NASDAQ: RELY

2025 Key Performance Metrics

The substantial majority of our revenue is currently generated from our global money movement product, where we earn revenue from transaction fees charged to customers and foreign exchange spreads applied to the amount the customer is sending.

In addition to our financial results, we regularly review key performance metrics to evaluate our performance, identify trends affecting our business, prepare financial projections, and make strategic decisions. We believe that these key performance metrics provide meaningful supplemental information for management and investors in assessing our historical and future operating performance. The calculation of these key performance metrics discussed below may differ from other similarly titled metrics used by other companies, analysts, or investors. The key performance metrics that we use to measure the performance of our business are defined as follows:

•“Active customers” is defined as the number of distinct customers that have successfully completed at least one transaction using Remitly during a given period. We identify customers through unique account numbers.

•“Send volume” is defined as the sum of the amount that customers send, measured in U.S. dollars, related to transactions completed during a given period. This amount is net of cancellations, does not include transaction fees from customers, and does not include any credits, offers, or bonuses applied to the transaction by us.

We measure active customers on a quarterly basis and as a result, this metric is only presented on a quarterly basis.

Our 2025 key performance metrics included the following results:

•Active customers for the fourth quarter of 2025 increased to 9.3 million, from 7.8 million, up 19% year over year.

•Send volume for the year ended December 31, 2025 increased to $74.9 billion, from $54.6 billion, up 37% year over year.

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The charts below present the respective key performance metrics for the past five fiscal years (active customer figures below represent active customers during the fourth quarter of the respective year):

Our Platform

The core product on our platform enables customers to send money digitally across borders. Our customers predominantly engage with us via their mobile phones, either using our mobile app, website, or messaging services, shifting what traditionally required waiting in line to speak with an agent to handheld devices. Our customers are able to set up an account and start sending money to international recipients, generally within minutes. Recipients can receive funds in multiple ways using our diversified, high quality global disbursement network. Our customers can also track the status of their transactions as they are processed. Providing our customers with a convenient, easy, and safe digital-first experience underpins our approach to product development, marketing, and customer success efforts.

While remaining focused on global money movement, which represents the substantial majority of our revenue today, we continue to evolve and invest in our technology to deepen relationships with our customers and attract new customers by adding relevant services, features, and products on our platform.

Strategy

We operate in a large, diverse, and growing global cross-border payments market. Based on recent estimates from FXC Intelligence, a financial data company, consumers and small to mid-sized businesses move more than $22 trillion across borders annually, a figure expected to reach more than $34 trillion by 2032. The consumer-to-consumer category alone represents approximately $2 trillion, with the additional categories of consumer-to-business and business-to-business expanding our total addressable market potential significantly.

Our approach to achieving our strategy has been rooted in deeply understanding our customers’ unique and local needs to provide them with a differentiated experience in cross-border payments. Managing our business from this perspective has been key to our success since the very beginning and forms the framework of our strategy, which includes the following focus areas:

•Focus on core global money movement. Global money movement remains the foundation of our business and represents the substantial majority of our revenue today. We continue to prioritize delivering a reliable, fast, and transparent cross-border payment experience, supported by disciplined execution and ongoing investment in our platform. This focus enables us to strengthen customer trust, increase engagement, and support consistent usage.

•Unlock incremental customer categories. As we have scaled our core offering, we have broadened the set of customers we serve beyond low-amount senders to include high-amount senders, businesses, and receivers. These customer categories reflect a wider range of cross-border financial needs and represent meaningful opportunities to expand our addressable market while leveraging the same underlying platform and network.

•Deepen our customer relationships through adjacent and novel use cases. Building on the trusted relationships established through money movement, we continue to introduce additional products and features designed to increase customer engagement and lifetime value. These include Remitly Flex, which allows customers to send now and pay later via a no-interest, flexible payment option to fund their cross-border transactions; Remitly Wallet and Card, which respectively enable customers to store and save money in a digital wallet, and spend funds globally with a digital debit card; and membership and loyalty programs, which deliver a unified experience that builds and

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rewards engagement with our products and services through Remitly One. We expect these products to deepen relationships with existing customers and attract new customers seeking broader cross-border financial solutions.

