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ComplyPay

“Can a non-bank, DLT-powered wallet infrastructure become the default escrow and payouts layer for European platforms?”

HQCopenhagen, Denmark
FoundersStefan Krumbæk, Mads Stolberg-Mathieu
IndustryInfrastructure / Payments
The story

ComplyPay is the trading name of Danish payments company ZTLment ApS. The company offers API-based 'compliant wallet infrastructure' — virtual IBAN wallets, multi-currency payouts, escrow-like splits and KYC — pitched to marketplaces and SaaS platforms. The product is powered by distributed ledger technology and rides on Banking Circle's payment infrastructure for global payouts.

Last 12 months
2025-05
2025-03
Product timeline
0
ZTLment ApS founded in Copenhagen, CVR 41801298· founding
2025
Partners with Banking Circle to power global payouts under the ComplyPay brand· banking
Regulated entities
1
regulatory licence held by ComplyPay
Licence types, jurisdictions and registered entities are in the Embedded Finance Index report.
The stack
6 layers disclosed in ComplyPay’s embedded-finance stack
Payments / PSP
ComplyPay (self-operated)
Banking / BaaS
in the full report
Ledger
in the full report
Unified APIs
in the full report
Sponsor bank
in the full report
FX & payouts
in the full report
Accounting gap: significant
5 more providers across 5 layers, with confidence-scored evidence and source URLs, are in the Embedded Finance Index report.

ComplyPay — frequently asked

What bank does ComplyPay use?

ComplyPay discloses Banking Circle as its banking provider, according to the Embedded Finance Index 2026.

Is ComplyPay a bank?

ComplyPay does not disclose a bank charter of its own; its banking services are provided through Banking Circle.

Who is ComplyPay's payment processor?

ComplyPay processes payments through ComplyPay (self-operated).

What ledger does ComplyPay use?

ComplyPay runs its ledger on ComplyPay distributed ledger (in-house).

Who handles ComplyPay's FX and cross-border payouts?

ComplyPay uses Banking Circle for FX and cross-border payouts.

What is ComplyPay's embedded finance stack?

The Embedded Finance Index 2026 maps 6 layers in ComplyPay's stack: Payments / PSP (ComplyPay (self-operated)); Banking / BaaS (Banking Circle); Ledger (ComplyPay distributed ledger (in-house)); Unified APIs (Banking Circle); Sponsor bank (Banking Circle); FX & payouts (Banking Circle).

Who founded ComplyPay?

ComplyPay was founded by Stefan Krumbæk and Mads Stolberg-Mathieu and is headquartered in Copenhagen, Denmark.

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