> For the complete documentation index, see [llms.txt](https://docs.spendl.money/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.spendl.money/spendl-compliance-pack/spendl-fais-disclosure-notice.md). # Spendl FAIS Disclosure Notice Version 1.2 1\. Document Control | **Version** | 1.2 | | ------------------ | ------------------------------------------------------- | | **Effective Date** | 1 July 2026 | | **Approved By** | Board of Directors | | **Owner** | Chief Compliance Officer | | **Next Review** | July 2027 or sooner on regulatory or operational change | ### 2. Introduction In terms of sections 4 and 5 of the General Code of Conduct for Authorised Financial Services Providers and Representatives (Board Notice 80 of 2003, as amended) under the Financial Advisory and Intermediary Services Act No. 37 of 2002 (FAIS Act), SPENDL is required to disclose the information in this notice. If there is anything in this notice that you do not understand, please contact us to request further information. ### 3. Financial Services Provider Details | **Registered Name** | Light Fusion (Pty) Ltd t/a Spendl Technologies | | ----------------------- | ---------------------------------------------------------------------------------------------- | | **Registration Number** | 2023/154151/07 | | **FSP Licence Number** | 53757 | | **FSP Category** | Category I - Intermediary services in respect of crypto assets (as an Exempt Crypto Asset FSP) | | **FIC Registration** | Accountable Institution, Org ID 74993 | | **Physical Address** | Central Square, Pinelands, Cape Town | | **Website** | [www.spendl.money](http://www.spendl.money) | ### 4. Contact Details * General support: * Compliance Officer (CCO): Carl Muller, * Information Officer (POPIA): Carl Muller, * Complaints: ### 5. Key Individuals and Representatives SPENDL's appointed Key Individual is Carl Muller. Key Individuals and Representatives are recorded on the FSCA website ([www.fsca.co.za](http://www.fsca.co.za)). Some Representatives may work under supervision as required. SPENDL has the necessary controls and procedures in place to ensure its Key Individuals and Representatives comply with the prescribed Fit and Proper Requirements (including experience, qualifications, regulatory examinations, and honesty and integrity requirements) as outlined in the Determination of Fit and Proper Requirements for Financial Services Providers, 2017 (Board Notice 194 of 2017). SPENDL accepts full responsibility for financial services rendered by its Representatives within the scope of their authorisation. ### 6. Nature and Scope of Financial Services SPENDL provides intermediary services in relation to crypto assets under FAIS Category I. The Services include: * SPENDL Card: A prepaid reloadable debit card funded by converting supported Crypto Assets to ZAR (Schedule A of the Terms and Conditions). * B2B Platform and Public API: Multi-tenant infrastructure for regulated or compliance-conscious businesses (Schedule B). * ITT: A closed-loop tokenised payment instrument (Schedule C). * Cross-Border Crypto Compliance: Inbound and outbound cross-border crypto-asset flow handling (Schedule D). * Treasury and Off-Ramp: Crypto-to-ZAR conversion and settlement (Schedule E). SPENDL does not provide investment, legal, tax, accounting, or financial advice. Where SPENDL provides intermediary services, those services are intermediary in nature and not advisory. ### 7. Financial Intelligence Centre Act (FIC Act) SPENDL is registered as an Accountable Institution with the Financial Intelligence Centre (Org ID 74993). SPENDL is obliged to: * Identify and verify Customers (KYC/CDD) under its Risk Management and Compliance Programme (RMCP) adopted under section 42 of the FIC Act. * Maintain records of verification documents for at least five years. * Report suspicious or unusual transactions to the FIC. * Screen Customers, Beneficial Owners, and transactions against Sanctions Lists. * Comply with the Travel Rule under FIC Directive 9. ### 8. Compliance SPENDL's compliance is monitored by its appointed Compliance Officer, Carl Muller. The Compliance Officer ensures adherence to the FAIS Act, the General Code, the FIC Act, POPIA, and applicable Joint Standards. * Compliance Officer email: ### 9. Conflicts of Interest SPENDL has adopted a Conflict of Interest Management Policy in compliance with Section 15 of the FAIS Act and the General Code. The policy is summarised in the Terms and Conditions and is available on request or via the Website. * SPENDL identifies and avoids actual, potential, and perceived conflicts where reasonably practicable. * Where a conflict cannot be avoided, it is managed and disclosed to the affected Customer. * SPENDL does not pay or accept inducements that could compromise the duty owed to a Customer. * Employee personal-account dealing is restricted. * The policy is reviewed annually