•Scale with discipline and efficiency. Across all stages of expansion, we apply a data-driven approach to customer acquisition, product development, and resource allocation. Our strategy emphasizes sustainable growth, efficient unit economics, and reinvestment in platform capabilities that support long-term scalability. As we expand into new geographies and customer categories, we remain focused on balancing growth with operational efficiency and attractive unit economics.

Together, these strategic priorities allow us to pursue long-term growth while remaining anchored in our core global money movement business and leveraging our platform to serve a broader set of cross-border financial needs over time.

What Sets Us Apart

Our competitive advantage is built on three core strengths—trust, network, and scale—which together enable us to deliver reliability, speed, and a fair and transparent price for cross-border financial services.

Trust

Trust is the foundation of everything we do and is earned through reliability, fairness, and security. Delivering cross-border financial services in a trusted and reliable way across geographies is incredibly complex. We are focused on delivering a reliable and seamless experience to customers that builds trust and drives repeat engagement with our platform. We manage this complexity by localizing services across more than 175 countries, supporting diverse payment methods and currencies, maintaining robust fraud and compliance systems, and operating sophisticated treasury and foreign exchange capabilities to deliver funds reliably through our global disbursement network.

Our digital-first platform provides an easy-to-use, end-to-end process with a simple and reliable user experience that builds trust by delivering peace of mind. In just a few minutes, customers are able to set up and send money for the first time with Remitly, and repeat transactions are easier with just a few taps. Our users can also track the status of their transactions as they are processed, and we provide a reliability promise to customers which is underpinned by our sophisticated risk models, high quality network, and empathetic customer service.

We also earn trust through the quality and resilience of our partner ecosystem. We select and manage funding and disbursement partners based on service quality, regulatory compliance, operational performance, and risk standards, and we design our network with redundancy across corridors to support reliability and continuity of service.

This reliable, fair, and secure experience enables us to engage beyond the initial transaction, generating strong repeat usage and high customer loyalty. Our services are highly non-discretionary for many of our customers, which results in high revenue visibility throughout economic cycles. As of December 31, 2025, our Remitly app had a 4.9 iOS App Store rating with approximately 4.0 million reviewers and a 4.8 Android Google Play rating with over 1.3 million reviewers (app ratings are based on all countries or regions and the rating may vary based on user location and device type).

Network

Our global network of funding and disbursement partnerships is at the core of our business and enables us to complete transactions efficiently across more than 5,300 corridors without the need to deploy local operations in each country, while complying with global and local licensing and regulatory requirements. A corridor represents the pairing of a send country, from which a customer can send a cross-border payment, with a specific receive country to which such cross-border payment can be sent. As a result of the quality of our network and the foundational investments we have made, adding a new send country typically unlocks a significant number of new corridors, allowing us to scale rapidly.

Our network strategy emphasizes direct integrations with funding and disbursement partners wherever possible, reducing reliance on intermediaries and supporting faster, more reliable, and cost-efficient delivery of funds. This approach also helps mitigate operational complexity and concentration risk while enabling consistent service levels across geographies. These direct integrations also allow for a better customer experience and lower costs and are a significant competitive advantage. Our partners, including those that are among the most trusted and recognized brands around the world, create a broad and effective pay-in and disbursement ecosystem for our customers:

•Pay-in Acceptance. We have relationships with top tier banks and leading global payment processors and networks. These relationships provide our customers an array of payment options to fund cross-border payments with a bank account, card-based payments, or alternative payment methods.

We can accept and settle transfers from hundreds of millions of consumer bank accounts, payment methods such as Apple Pay and Google Pay, as well as Visa and Mastercard credit and debit cards. As a digital service, we typically do not have sending agents who accept cash. We, in turn, do not incur costs or commissions associated with physical agent-based sending and funding.

