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BlindPay Compliance Updates - December

Bernardo Simonassi
Bernardo Simonassi
•

All these updates will take effect on January 8th, 2026.

Important compliance changes are coming to BlindPay's onboarding process to ensure continued regulatory compliance.

TL;DR

  • PoA documents for UBOs are now mandatory
  • New updates to Business PoA documents

PoA documents for UBOs are now mandatory

Starting January 8th, 2026, it will be mandatory for all Ultimate Beneficial Owners (UBOs) to submit a valid proof of address document as part of the onboarding process. For comprehensive guidance on accepted documents and submission procedures, please refer to the documentation here.

New updates to Business PoA documents

If you are onboarding a contractor or freelancer company in Brazil (with a single UBO), and the company's registered address is that of the accountant, we will accept a document co-signed by both the accountant and the UBO. This document should clearly explain their relationship and the reason for using the accountant's address as the company's official registration.

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Blind Pay, Inc. (“BlindPay”) is a United States-based financial technology and payments infrastructure company, incorporated in the State of Delaware on May 2, 2024. BlindPay is duly registered as a Money Services Business (“MSB”) with the Financial Crimes Enforcement Network (“FinCEN”) under registration number 31000277566153. BlindPay is not a state-licensed money transmitter and does not, in its own capacity, engage in regulated money transmission services. All such regulated activities are conducted exclusively through, and under the licenses of, duly authorized financial institution partners. BlindPay's role is limited to providing financial technology, virtual account management, payment processing, and related payments infrastructure services that facilitate payment flows and account functionalities. These services are provided in coordination with its licensed partners and in compliance with applicable federal MSB requirements and relevant state regulatory frameworks.

Blind Pay, LLC (“BlindPay”) is a Delaware limited liability company formed on June 24, 2025. BlindPay is duly registered as a Money Services Business (“MSB”) with the Financial Crimes Enforcement Network (“FinCEN”) under registration number 31000318334247 and is listed in the Nationwide Multistate Licensing System (“NMLS”) under NMLS ID #2745309.

BLIND PAY SOCIEDADE PRESTADORA DE SERVIÇOS DE ATIVOS VIRTUAIS LTDA. (“BlindPay”) is a Virtual Asset Service Provider (“VASP”) operating in Brazil. The company is presently completing the regulatory adaptation process required of Virtual Asset Service Provider Companies (SPSAV) under Central Bank of Brazil Resolution No. 520/2025, and remains subject to the transitional regime set forth in Article 88 of that Resolution. Registered address: Avenida Princesa Isabel, nº 15, Sala 1405, Edifício Martinho de Freitas, Centro, Vitória/ES, 29010-361.

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