Legal Document
AML & KYC Policy
Having regard for user safety, legal requirements in the Republic of Uganda and other countries, and recommendations from FATF, SendiCash has implemented a Know Your Customer (KYC) and Anti-Money Laundering / Counter Terrorist Financing (AML / CTF) program similar to those used by regulated financial institutions.
The purpose of these policies is to effectively combat money laundering and terrorist financing on our platform by properly identifying users, supervising their transactions, and preventing activity that hides the criminal origin of money or finances illegal activity. Specific provisions of the policy are confidential and for internal use only in order to prevent circumvention by dishonest actors; the sections below summarise how the policy affects you as a user.
Last updated: TBD
1. User Identification
We are obliged to identify, beyond a reasonable doubt, the identity of persons who transact on our platform. We collect ID scans whose authenticity is verified with specialist software from professional external providers. We also request a selfie or recorded video with your ID document to prevent misuse of your documents by someone else. Likeness verification is performed via automated tools or, if necessary, manually by our customer support team. If we cannot determine that the documents belong to you and are authentic, we cannot allow transactions to proceed.
2. Company Identification
For legal entities the procedure is more stringent and depends on the company’s structure, jurisdiction, and business activities. We identify owners, authorised representatives, the location of the company, and the nature of its business. Because documentation standards vary globally, verification for such users is manual and may take longer.
3. Transaction Monitoring and Supervision
We analyse transactions through our exchange audit platform to detect suspicious or unusual behaviour. Flagged transactions are reviewed by AML specialists to evaluate risk and, where necessary, paused for clarification with the user.
4. Additional Verification
As your trade volume increases, or if your activity is flagged as suspicious or higher risk, we may require additional documentation such as proof of residence, education, occupation, and source of funds. If the information provided does not clarify our concerns we may terminate the business relationship and, where required, report the activity to relevant authorities.
5. Basic AML / CTF Rules
- No cash deposits are accepted unless supported by verified documentation.
- Deposits from third parties, joint or shared accounts, or accounts managed on behalf of someone else are not permitted.
- We do not allow exceptions for documentation required from users.
- We may refuse to process a transaction at any time if we suspect AML / CTF risk and may be legally prohibited from notifying you if we report suspicious behaviour to authorities such as the Financial Intelligence Authority.
6. Sanctioned Countries
We do not open accounts or process transactions for citizens, residents, or individuals in countries subject to international sanctions, prohibitions, or jurisdictions classified as high risk by our AML team. Currently we do not provide services to residents of the USA, Afghanistan, Cambodia, DPRK, Iran, Iraq, or Syria.
7. Risk Assessment
We apply a risk-based approach, identifying, assessing, understanding, and mitigating AML / CTF risks across customer profiles, products, geographies, and channels. Higher risk scenarios trigger enhanced due diligence.
8. Tiers of KYC Verification
We operate a tiered verification system based on the principle that larger deposits or withdrawals require more information about users and their funds to mitigate AML / CTF risks. The model is subject to change based on regulatory updates, audits, and operational learnings; any changes affecting you will be communicated accordingly.