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•Payment Disbursement. We provide broad and high quality access to disbursement options for our customers allowing them to choose the method that is most convenient for their recipients, including bank accounts, cash, and alternative payment methods. Our broad disbursement network supports reliable delivery and choice, allowing customers to select whatever method works best for their family and friends to receive funds. We have access to many disbursement partners across the globe including major banks, aggregators, cash pick-up options, and mobile wallet partners. These relationships provide our customers with choice of disbursement and enable us to send funds within minutes, or even seconds, to over 5.4 billion bank accounts and mobile wallets, and approximately 490,000 cash pick-up options, including retail outlets and banks.

We select our disbursement partners based on our recipients’ preferences, quality of service, cost, brand recognition, and co-branding opportunities. Our disbursement partners make us a trusted source of global money movement because our customers are typically already familiar with their chosen disbursement partner and recipients feel comfortable receiving money where they regularly bank or shop. In addition, we only select disbursement partners that meet or exceed: (1) our geographic coverage goals in the regions in which they operate; (2) our robust compliance and regulatory requirements; and (3) our specific operating metrics such as credit worthiness and error rates.

As a result of our significant global presence, we are able to establish multi-faceted partnerships. These partnerships enable the ability to source and settle foreign exchange rates locally, accept payments, or deposit customer funds directly to customer accounts. In addition, we have redundancies built into our global network for our various partnerships.

We focus on creating financial inclusion by providing payout optionality and access for recipients who do not always have convenient access to traditional banking. We believe our focus on financial inclusion creates peace of mind for our customers and their families while attracting and retaining loyal customers.

Our customers primarily send money from the United States, Canada, the United Kingdom, and other countries in Europe, with recipients located around the world. Our largest receive countries by send volume include India, Mexico, and the Philippines.

Scale

We believe scale reinforces both trust and network capabilities by enabling lower unit costs, better pricing, and continuous reinvestment in product performance and quality, including through greater use of direct integrations that improve efficiency as our volumes grow. Our data-driven approach to optimizing customer lifetime value, combined with localized and scalable marketing solutions, allows us to acquire new customers at attractive unit economics. In addition to product enhancements and efficiencies in variable operating costs, we are transforming our marketing engine from a single-product acquisition model into an artificial intelligence-powered system that drives multi-product engagement, and strengthens our ability to reactivate, retain, and increase share of wallet among existing customers. We believe our expertise in localizing our marketing, products, and customer support at scale is a key differentiator and enables us to provide customers with a personalized experience that drives peace of mind while also delivering high returns on marketing and product investments.

Our scale also supports our disciplined expansion into new customer categories and use cases across the world. We see significant opportunity to create value by expanding our cross-border financial services to a broader set of customers. Building on our roots of serving primarily low-amount senders who send money to family and friends, we now also serve high-amount senders, businesses, and receivers, across our global network. As we continue to scale, we apply a data-driven approach to optimize customer value, product features, marketing strategies, and economics across new geographies and customer categories. We also leverage our localization expertise and technology to strengthen our global partner network through additional direct integrations and expanded payment methods to enhance our cross-border payment experience across corridors.

Technology

Our purpose-built technology enables the foundation for our multi-product strategy and our ability to deliver trusted, reliable, and localized digital financial services at global scale. We have evolved from a single-product provider to a flexible and scalable platform, powered by shared services, modular components, real-time data platforms, advanced data, and artificial intelligence (“AI”) models, while maintaining security and trust.

