This document delineates the terms and conditions governing your Spring Development Bank (SDB) Account and associated services. These terms and conditions, along with any other applicable terms, constitute a binding legal agreement (“the Agreement” or “the Terms”) between you as the Account Holder, and SDB, the Bank.
For the purposes of these Terms and Conditions, the following definitions shall apply:
Our primary method of delivering services is through the SDB mobile app, although we also extend our services through various web interfaces. These Terms govern your access to our services regardless of the platform or method used, applicable across all possible service access points as described within these terms.
Your account with SDB is categorised as a ‘virtual’ account designed to store digital money in multiple currencies. Digital money serves as an electronic alternative to traditional cash. Upon receipt of funds in any currency, we will credit your account with an equivalent amount of digital money in that same currency, which can then be utilised for transactions and is accepted as payment by others.
Utilising Your Account Once your account is credited with digital money, you are enabled to use it for various services, including:
You must be at least 18 years of age to open an SDB account. We will collect personal and financial information to verify your identity and the source of your funds in compliance with legal and regulatory obligations. Our Privacy Policy, accessible via the SDB app and website, further explains our use of your information.
It is imperative to maintain the accuracy of the information you provide to us and notify us immediately of any changes. Should any discrepancies be discovered, we will update your information accordingly. We may occasionally request additional information to comply with legal and regulatory requirements, which should be provided promptly to avoid any disruptions.
You can monitor all transactions through the SDB app. This information will remain accessible as long as you are a Account Holder . Should you require historical data post-account closure, it must be downloaded while the account remains active.
SDB reserves the right to correct any erroneous transactions due to system errors, user input mistakes, or other discrepancies. The Bank will make reasonable efforts to notify affected Account Holder through official communication channels. Corrective actions may include reversing incorrect debits or credits and reallocating funds to the correct account.
Spring Development Bank (SDB) reserves the right to correct any erroneous transactions that may occur due to system errors, user input mistakes, or any other transactional discrepancies. The Bank may, without prior consent, adjust affected accounts to rectify such errors in compliance with applicable banking regulations.
In cases where an erroneous transaction is identified and rectified, the Bank will make reasonable efforts to notify affected Account Holder through official communication channels, including email, SMS, or any other means deemed appropriate. Such notifications will include details of the error, corrective actions taken, and relevant timelines for adjustments.
Upon identification of an error, SDB may take the following corrective actions:
Account Holder are responsible for regularly reviewing their account statements and promptly reporting any discrepancies to the Bank. Failure to report transaction errors within a reasonable period may limit the Bank’s ability to investigate and rectify the issue.
All rectifications will be conducted in accordance with applicable laws and regulations, including but not limited to:a. Principles of Good Faith and Fair Dealing to ensure fairness in all adjustments;b. Basel Core Principles for banking integrity and risk management;c. Anti-Money Laundering (AML) regulations to prevent financial system abuse.
If an Account Holder disputes an adjustment, they may contact the Bank’s Account Holder service or escalate the matter to the Compliance Team. Disputes will be handled in accordance with SDB’s internal procedures.
SDB reserves the right to review and amend this policy as necessary to align with evolving legal and regulatory requirements. Any changes will be communicated to Account Holder in a timely manner.
We will typically communicate with you via email, online Account Holder service chat, the Telegram user community, and RMs. These methods will be employed for sending account updates, fraud alerts, and security notifications. It is vital to regularly engage with the SDB app to receive this information promptly.
You may terminate this agreement and close your account at any time through the SDB app or by contacting us at [email protected]. Upon closure, any outstanding charges must be settled. A 30-day period for fund withdrawal will be provided post-closure, during which standard transaction limits will remain in effect. Should you require conversion of funds into a different currency, it will be performed at the prevailing rate plus applicable fees.
SDB reserves the right to freeze, restrict, or suspend an Account Holder’s account without prior notice if there is reasonable suspicion of illegal activities, including but not limited to fraud, money laundering, terrorist financing, unauthorised transactions, or any other financial crime.
The Bank may initiate such action based on internal risk assessments, regulatory directives, or reports from relevant authorities. Account freezing shall remain in effect until a thorough investigation is completed, and SDB shall not be liable for any losses or inconveniences resulting from such measures. If the investigation confirms fraudulent or unlawful activity, SDB reserves the right to close the account and take further action, including reporting to relevant authorities and recovering any associated funds.
