Compliance
Compliance by design
- Keys never touch a device.
- Every party is screened.
- Every transaction is recorded.
Compliance
Who performs regulated activities, and what Saleem is.
5 Lanes Limited, trading as Saleem, is registered in ADGM and is not licensed to conduct regulated financial activities. At launch, licensed partners will perform fiat cash-in and cash-out, custody and any other regulated activity required in each jurisdiction. Saleem will provide the software layer for instruction validation, screening orchestration, routing, records and reconciliation.
Saleem may pursue additional permissions, directly or through a group entity, as the operating model and corridor requirements mature.
Target operating model, not present fact.
| Saleem | Sending partner | Receiving partner | |
|---|---|---|---|
| Cash-in | Validates the instruction | Receives the funds and converts them, under its licence | None |
| Custody | Holds no funds and no keys; provides the interfaces | Holds value until it is transferred, under its licence | A licensed custodian holds recipient balances |
| KYC | Orchestrates the checks and records the result | Verifies the payer, under its licence | Verifies the recipient, under its licence |
| Sanctions screening | Orchestrates screening of every party and payment; records the result | Screens and decides on its own customers | Screens and decides on its own customers |
| Travel Rule | Formats and carries the originator and beneficiary data | Meets the originator obligation | Meets the beneficiary obligation |
| Routing | Chooses the route and the network | None | None |
| Records | One record per payment, and the reconciliation file | Keeps its own regulatory records | Keeps its own regulatory records |
| Cash-out | Validates and records the instruction | None | Pays out in local currency, under its licence |
OFAC, Syria sanctions programme page; US Congress, FY2026 NDAA. Position pending compliance review.
KYC, sanctions and the Travel Rule, on every party and every transfer.
Document identity verification, biometrics and risk-tiered onboarding, through two providers.
Counterparty risk, sanctions, surveillance and analytics, four providers in consensus; residual designations screened on every transaction.
IVMS101 originator and beneficiary data exchanged on every settlement chain.
Tiered verification is a specified design, with limits scaled by verification level. Compliance providers are integrated at the client layer; the server-side wiring sits within production scope.
Custody, key management and data protection.
Recipient balances are to be held by a licensed custodian and accessed through Saleem's interfaces; keys do not sit on the handset. This is the target operating model at launch. The account is the phone number, protected by a PIN, so a lost or shared handset does not expose the balance.
Institutional-grade wallet infrastructure covering end-user wallets, partner and institutional settlement, and treasury reserves across six settlement networks.
An encrypted document vault (AES-256, SHA-256 integrity) with jurisdiction-aware retention. Saleem never sells, licenses or transfers consumer data; any analytics are opt-in, consent-based and cohort-level, with every query audit-logged; an independent Data Protection Officer is appointed ahead of launch with board access, and data subject access requests are honoured within statutory windows.
Records, reporting, reconciliation and governance.
Every payment, approval and spend on a tamper-proof audit trail; every bulk disbursement row passes six sequential compliance stages.
Exports in bank formats: camt.053 and camt.054, MT940, BAI2 and CSV.
Disbursement reconciliation per recipient; every batch and every failure accounted for.
Two people approve every disbursement, and a compliance console covering risk overview, KYC review and the document vault, Travel Rule transfers, screening consensus and the audit trail.
Six client surfaces are built and demonstrable against mocked services. The production backend, licensed-partner connections and independent security testing remain pre-launch work. No customer funds move on the platform today.
Dirham payment tokens under the CBUAE regime (DDSC, AEDZ, AE Coin) and dollar tokens recognised by the ADGM FSRA (USDC, USDT, USDU), on six settlement networks. Status and licence per network and token
Marks shown are the property of their respective owners and indicate technical support, not endorsement.