoPAY.
  3. Neither party shall be liable for any economic loss, delay or failure in performance of any part of these T&C to the extent that such loss, delay or failure is caused by fire, flood, explosion, accident, war, strike, embargo, governmental requirement, civil and military authority, Act of God, civil unrest, unavailability of public internet, hacking or distributed DoS attacks, inability to secure materials or labor, termination of vital agreements by third parties, action of the other party or any other cause beyond such party’s reasonable control. If such force majeure circumstances last longer than 3 months, either party is entitled to terminate these T&C immediately after giving written notice.
  4. We shall not bear any responsibility for failing to comply with our obligations set out in these T&Cs arising in connection with the state of emergency and/or quarantine declared by governments.

Any dispute, controversy, proceedings or claim relating to this Privcy Policy shall fall within the jurisdiction of the competent courts of the United Kingdom.