Upon receipt of funds, the equivalent value in digital money is credited to your account immediately and safeguarded until utilised.
We employ robust measures to secure your funds and request that you maintain the security of your account credentials. Immediate contact should be made via the SDB app if you suspect any unauthorised use of your account or security details. Account freezing and unfreezing can be managed through the app or by contacting Customer Service.
The account must not be utilised for illegal purposes or in any manner that could impede the functionality of our services. Respectful interaction with our staff is required at all times.
Should your account incur a negative balance, you are required to correct it immediately. Failure to address a negative balance may lead to recovery actions including legal proceedings or debt collection.
If you are dissatisfied with our services, please raise your concerns through the SDB app. We are committed to addressing complaints efficiently.
6.A.1. Compliance with Applicable Laws
Spring Development Bank (“the Bank” or “SDB”) is committed to protecting the privacy and security of personal data in accordance with international data protection principles, including but not limited to the OECD Privacy Guidelines, the United Nations Guidelines for the Regulation of Computerised Personal Data Files, and other globally recognised data protection frameworks.
SDB operates under the regulatory framework set out by the Interim Central Bank of Myanmar, the Ministry of Planning, Finance and Investments, and the National Unity Government of Myanmar.
16.A.2. Collection and Processing of Personal Data
SDB collects, processes and stores personal data at its sole discretion for the purposes of:
(a) Providing banking services, including account management, transactions and Account Holder support;
(b) Complying with legal and regulatory obligations, including anti-money laundering (AML) and fraud prevention;
(c) Enhancing security and preventing unauthorised access to accounts;
(d) Conducting market research, improving services and offering tailored financial products; and
(e) Any other purpose that SDB deems necessary for its legitimate business interests. By using SDB’s services, Account Holder explicitly consent to the collection and processing of their personal data as outlined above.
16.A.3. Confidentiality and Security Measures
While SDB implements reasonable security measures, the Bank does not guarantee absolute protection against unauthorised access, data breaches or cyberattacks. SDB shall not be held liable for any loss, damage or disclosure resulting from such incidents, except where required by law.
16.A.4. Data Sharing and Third Parties
SDB does not sell, rent or share personal data with third parties for marketing purposes. However, the Bank reserves the right to disclose Account Holder data when necessary for:
(a) Regulatory compliance, including requests from government authorities and financial regulators;
(b) Fraud prevention, credit risk assessment or debt recovery services;
(c) Legal proceedings, including enforcement of the Bank’s rights; and
(d) Banking operations, such as processing transactions through third-party service providers, subject to appropriate confidentiality safeguards. Account Holder acknowledges that SDB shall not be liable for disclosures made in accordance with the above conditions.
16.A.5. Communication of New SDB Products and Services
SDB may use Account Holders’ contact details for any essential service-related communications. Additionally, SDB may contact Account Holder to provide information on new banking products, services and promotional offers.
16.A.6. International Data Transfers
SDB may transfer Account Holder data across jurisdictions as required for operational efficiency. The Bank shall ensure that appropriate safeguards, such as contractual clauses or recognised data transfer mechanisms, are in place. Account Holder acknowledges that SDB shall not be liable for any differing data protection standards in foreign jurisdictions.
16.A.7. Bank’s Limitation of Liability
(a) No Absolute Security Guarantee: While SDB takes reasonable steps to protect Account Holder data, it does not guarantee absolute security.
(b) Third-Party Breaches: The Bank shall not be responsible for data breaches resulting from third-party actions beyond its control.
(c) Account Holder Responsibility: Account Holder are responsible for safeguarding their login credentials, personal data and financial information. The Bank shall not be liable for unauthorised access due to Account Holder’s negligence.
16.A.8. Account Holder Rights
Subject to applicable laws, Account Holder may:
(a) Request access to, correction or deletion of their personal data;
(b) Object to certain processing activities; and
(c) Withdraw consent where processing is based on consent. All requests shall be reviewed at SDB’s discretion and processed within a reasonable timeframe. SDB reserves the right to deny requests where not such requests are not required legally.
