“Can a non-bank, DLT-powered wallet infrastructure become the default escrow and payouts layer for European platforms?”
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.
ComplyPay discloses Banking Circle as its banking provider, according to the Embedded Finance Index 2026.
ComplyPay does not disclose a bank charter of its own; its banking services are provided through Banking Circle.
ComplyPay processes payments through ComplyPay (self-operated).
ComplyPay runs its ledger on ComplyPay distributed ledger (in-house).
ComplyPay uses Banking Circle for FX and cross-border payouts.
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).
ComplyPay was founded by Stefan Krumbæk and Mads Stolberg-Mathieu and is headquartered in Copenhagen, Denmark.
Get a read on where your own stack stands against ComplyPay and the rest of its category — what they built versus bought, which providers they use, and where the gaps in your own strategy and competitive set actually are.