Legal

Anti-Money Laundering Policy

Our commitment to preventing money laundering, terrorist financing, and financial crime on the GlobiPay platform.

Last updated: January 1, 2026

Contents

  1. Introduction
  2. Know Your Customer
  3. Transaction Monitoring
  4. Suspicious Activity
  5. Risk Assessment
  6. Record Keeping
  7. Employee Training
  8. Compliance Officer
  9. Penalties
  10. Cooperation
  11. Policy Review
  12. Contact

1. Introduction & Commitment

GlobiPay, operated by Globiz, is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We recognise our responsibility to detect and prevent the use of our Platform for money laundering, terrorist financing, or other financial crimes.

This policy applies to all users, employees, partners, and third parties who interact with the GlobiPay platform. It is designed to comply with:

  • The Proceeds of Crime and Anti-Money Laundering Act (POCAMLA) of Kenya
  • Central Bank of Kenya (CBK) guidelines on AML/CTF
  • Financial Action Task Force (FATF) Recommendations
  • Prevention of Terrorism Act of Kenya
  • Applicable international AML/CTF regulations

2. Know Your Customer (KYC)

GlobiPay implements robust KYC procedures to verify the identity of all users:

a) Customer Identification

  • All users must register with verified Google or Apple accounts
  • Users engaging in transactions above specified thresholds must provide government-issued identification (national ID, passport, or driving licence)
  • Phone number verification via M-Pesa registration
  • Additional verification may be required for high-value or high-risk transactions

b) Customer Due Diligence (CDD)

  • Standard due diligence is applied to all users at onboarding
  • Enhanced due diligence (EDD) is applied to high-risk users, including those transacting large volumes, users from high-risk jurisdictions, and politically exposed persons (PEPs)
  • Simplified due diligence may apply to low-risk, low-value transactions as permitted by regulation

c) Ongoing Monitoring

  • Continuous monitoring of user transactions and behaviour
  • Periodic review and update of customer information
  • Re-verification when user behaviour changes materially or risk indicators are detected

3. Transaction Monitoring

GlobiPay employs automated and manual transaction monitoring to detect suspicious activity:

  • Automated Screening: Real-time monitoring of all transactions for patterns indicative of money laundering, structuring, or fraud
  • Threshold Reporting: Transactions exceeding specified monetary thresholds are flagged for review
  • Behavioural Analysis: Unusual patterns such as rapid fund transfers, frequent high-value transactions, or activity inconsistent with a user's profile are investigated
  • Sanctions Screening: All users and counterparties are screened against international sanctions lists, including UN, EU, OFAC, and Kenya's domestic lists

4. Suspicious Activity Reporting

When suspicious activity is identified, GlobiPay follows these procedures:

  • The compliance team investigates the flagged activity
  • If suspicion is confirmed, a Suspicious Transaction Report (STR) is filed with the Financial Reporting Centre (FRC) of Kenya
  • The affected account may be suspended or restricted pending investigation
  • GlobiPay will not inform the user that an STR has been filed ("tipping off" is prohibited)
  • All STRs and related documentation are maintained for the legally required retention period

5. Risk Assessment

GlobiPay conducts regular risk assessments to identify and mitigate AML/CTF risks:

  • Customer Risk: Users are assigned risk ratings based on verification status, transaction history, geographic location, and other factors
  • Product Risk: Each service (escrow, events, pools) is assessed for AML vulnerability. Escrow and contribution pools receive heightened scrutiny due to funds-transfer nature
  • Geographic Risk: Transactions involving high-risk jurisdictions identified by FATF are subject to enhanced monitoring
  • Channel Risk: Mobile and digital channels are assessed for risks specific to remote, non-face-to-face transactions

6. Record Keeping

GlobiPay maintains comprehensive records as required by law:

  • Customer identification records: retained for the duration of the relationship plus 7 years
  • Transaction records: retained for a minimum of 7 years from the date of the transaction
  • Suspicious activity reports and investigation files: retained for 7 years from filing
  • KYC/CDD documentation: retained for the duration of the relationship plus 5 years
  • Training records: retained for the duration of employment plus 5 years

7. Employee Training

All GlobiPay employees and relevant contractors receive AML/CTF training:

  • Initial training during onboarding covering AML/CTF laws, red flags, and reporting obligations
  • Annual refresher training incorporating regulatory updates and emerging risks
  • Role-specific training for compliance, customer-facing, and technical staff
  • Documented assessments to verify understanding and competence

8. Compliance Officer

GlobiPay has appointed a designated Money Laundering Reporting Officer (MLRO) responsible for:

  • Overseeing AML/CTF compliance across the organisation
  • Receiving and reviewing internal suspicious activity reports
  • Filing STRs with the Financial Reporting Centre
  • Ensuring policies, procedures, and controls are up to date
  • Liaising with regulatory authorities and law enforcement
  • Reporting to senior management on AML/CTF matters

9. Penalties for Non-Compliance

Users who attempt to use GlobiPay for money laundering or other financial crimes will face:

  • Immediate account suspension and restriction of funds
  • Reporting to law enforcement and the Financial Reporting Centre
  • Permanent ban from the GlobiPay platform
  • Potential criminal prosecution under applicable laws

Employees who fail to comply with AML/CTF procedures are subject to disciplinary action, up to and including termination.

10. Cooperation with Authorities

GlobiPay cooperates fully with:

  • The Financial Reporting Centre (FRC) of Kenya
  • The Central Bank of Kenya (CBK)
  • Kenya Police Service and Directorate of Criminal Investigations (DCI)
  • International law enforcement agencies upon valid legal request
  • Courts and tribunals as required by law

11. Policy Review

This AML Policy is reviewed and updated at least annually, or more frequently in response to:

  • Changes in AML/CTF legislation or regulatory guidance
  • New risks identified through risk assessments
  • Findings from internal or external audits
  • Significant changes in GlobiPay's services or user base

12. Contact

To report suspicious activity or for questions about our AML compliance, contact:

  • Email: globiz2025@gmail.com
  • Subject Line: AML Compliance Enquiry
  • Company: Globiz (GlobiPay)
  • Location: Nairobi, Kenya