16.B.1. Obligation of Confidentiality
SDB shall maintain confidentiality of all Account Holder information and shall only disclose such information where:
(a) Required by law, regulatory authority or court order;
(b) Necessary to protect the Bank’s interests, including fraud prevention and risk management;
(c) Authorised by the Account Holder in writing; or
(d) In accordance with the terms set out in Clause 15.A.4.
16.B.2. Employee and Third-Party Confidentiality Obligations
SDB ensures that employees, contractors and third-party service providers are subject to strict confidentiality obligations. However, SDB shall not be liable for unauthorised disclosures made by third parties beyond its reasonable control.
16.B.3. Retention of Confidential Information
SDB shall retain Account Holder’s data and confidential information for as long as necessary to fulfil the purposes outlined in these Terms and Conditions, comply with legal obligations or protect the Bank’s interests. Upon expiration of the retention period, the Bank may securely delete, anonymise or archive such data at its discretion.
SDB reserves the right to update this Data Protection and Confidentiality Clause at any time without prior notice. Any changes shall be published on Bank’s website or official communication channels, and continued use of SDB’s services constitutes acceptance of the revised terms.
All intellectual property related to SDB services and products is owned by us and is protected under applicable laws. Unauthorised use of our intellectual property is strictly prohibited.
The Agreement is personal to you and non-transferable. We reserve the right to novate or assign rights and obligations under the agreement as necessary to comply with legal or regulatory requirements. Enforcement Failure to enforce any provisions of this Agreement does not waive our right to enforce them later.
Failure to enforce any provisions of this agreement does not waive our right to enforce them at a later time.
SDB shall not be liable for any indirect, incidental, special, or consequential damages, including but not limited to:
SDB shall not be held responsible for any loss, damage, or unavailability of services resulting from:
In all circumstances, the Bank’s total liability to any Account Holder for direct losses shall not exceed the total fees paid by the Account Holder over the preceding 12 months.
While SDB employs reasonable efforts to maintain service availability and security, the Bank does not guarantee that services will be uninterrupted, secure, or free from errors. The Account Holder acknowledges that banking services may be subject to technical disruptions beyond SDB’s control.
The Account Holder acknowledges that:
The Account Holder agrees to indemnify and absolve the Bank, its directors, employees, agents, and affiliates from any claims, liabilities, losses, damages, costs, or expenses (including legal fees) arising from:
If a third party makes a claim against SDB due to the actions, omissions, or negligence of the Account Holder, the Account Holder shall be solely responsible for resolving such claims at their own cost. The Bank reserves the right to recover any losses or expenses incurred due to such claims.
SDB reserves the right to deduct amounts owed under this Indemnification Clause from the Account Holder’s account without prior notice, to the extent permitted by applicable law.
SDB reserves the right to update, modify, or amend this Limitation of Liability and Indemnification Clause at any time, without prior notice, in accordance with regulatory requirements and operational needs.
The Bank reserves the right to:
Account Holder may be required to provide valid identification and documentation as part of the Know Your Account Holder (KYC) process. The Bank reserves the right to request updated documentation periodically. The Bank may refuse transactions or account openings if:
24.1.1 If an account remains inactive for a continuous period of 12 months, it shall be classified as a dormant account. Inactivity is determined by the absence of Account Holder-initiated transactions, including deposits, withdrawals, or other account activity.
24.1.2 The Bank shall make reasonable efforts to notify the Account Holder before classifying an account as dormant. However, failure to receive such notification shall not affect the Bank’s rights under this policy.
24.2.1. Once an account is classified as dormant:
Transactional capabilities may be restricted or suspended until reactivation;
The Account Holder may be required to provide additional verification or formally request reactivation in accordance with the Bank’s procedures.
24.2.2 The Bank reserves the right to apply administrative fees for the maintenance of dormant accounts, as specified in the Bank’s Schedule of Fees and Charges.
24.3.1. If an account remains dormant for a period of five (5) consecutive years, the Bank may, at its sole discretion:
Transfer the balance to a designated holding account for safekeeping;
Report and remit unclaimed funds in accordance with applicable laws, including regulations set by the Interim Central Bank of Myanmar, the Ministry of Planning, Finance and Investments, and the National Unity Government of Myanmar.
24.3.2. Where funds are transferred to a designated holding account or remitted as unclaimed funds, the Account Holder may be required to submit a formal request and provide satisfactory proof of ownership to reclaim the balance.