and on any material change. SPENDL currently holds no ownership interests in product suppliers or third parties that could create a conflict of interest. ### 10. Professional Indemnity and Fidelity Cover As a crypto asset service provider (CASP), SPENDL is currently exempt from the requirement to maintain professional indemnity insurance and fidelity guarantee cover under Part VI of the Determination of Fit and Proper Requirements for Financial Services Providers, 2017 (Board Notice 194 of 2017), pursuant to FSCA FAIS Notice 25 of 2023, as stated in clause 3.2 of the Terms and Conditions. The exemption may be amended or withdrawn by the FSCA, in which event SPENDL will comply with any new requirements within the prescribed period. ### 11. Risk Disclosures The full Risk Notice and Crypto Asset Risk Disclosures are set out at the front of the Terms and Conditions and incorporated into Part 7. Key risks include: * Crypto assets are highly volatile and speculative. You may lose some or all of your capital. * Conversion rates include an FX margin and are subject to slippage and market movement. * Crypto asset transactions are confirmed by independent blockchain networks that SPENDL does not control. * ZAR Balances are held in a pooled client account at the Programme Partner and are not protected by any statutory deposit-insurance scheme. * Stablecoins may lose their peg, be frozen by their issuer, or become illiquid. * SPENDL does not promise returns, yields, capital protection, or any specific outcome. You are encouraged to read the full Risk Notice in the Terms and Conditions and seek independent professional advice before transacting. ### 12. Fees Fees are set out in the Fee Schedule (Schedule F of the Terms and Conditions) published on the Website. Fee categories include: card issuance and replacement, ATM and POS transaction fees, crypto-to-ZAR conversion fee and FX margin, Network and pass-through fees, monthly platform fees (B2B), and others as detailed in the Fee Schedule. SPENDL may amend fees on notice in accordance with its Terms and Conditions. ### 13. Complaints Procedure If you wish to lodge a complaint, submit it in writing to with all supporting documents. SPENDL will acknowledge the complaint within 3 Business Days and aim to resolve it within 30 days as per our Terms and Conditions. Our Complaints Management Policy is available on the Website. If unresolved, you may escalate to the below in accordance with our Terms and Conditions: #### Ombud for Financial Services Providers (FAIS Ombud) * Address: Menlyn Central Office Building, 125 Dallas Avenue, Menlyn, Pretoria, 0010 * Telephone: 012 762 5000 / Sharecall 0860 663 274 * Email: * Website: [www.faisombud.co.za](http://www.faisombud.co.za) **Note:** Complaints must be referred to the Ombud within six months of SPENDL's final response. #### Information Regulator For data protection complaints under POPIA: * Email: * Website: [www.inforegulator.org.za](http://www.inforegulator.org.za) ### 14. Protection of Personal Information (POPIA) SPENDL processes Personal Information in accordance with POPIA and, where applicable, the EU GDPR and UK GDPR. The Privacy Policy published on the Website describes the categories of Personal Information collected, purposes, lawful bases, recipients, retention periods, security measures, cross-border transfer mechanisms, and your rights. Our full Privacy Policy is available on request or via the Website. ### 15. Document Storage SPENDL keeps records of Customer information, instructions, and communications for at least five years in accordance with the FIC Act and our Terms and Conditions, the FAIS Act, and tax law. Electronic back-ups are maintained. ### 16. Waiver of Rights SPENDL will never request or require a Customer to waive their rights under the FAIS Act, the Consumer Protection Act, POPIA, or any other non-excludable statutory right. ### 17. Customer Declaration By using SPENDL's Services, you confirm that you have read and understood this FAIS Disclosure Notice and agree to be bound by SPENDL's Terms and Conditions. ### 18. Version Control | **Version** | **Effective Date** | **Summary of Changes** | **Reason for Changes** | **Approved By** | | ----------- | ------------------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------ | | 1.1 | 1 September 2025 | Founding version - initial FAIS Disclosure Notice issued | Initial FSCA/FAIS compliance requirement upon platform launch | Board of Directors | | 1.2 | 1 July 2026 | Rewritten with added sections on services offered, risk disclosures, and fees, plus stronger legal citations, a corrected FSP category, and version control details | Updates reflect Spendl’s revised RMCP, tightened FIC rules (sanctions screening, Travel Rule), and FSCA disclosure requirements for crypto-asset providers, aligning with the broader compliance pack refresh | Board of Directors |