Law Enforcement Information Request Guidelines

Last Updated: 1st July, 2026

Introduction

Zabira ("Company," "we," "our," or "us") is committed to complying with applicable laws, regulations, court orders, and lawful governmental requests while protecting customer privacy, maintaining platform integrity, and fulfilling our legal, contractual, and regulatory obligations.

These Guidelines describe the process by which law enforcement agencies, regulatory authorities, judicial bodies, government agencies, business partners, and customers may submit requests relating to customer information, investigations, account restrictions, asset preservation, compliance reviews, and other lawful actions.

These Guidelines are provided for informational purposes only and do not create contractual rights, service commitments, legal obligations, or enforceable expectations in favor of any person or entity.

1. General Principles

The Company evaluates requests in accordance with relevant and applicable legal provisos including but not limited to:

  • Applicable laws and regulations;
  • Data protection and privacy requirements;
  • Anti-money laundering ("AML") obligations;
  • Counter-terrorist financing ("CTF") requirements;
  • Economic sanctions and trade control laws;
  • Financial crime prevention obligations;
  • Contractual obligations;
  • Internal compliance, security, and risk management policies; and
  • Operational and technical considerations.

Nothing in these Guidelines limits or modifies the Company's independent legal and compliance obligations under applicable law.

The Company reserves the right to determine the manner, scope, timing, and extent of any response to a request, subject to applicable legal requirements.

2. Requests From Law Enforcement Officials

Requests from the class of persons/entities mentioned above in relation to Zabira users must follow the protocols below:

2.1 Request Submission:

Requests should be submitted to the Legal Department email: legal@zabira.com

Where applicable, the request must comply with the following:

  • Originate from an authorized governmental, regulatory, judicial, or law enforcement authority using their official email domain and official letterhead on attached documents;
  • Be accompanied by valid legal process or legal authority such as subpoenas, court orders, warrants, or Mutual Legal Assistance document, (valid legal documents from courts consistent only of documents originating from competent courts within the Company's home country);
  • Identify the requesting agency and responsible official;
  • Include sufficient information to identify the relevant customer, account, transaction, wallet, asset, or activity under review.
  • Compulsorily include detailed information, specifying the nature of the investigation, the specific information or action requested, and the legal basis for the request.
  • All documents and communication must be provided in English or accompanied by a certified English translation.

Submission through an official agency communication channel does not, by itself, establish authenticity, legal sufficiency, jurisdiction, or authority.

The Company may undertake independent verification procedures before taking any action, including verification of identity, authority, authenticity, jurisdiction, and legal validity.

Account and Asset Actions: Where the request is for the freezing or preservation of assets, a clear and valid court order must be provided. The request and order for restriction must include the duration of the restriction.

2.2 User Privacy:

In line with our commitment to prioritizing the privacy of our users, we reserve the right but shall have no obligation to notify any customer regarding requests, inquiries, or related actions received regarding them.

The decision to notify or not to notify and the extent thereof shall be made by the Company based on applicable law, regulatory requirements, investigative considerations, risk assessments, contractual obligations, and operational factors.

For certain cases, we may require more information from you to ensure our compliance with applicable laws and regulations as well as internal policies and procedures of Zabira.

We will take all reasonable and necessary steps to verify the legitimacy and legal standing of requests

The Company may delay, limit, modify, or withhold notification for any reason permitted by law.

3. For Merchants, Project Teams, Customers, Vendors, Partners

Users who fall under the above category due to shared technology agreements such as API integrations and channel usage may identify a need to restrict or suspend specific user accounts in relation to potentially fraudulent, unauthorised, unlawful, security-related, or otherwise concerning activities. For such requests, the following protocol must be followed:

  • Request emails must be sent to compliance@zabira.com and shall cc the legal@zabira.com.
  • Request email must contain all relevant information regarding the account to be suspended or restricted - including KYC information, the flagged transaction information where applicable, and other necessary identifiers;
  • For clear understanding of the circumstances, requests must include all relevant information relating to how the decision was made to request for the account restriction or suspension;
  • Requests must be accompanied by supporting documents including police investigation report, court orders or equivalent legal documents to validate the request and subsequent actions on the account.

