1. Our commitment
[Paysasa legal entity name] Limited is committed to preventing money laundering, terrorist financing and proliferation financing. We comply with the Proceeds of Crime and Anti-Money Laundering Act, 2009 (POCAMLA) and its regulations, the Prevention of Terrorism Act, 2012, the National Payment System Act, 2011 and CBK guidance, and we report to the Financial Reporting Centre (FRC). [Compliance to confirm reporting-institution status.]
2. Governance
Our board approves this policy. A Money Laundering Reporting Officer (MLRO), [Name], is responsible for the programme, staff training, independent audit and regulator liaison. We review the policy at least once a year.
3. Customer due diligence
We verify every customer before they transact beyond basic limits.
| Level | What we collect | Typical access |
|---|---|---|
| Basic | Name, phone number, OTP verification | Low-value wallet use [limits] |
| Verified | National ID or passport, selfie liveness check, date of birth | Standard limits, payouts and checkout [limits] |
| Business | Registration certificate, KRA PIN, directors and beneficial owners, proof of address, business description | Merchant features, bulk payouts, Gold and Platinum [limits] |
4. Enhanced due diligence
We apply extra checks to higher-risk customers, including politically exposed persons (PEPs), high-risk countries, high-value or unusual activity and complex ownership. This can include source-of-funds and source-of-wealth evidence and senior approval.
5. Transaction monitoring
We monitor transactions with rules and risk scoring for patterns such as structuring, rapid in-and-out movement, unusual escrow use or mismatches with the customer’s profile. We may hold, delay or decline transactions that look suspicious.
6. Sanctions and watchlist screening
We screen customers and counterparties against UN, other applicable sanctions and domestic lists at onboarding and on an ongoing basis.
7. Reporting and tipping-off
We file suspicious transaction reports with the FRC where required. The law prohibits us from telling a customer that a report has been made, so we may be unable to explain why a transaction was held.
8. Record keeping
We keep identification and transaction records for at least [seven] years after the relationship ends, as POCAMLA requires.
9. Your rights and data
Verification data is processed under the Data Protection Act, 2019 only for compliance and security purposes. See the Privacy Policy.
10. Contact
Compliance questions: [email protected]. To report suspicious activity, email [email protected].