Newrails Group Risk Appetite Statement
Our approach to responsible financial innovation
At Newrails, responsible innovation, financial integrity and effective risk management are central to how we operate.
We recognise that providing payment services, electronic money and digital asset solutions involves financial, regulatory, operational and financial crime risks. Our approach is to identify, assess, manage and monitor these risks in a proportionate and consistent manner, while supporting legitimate businesses and the development of innovative financial infrastructure.
Our risk appetite
Newrails maintains a moderate appetite for controlled commercial growth and innovation, supported by appropriate governance, risk assessment and operational safeguards.
We maintain a low appetite for unmanaged financial crime, regulatory, operational, liquidity, safeguarding, counterparty and reputational risks.
We have no appetite for knowingly facilitating unlawful activities, money laundering, terrorist financing, sanctions evasion, fraud, misuse of customer funds or activities outside applicable regulatory permissions.
We recognise that certain legitimate businesses and financial activities may present elevated inherent risks. These are assessed on a risk sensitive basis and may be accepted where permitted by applicable law and internal policies, subject to appropriate due diligence, controls and approval.
Our core principles
- Regulatory compliance: We conduct our activities within the applicable legal and regulatory frameworks of the jurisdictions in which our operating entities provide services.
- Financial crime prevention: We maintain risk based measures designed to prevent and detect money laundering, terrorist financing, sanctions evasion, fraud and other financial crime.
- Customer due diligence: We assess customers and business relationships using appropriate identification, verification, screening and ongoing monitoring measures. Enhanced due diligence is applied where required by the risks identified.
- Protection of customer funds and assets: We maintain arrangements designed to protect customer funds and assets in accordance with the applicable legal requirements and the nature of the services provided.
- Operational resilience and security: We seek to maintain secure and resilient services through technology controls, cybersecurity measures, incident management and oversight of relevant third party service providers.
- Responsible digital asset services: We support digital asset innovation within the permitted activities of the relevant service providing entity, supported by proportionate blockchain analytics, transaction monitoring and wallet related controls.
Our operating entities
This Group Risk Appetite Statement covers:
Newrails UAB - Lithuania
A Lithuanian electronic money institution responsible for its applicable electronic money and payment services, including the issuance of EURW.
Newrails International - Costa Rica
A Costa Rican entity providing virtual asset related services, including approved digital asset exchange and associated custody functionality, within its applicable legal and regulatory perimeter.
Each entity is responsible for compliance with its applicable legal and regulatory obligations and maintains policies and procedures appropriate to its activities and risks.
Governance and oversight
Risk management is embedded within our business activities and governance arrangements.
Our operating entities maintain defined responsibilities for risk ownership, compliance oversight, financial crime prevention, monitoring and escalation.
Our Group wide approach supports consistency in risk management while recognising the distinct legal and regulatory responsibilities of each entity.
Ongoing commitment
Newrails is committed to maintaining a risk aware culture, strengthening its controls and adapting its risk management arrangements as its services, technologies and regulatory environment evolve.
Our objective is to support legitimate financial innovation while maintaining the integrity, security and resilience of the services we provide.
This statement provides a high level overview of the risk appetite principles applicable to Newrails UAB and Newrails International. It does not replace the individual entities' policies, contractual terms or applicable legal and regulatory requirements. Services and availability vary by entity and jurisdiction.