We believe that our differentiated approach to building and operating our technology infrastructure enables a great customer experience and allows us to meet customer demands in a more flexible way. Our technology has broad and complex capabilities and, together with our proprietary data, gives us a distinct advantage in understanding our customers and being able to meet their needs. Given the scale of our business, the local nuances of the regions we serve, and the complexity of digital cross-border financial services, continued investments in our technology have positioned us for efficiency, innovation velocity, and sustained growth. Our technology approach includes the following:

•Rapid innovation. Our platform enables faster product development and iteration through shared services, modular architecture, and real-time data infrastructure, allowing us to launch new products and features efficiently, test and learn in-market, and expand successful offerings across geographies and customer categories with lower incremental cost;

•Trust and compliance. Our unified risk systems, including electronic Know Your Customer (“KYC”), machine learning-based fraud scoring, and real-time payment authentication, are deployed across our products and provide customers immediate feedback, while adhering to highly complex and evolving global and local regulatory requirements;

•Data advantage. We leverage proprietary data generated from customer transactions across our platform to power intelligent pricing, personalization, and security, all of which support continuous optimization as we scale; and

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•AI-powered efficiency. We embed AI across customer-facing experiences and internal workflows to improve speed, accuracy, and cost efficiency. Machine learning further enhances trust, risk management, and forecasting, enabling more intelligent, personalized, and secure interactions across our platform.

Customer Experience

With a focus on simplicity and delight for our customers, we strive to make each customer interaction on our platform fast, intuitive, and effortless. We focus on reducing friction throughout the end-to-end journey while providing clarity, predictability, and confidence that funds will arrive as expected. New customers can typically initiate a transaction with only a few taps after setting up their account and adding their recipient’s information. We have further streamlined the experience for existing customers completing repeat transactions. In addition, we recognize that customers’ needs and preferences vary across corridors and payout method. As a result, we continue to localize the customer journey by tailoring language, payment methods, product selection, and user flow to local preferences.

When issues or delays do occur, we prioritize fast resolution and self-service, whenever possible. Customers can access tools and support content designed to address common questions and issues directly. For customers who prefer live assistance, we provide access through the Remitly Help Center and an AI-powered virtual assistant that reflects our broader use of AI to deliver faster, consistent, and conversational support while maintaining access to associates when needed.

We continuously leverage data-driven insights to improve reliability, reduce friction, and enhance the performance of our products and services. Dedicated teams across product, engineering, design, analytics, compliance, marketing, and customer service are responsible for the envisioning, design, development, and testing of our products and services. The majority of our investment is focused on developing new functionality, expanding global accessibility, improving the customer experience, reducing fraud loss rates, and further enhancing the usability, reliability, and performance of our platform.

Competition

We operate in a highly competitive global cross-border payments and financial services landscape. We compete with a range of providers that vary in scale, geographic reach, regulatory coverage, technology capabilities, and the extent to which their products are designed specifically for cross-border use cases. Competitive dynamics are influenced by factors including trust and reliability, network depth and payout optionality, customer experience, pricing, regulatory compliance, and the ability to operate efficiently at scale. Our competitors generally fall into the following categories:

•Incumbent providers with a scaled legacy footprint. These legacy providers operate extensive networks of brick-and-mortar locations with agents around the world, and have broad brand recognition in certain corridors. While they often offer wide geographic coverage, they typically have been slow to adopt digital solutions, which can result in higher costs, slower settlement times, and more limited customer experiences.

•Traditional banks and global financial institutions. Traditional bank networks offer a wide variety of financial services, including global money movement. While they may benefit from scale and regulatory reputation, they have limited disbursement options and may have burdensome KYC processes that do not cater to global citizens.

•Digital-first cross-border payment providers. These providers aim to provide payments, money transfer, and other financial products with convenience, transparency, and affordability. Some operate at regional or sub-scale levels, with limited corridor coverage, payout options, or licenses, while others may offer global digital services without cash payout capabilities. As a result, many digital-first providers face trade-offs between customer experience and the depth, resilience, or breadth of their underlying payment infrastructure.

•Emerging players focused on complementary financial products and services, and alternative payment solutions. These include digital-only banks, digital wallets, neobanks, and other emerging fintech platforms that typically offer a subset of the financial services offered by traditional banks with a greater emphasis on convenience and user experience. Emerging players also include providers leveraging stablecoins to facilitate cross-border payments, which may offer faster settlement and lower transaction costs than traditional rails, but remain subject to evolving legal, regulatory, and operational considerations. Remitly views stablecoins as an emerging payment rail that may complement the traditional infrastructure where appropriate, by giving customers the option to receive, hold, or spend funds using stablecoin-based payment methods.