24.4.1. A dormant account may be reactivated upon submission of a formal request by the Account Holder, along with any required identification or documentation as determined by the Bank.
24.4.2. The Bank reserves the right to refuse reactivation if the account has been closed or if funds have been remitted as unclaimed in compliance with legal or regulatory requirements.
The Bank reserves the right to amend this Dormant Account Policy at any time, in line with regulatory changes or operational requirements. Any such amendments shall be communicated through the Bank’s official channels.
The Bank may introduce, modify, or remove fees and charges applicable to transactions, account maintenance, or other banking services. Account Holder will be notified of any changes in advance via website updates, or in-app notifications.
The Bank reserves the right to suspend or terminate services to an Account Holder under the following conditions:
Any dispute arising under these Terms and Conditions shall first be addressed through the Bank’s internal dispute resolution mechanism.
If the dispute remains unresolved, it shall be referred to arbitration under the rules of Interim Central Bank of Myanmar. The arbitration process shall be binding, and decisions rendered shall be enforceable in a court of law.
Spring Development Bank (SDB) operates under the authority of the Interim Central Bank, which adheres to the laws established by the Ministry of Planning, Finance and Investments, National Unity Government (NUG) of Myanmar.
These Terms and Conditions shall be governed by and construed in accordance with the financial regulations enforced by the Interim Central Bank of Myanmar. Any disputes arising under this Agreement shall be subject to the exclusive jurisdiction of the relevant regulatory authorities and arbitration mechanisms recognised under the NUG legal framework.
By continuing to use SDB services, you agree to these Terms and Conditions, which constitute our entire agreement regarding your use of the account and associated services.
Last updated: 17 February 2025
Spring Development Bank (“SDB”, “we”, “our” or the “Bank”) is committed to protecting its customers, users, staff, Relationship Managers, agents and systems from money laundering, terrorist financing, sanctions evasion, fraud and other unlawful activity.
This Policy explains the standards SDB applies when providing its services, including account services, transfers, foreign exchange, remittance, digital asset-related services and other supported products made available through SDB’s approved channels.
The purpose of this Policy is to explain, in customer-facing form, how SDB applies anti-money laundering, counter-terrorist financing, sanctions, fraud-prevention and related compliance controls when onboarding customers, maintaining customer relationships and processing transactions.
This Policy should be read together with SDB’s Terms and Conditions, Privacy Policy and any other applicable product terms or compliance notices issued by SDB.
AML/CFT means anti-money laundering and counter-terrorist financing controls.
Beneficial owner means the natural person who ultimately owns, controls or benefits from
an account, relationship, company, organisation, trust or transaction.
Digital asset means a digital representation of value or rights, including crypto-assets or stablecoins, where supported by SDB.
Politically exposed person means a person who holds, or has held, a prominent public function, together with any related person where relevant to SDB’s risk assessment.
Sanctions means financial, trade or related restrictions applied by competent authorities and through SDB’s screening and compliance controls.
Source of funds means the origin of the money or assets used in a transaction.
Source of wealth means the origin of a customer’s overall wealth or economic means.
USDT means Tether or any supported equivalent designated by SDB for the relevant
service.
This Policy applies to all SDB customers, account holders, users, authorised representatives, counterparties and persons using or seeking to use SDB products or
services.
It applies across supported channels and services, including account opening and
onboarding, fiat and digital asset-related transactions, deposits, withdrawals, transfers, remittances, currency exchange, RM-assisted transactions and any other activity that SDB reasonably considers relevant to AML/CFT, sanctions, fraud-prevention or customer protection.
Certain withdrawal services, including digital asset and USDT cash-out services, may be subject to separate service terms, fees, caps, service windows and verification requirements notified by SDB.
Before opening or maintaining an account, processing a transaction or providing a service, SDB may require information and documents to verify identity and assess risk.
This may include:
SDB may also carry out ongoing due diligence and may ask for updated documents or explanations during the customer relationship.
Where an account, transaction or relationship involves a company, organisation, trust, nominee, authorised representative, attorney, guarantor, introducer or other third party, SDB may require information to identify the ultimate beneficial owner and the person with effective control.
SDB may refuse to establish, continue or process a relationship or transaction where beneficial ownership, authority or the intended purpose of the relationship cannot be established to SDB’s standard requirements.