Submission of a request does not guarantee review, action, response, restriction, suspension, preservation, recovery, or enforcement. Upon receiving the email with requested supporting documents and relevant information, we may review and decide whether to proceed with what is being requested or not based on relevant considerations as permitted by law.

4. For Zabira Users

4.1 Understanding Law Enforcement Processes:

If your account is subject to investigation or action based on a law enforcement request, it is because we have received official legal documentation requiring us to do so. Our actions are strictly in compliance with legal obligations and are not arbitrary.

4.2 Privacy and Security:

Be assured that we respect and protect your privacy and personal information. Any disclosure of your information will be in strict adherence to our Privacy Policy and applicable legal requirements.

We may independently conduct reviews, investigations, monitoring activities, restrictions, suspensions, enhanced due diligence procedures, or other compliance actions where deemed necessary or appropriate, including in connection with:

  • Applicable legal or regulatory requirements;
  • Court orders or legal process;
  • Fraud prevention;
  • Financial crime investigations;
  • Security incidents;
  • Sanctions compliance;
  • AML and CTF obligations;
  • Risk management activities;
  • Contractual obligations;
  • Internal policy enforcement; or
  • Platform integrity and customer protection initiatives.

The Company is not obligated to disclose the existence, scope, methodology, status, findings, or outcome of any review, investigation, monitoring activity, or compliance process except where required by law.

5. General Applicability

This applies to all requesting parties captured in this document in part 1:1 and part 2:2 above.

6. Evaluation of Requests

We review every request on a case-by-case basis. Therefore, we may require additional information, clarification, or supporting documents before determining whether action is appropriate.

Nothing in these Guidelines obligates the Company to comply with any request beyond what is required by applicable law.

We may decline to process or challenge requests that are determined by reasonable judgement to be legally insufficient, invalid, defective, overbroad, disproportionate, ambiguous, technically infeasible, inconsistent with the applicable laws, unsupported by appropriate authority or evidence, and for any other suitable reason.

7. Processing and Response Time

The timing of any review, investigation, response, disclosure, restriction, preservation, suspension, or other action depends on numerous factors, including legal requirements, complexity, jurisdictional considerations, operational constraints, risk assessments, and the availability of relevant information.

The Company makes no representation, warranty, or commitment regarding review, investigation, response, or resolution timeframes.

8. Urgent Requests

For time-sensitive requests where police reports, court orders, or applicable legal authority are yet to be available, the Company may but is not under obligation to consider the request. Zabira has the sole discretion in deciding subsequent actions for such emergency requests.

Where it is determined that restrictions are necessary, we may implement such restrictions for a maximum of 24 hours within which the requester shall provide the necessary legal supporting documents to ratify the request. Otherwise, we may decide to withdraw all restrictions or suspensions put in place.

Such restrictions or measures taken in the emergency situation by Zabira shall not constitute an acknowledgment of legal validity, liability, wrongdoing, ownership rights, entitlement to assets, or an obligation to maintain such measures.

9. Rights and Limitations

Third parties may not rely upon these Guidelines as a basis for asserting rights, claims, expectations, duties, obligations, standards of care, or causes of action against the Company.

The Company may amend, modify, suspend, withdraw, or replace these Guidelines at any time without notice.

To the fullest extent permitted by applicable law, the Company shall not be liable for any loss, damage, claim, cost, expense, delay, interruption, or other consequence arising from or relating to the requests, activities undertaken, or measures taken or not taken in connection with requests made.

Nothing in these Guidelines shall be construed as:

  • Acceptance of jurisdiction;
  • Waiver of rights or defenses;
  • Consent to any request;
  • Recognition of ownership claims;
  • Recognition of entitlement to assets;
  • Admission of liability;
  • Admission of wrongdoing; or
  • Creation of any fiduciary, contractual, statutory, or other duty beyond those imposed by applicable law.

We reserve all our rights including but not limited to our rights to pursue any and all available legal and equitable remedies and challenge jurisdiction.

10. Contact Direction

For further enquiries or assistance regarding these Guidelines or any legal, regulatory, law enforcement, or governmental inquiries, please reach out to legal@zabira.com.

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