•Informal person-to-person channels. Informal methods, such as bringing cash home when global citizens travel and trusting others to deliver cash back home, continue to be used in certain corridors. Established networks of “IOUs” based on documentation or passwords, and other systems of trust-based cash transfers typically lack transparency, regulatory oversight, and consumer protections. As digital alternatives expand in reach, reliability, and accessibility, we believe the share of informal person-to-person channels will likely diminish over time, expanding the addressable market for the formal competitor categories described above.

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Digital-first companies, like Remitly, are increasingly gaining market share from legacy providers and traditional banks. We believe that the principal competitive factors across experience, product, network, and technology include:

•Experience. Digital-first companies are focusing on the customer experience, by providing a trusted relationship with customers and their families, especially during challenging times, such as family emergencies or natural disasters. Digital-first companies provide simple and convenient customer experiences, tailored by region and corridor, which appeals to customers and their families on a hyper-local level.

•Product. Digital-first companies have the ability to focus on the product. With the various pay-in and pay-out options, the speed and certainty of transactions is a competitive advantage. Remitly’s diversified product suite supports multiple payment rails, which includes traditional methods and emerging alternative payment options, offering customers flexibility and choice. Digital-first companies are able to provide an adjacent suite of digital-first financial services with fair and transparent product pricing, while providing global and local customer service.

•Network. Digital-first companies leverage their expansive global network to provide a vast array of easy-to-access disbursement options and the ability to accept alternative payment methods.

•Technology. Digital-first companies focus on technological differentiation, through service availability, performance, scalability, and reliability. The ability to innovate continues to be a competitive advantage. Technology also enables continuous customer experience improvements within a complex, highly regulated industry.

By focusing on the unique needs of our customers, we believe that we have built a differentiated and compelling value proposition, and that we compete favorably on the basis of these factors. Specifically, we believe that our digital-first suite of products, our vast global network, our localization expertise at scale, and our data-driven approach create sustainable differentiation in relation to our competitors.

Regulatory Environment

Our business is subject to a wide range of federal, state, and foreign laws, regulations, and supervisory guidance across the globe. The majority of these are applicable to us on the basis of the jurisdictions in which we operate and conduct our activities. These include, without limitation, the United States, Canada, the United Kingdom, and the European Economic Area (the “EEA”). We may also be subject to laws, regulations, and guidance on the basis of the jurisdictions in which recipients receive disbursements. These include India, Mexico, and the Philippines, as well as other receive countries. These laws and regulations include strict requirements intended to help detect and prevent money laundering, terrorist financing, sanctioned persons and activity, fraud, data misuse, theft and misappropriation, and other illicit activity. In addition, the applicable regulatory framework includes laws, regulations, and guidance regarding money transmission and financial services licensing, operational risk frameworks including outsourcing oversight, consumer protections including disclosures, foreign exchange, safeguarding of customer funds, currency controls, unclaimed property, privacy, data sharing, and cybersecurity. The regulatory requirements applicable to our business in any given jurisdiction are typically extensive, complex, frequently evolving, and increasing in scope, and may impose overlapping and/or conflicting requirements or obligations. For more information, see the section titled “Risk Factors—Legal and Compliance Risks.”

We have developed and implemented a compliance program, including our anti-money laundering (“AML”) and consumer protection programs, composed of policies and procedures designed to comply with applicable regulatory frameworks. We also monitor these areas closely to continue to adapt our business practices and strategies to help us comply with the current and evolving regulatory environment.

Anti-Money Laundering

In the United States, our business is subject to federal AML laws, regulations, and supervisory guidance, which includes the Bank Secrecy Act (as amended, the “BSA”), as well as similar state laws, regulations, and supervisory guidance. The BSA, among other things, requires companies engaged in money transmission to register with the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury as money services businesses and to develop and maintain risk-based AML programs, report suspicious activity, and collect and maintain information about their customers and certain transaction records. These requirements may also apply to our disbursement partners and, if our partners have relationships with their own disbursement providers, those partners’ disbursement providers (“disbursement sub-partners”). Furthermore, FinCEN has interpreted the BSA to require money services businesses to conduct risk-based monitoring of their counterparties.