SDB applies a risk-based approach to AML/CFT compliance. This means that the level of due diligence, monitoring, review and control applied to a customer or transaction may vary according to the risk presented.
Relevant factors may include the type of customer or counterparty, the nature of the product or service used, transaction size, frequency, speed and pattern, links to higher-risk jurisdictions or sanctions exposure, digital asset or wallet-related risk, unusual or inconsistent transaction activity, use of remote channels, and whether the transaction involves a politically exposed person, a high-risk business or another heightened-risk feature.
SDB may apply enhanced due diligence where a customer, account, wallet, counterparty, product or transaction presents a higher level of risk.
Enhanced due diligence may include obtaining additional identity or business documents, requesting information on source of funds or source of wealth, requiring further explanation of the purpose of a transaction, carrying out additional checks on beneficial owners or related parties, requiring re-verification of wallet addresses or beneficiary details, increasing monitoring of the account or transaction pattern, and requiring additional approval or review before a transaction is processed.
SDB may screen customers, beneficial owners, wallet addresses, beneficiaries and
transactions against sanctions lists, internal controls, adverse-information sources, fraud indicators and other risk tools.
For digital asset-related services or withdrawals, SDB may apply additional controls,
including wallet verification, proof of wallet ownership or control where appropriate, sanctions and blockchain analytics screening, transfer-information checks where necessary, review of higher-risk wallet exposure, review of unusual transaction patterns, and additional restrictions or review for higher-risk digital asset activity.
SDB monitors customer relationships and transactions on an ongoing basis. Monitoring may be automated, manual or both.
SDB may review transaction history and account behaviour, consistency with a customer’s known profile or expected activity, rapid movement of funds, linked or split transactions, repeated withdrawals or transfers, unusual currency conversion activity, patterns involving deposits followed by withdrawal requests, changes in wallet, device, contact or security details, and any other activity that may indicate money laundering, terrorist financing, sanctions evasion, fraud, abuse or unauthorised use.
SDB may at any time require further information or documents, delay or refuse a transaction, place a transaction or account on hold, restrict access to a service, reverse or cancel a transaction where permitted, or close an account or end a relationship where SDB considers it necessary to do so for compliance, fraud-prevention, security, operational or risk-management reasons.
SDB may take such action where, for example, required information is missing or cannot be verified, beneficial ownership cannot be established, sanctions or screening concerns arise, suspicious or inconsistent transaction patterns are detected, source of funds or transaction purpose cannot be satisfactorily explained, or SDB considers the action necessary to protect customers, SDB or the wider financial system.
Certain withdrawal products may also be subject to product-specific caps, fees and service conditions notified separately by SDB.
Where SDB knows, suspects or has reasonable grounds to suspect that funds, transactions, customers or counterparties may be linked to criminal conduct, money laundering, terrorist financing, sanctions evasion or other unlawful activity, SDB may investigate, restrict the relevant activity and report the matter to the appropriate authority where required.
SDB will not normally tell a customer if a suspicious activity review or report is being considered or has been made, except where disclosure is permitted or required.
Customers and users of SDB services must provide complete, accurate and up-to-date information, co-operate promptly with requests for documents or clarification, use only lawful funds and lawful wallet addresses, avoid using SDB services for illegal, deceptive or abusive purposes, notify SDB promptly of changes to identity, ownership, authority or transaction details, and comply with SDB’s Terms and Conditions and other applicable policies.
Failure to do so may result in delay, refusal, restriction, suspension, closure or reporting.
SDB may retain customer, transaction and compliance records for so long as is necessary for compliance, audit, investigation, dispute handling and legitimate business and risk-management purposes.
SDB will handle customer information in accordance with applicable requirements and its privacy and confidentiality commitments.
SDB may use, verify, store, analyse and share customer information where necessary for identity verification, customer support and service delivery, fraud prevention, sanctions screening, AML/CFT compliance, reporting, dispute handling, audit and internal governance, and protection of the Bank’s rights and interests.
SDB may review and update this Policy from time to time to reflect changes in its services, systems, risk environment or internal requirements. Any updated version may be published through SDB’s official channels.
Questions relating to this Policy, account verification, transaction restrictions or compliance-related requests may be directed to SDB through its official customer support or compliance contact channels published on SDB’s website or app or email at [email protected].