Similar AML laws, regulations, and supervisory guidance in the countries where we operate and those where we are licensed apply to our business internationally. These include laws, regulations, and supervisory guidance to detect and prevent money laundering and terrorist financing, including obligations to collect and maintain information about our users, recordkeeping, reporting, and due diligence and supervision of our counterparties similar to, and in some cases exceeding, those required under the BSA. We may also be impacted by AML laws, regulations, and supervisory guidance in the other countries in which our disbursement partners and disbursement sub-partners operate.

As a money services business, we maintain a robust AML compliance program that includes internal policies and controls, designation of AML compliance officers for each of our regulated entities, ongoing employee training and monitoring programs, and annual independent reviews.

Sanctions

Our business must also comply with U.S. economic and trade sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and with similar sanctions administered by sanctions authorities in other jurisdictions in which we operate or where we are licensed. These laws, regulations, and supervisory guidance prohibit or restrict transactions in, to, or from certain countries, regions, or governments, as well as with certain individuals and entities such as traffickers in illegal goods or services, terrorists, and terrorist organizations.

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Sanctions are imposed to address acute foreign policy and national security threats and may change rapidly and unpredictably in response to world events, or domestic or international political developments.

We have implemented policies, procedures, and internal controls that are designed to comply with these economic and trade sanctions programs. These measures include, without limitation, controls designed to prevent transactions to or from countries or territories that are subject to comprehensive sanctions, screening certain transactions and customer information against OFAC and other international government watchlists, blocking funds of persons named on OFAC’s list of Specially Designated Nationals and Blocked Persons and other persons and entities designated as prohibited persons by U.S. and non-U.S. sanctions authorities, and preparing and submitting blocking and other reports as required by relevant authorities.

Anti-Bribery

We are subject to regulations imposed by the Foreign Corrupt Practices Act (the “FCPA”) in the United States, the Corruption of Foreign Public Officials Act in Canada (the “CFPOA”), the U.K. Bribery Act in the United Kingdom, and similar laws in the other jurisdictions in which we or our disbursement partners or disbursement sub-partners operate, which generally prohibit companies and those acting on their behalf from making improper payments to foreign government officials for the purpose of influencing official action or otherwise gaining an unfair business advantage, such as obtaining or retaining business. We maintain a compliance program designed to comply with applicable anti-bribery laws, regulations, and supervisory guidance.

Money Transmission and Stored Value Licensing or Registration

We are subject to licensing and registration requirements in relation to our money transmission and stored value issuance activities on a state-by-state and federal basis in the United States and in almost every other jurisdiction from which our customers initiate transactions, including, but not limited to, Canada, the United Kingdom, and the EEA.

In the United States, we are registered as a Money Services Business with FinCEN, and we hold licenses to operate as a money transmitter (or its equivalent) in the 49 states where such licenses are required, as well as in the District of Columbia and various U.S. Territories. As a licensed money transmitter, we are subject to, among other requirements, restrictions with respect to the investment of customer funds, reporting requirements, bonding requirements, minimum net worth requirements, customer disclosure requirements, regulatory approval of directors and senior management of the licensed entity, AML and sanctions compliance, third-party risk management requirements, privacy and cybersecurity program requirements, requirements related to unclaimed property and escheatment, and examination by state regulatory agencies. In connection with certain licenses we hold in the United States, there are also different equity holding thresholds that may require a stockholder to obtain regulatory approval prior to exceeding such thresholds.

Outside the United States, we provide services to our customers in a variety of ways. In several jurisdictions, we have obtained licenses or are registered to operate as a money services business, payment service provider, or payment institution, as applicable. In Canada, we are registered with the Financial Transactions and Reports Analysis Centre of Canada as a money services business and are pending registration with the Bank of Canada as a payment service provider. In the United Kingdom, we hold a payment institution license from the Financial Conduct Authority (the “FCA”) and are pending licensure to operate as an electronic money institution, allowing for provision of wallet services. In Ireland, we hold a payment institution license from the Central Bank of Ireland, which permits us to provide certain payment services across the EEA. We are pending approval of an extension of our payment institution license, which would allow for provision of wallet services. We also hold licenses in several other jurisdictions and plan to apply for money transmitter or payment service licenses or their equivalents in additional jurisdictions. Under these licensing regimes and associated regulations and supervision, we are subject to requirements such as capital and safeguarding rules, consumer protection requirements, privacy and cybersecurity requirements (including those under the EU Digital Operational Resilience Act), outsourcing oversight requirements, requirements related to unclaimed property and escheatment, and periodic regulatory examinations. Additionally, in several foreign jurisdictions, we work with disbursement partners to make funds available to recipients, and such partners may be locally licensed businesses or regulated banks subject to compliance requirements with local laws.

Consumer Disclosure and Consumer Protection

We are subject to laws, regulations, and disclosure requirements relating to consumer protection in the United States and other jurisdictions in which we have operations, where such laws, regulations, and supervisory guidance are enforced by numerous government agencies. In the United States, the Consumer Financial Protection Bureau (the “CFPB”) implements, examines compliance with, and enforces federal consumer financial laws governing financial products and services, including the Electronic Fund Transfer Act and its implementing regulation, Regulation E, which includes the Remittance Transfer Rule. The Remittance Transfer Rule requirements include: (1) a disclosure requirement to provide consumers sending funds internationally from the United States with pre-transaction written disclosures and receipts; (2) an obligation to investigate and resolve certain errors, including errors that may be outside our control; and (3) an obligation, upon a customer’s request, and within the statutory time frames, to cancel certain transactions that have not been completed. In the past, the CFPB has issued guidance regarding consumer fees and disclosures. While this is not currently an area of focus for the CFPB, future administrations may examine, and select states are expected to continue examining, companies subject to their jurisdiction for transparency of fees, delivery speed, and exchange rates.

In addition, under the Dodd-Frank Act, it is unlawful for any provider of consumer financial products or services to engage in unfair, deceptive, or abusive acts or practice (“UDAAP violations”). The CFPB has rule-making and enforcement authority to prevent UDAAP violations in connection with any transaction involving a consumer financial product or service. As a larger participant in the industry for international money transfers, we are subject to direct CFPB supervisory authority over our business. This includes the authority to fine and provide consumer restitution for violations

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and request information and data about our compliance activities. In addition, the CFPB requires that we track and respond to consumer complaints. Select states may further focus on this issue in the absence of oversight by the CFPB.

Similar laws, regulations, and supervisory guidance in the countries where we operate and those where we are licensed apply to our business outside the United States. These include laws, regulations, and supervisory guidance to provide disclosures, an obligation to investigate and resolve certain errors and complaints, and obligations to cancel certain transactions. In addition, there has been an increase in the level and regulatory scrutiny of consumer protection laws, regulations, and supervisory guidance relating to “treating customers fairly.” These laws apply to our international business (including in the United Kingdom and the EEA). In the United Kingdom, the FCA has issued, supervises, and enforces the Consumer Duty that places an obligation on firms to act to deliver good outcomes for retail customers. Similarly, in Ireland, the Central Bank of Ireland has issued a comprehensive revised Consumer Protection Code that sets governance, conduct, and consumer protection requirements with a focus on securing customers’ interests.

Indirect Regulatory Requirements

In addition to the licenses discussed above, we also seek, obtain, and maintain additional licenses to support new products and use cases, and we also are subject to indirect regulatory requirements based on the requirements of our product partners and sponsoring financial institutions. At the current time, none of the businesses supported by these indirect or new licenses is material to our business.

For an additional discussion on governmental regulations affecting our business, please see “