AML / KYC Policy

1. Purpose & legal basis

This policy describes how Block2Pay, operated by Taafpay Limited Company, prevents money laundering and the financing of terrorism. It is written to comply with:

• Anti-Money Laundering Act, 2020 (Act 1044) and the AML Regulations, 2011 (L.I. 1987).
• Anti-Terrorism Act, 2008 (Act 762) as amended.
• Payment Systems and Services Act, 2019 (Act 987).
• Bank of Ghana's AML/CFT Guidelines for Accountable Institutions.
• FATF Recommendations as applicable to payment service providers.

2. Who must KYC

Block2Pay is a seller-side platform. The KYC obligation falls on sellers; buyers are never asked to register or upload documents.

• All sellers must complete Ghana Card identity verification before their first payout is approved. Verification is performed by Prembly against the NIA register.
• Enhanced due diligence (EDD) applies to sellers whose 30-day volume exceeds GHS 50,000, who transact with politically exposed persons (PEPs), or who are flagged by transaction monitoring.
• Buyers are identified by their Mobile Money number (KYC’d by the MNO under the SIM Registration Regulations, 2011 / L.I. 2006). Block2Pay does not collect additional buyer identity documents.

3. Customer due diligence

Seller onboarding captures and verifies:

• Full legal name (matched against Ghana Card via Prembly).
• Ghana Card number (PNR / ECOWAS Card).
• Date of birth and gender (cross-checked).
• Live selfie liveness check, matched to the Ghana Card photo.
• MoMo number (verified via OTP).
• Business description and category (for transaction monitoring).

A seller cannot create payment links or receive payouts until all checks return green. Records are retained for seven (7) years after the account is closed, per Act 1044 §35.

4. Payout thresholds

• Per-transaction limit: GHS 5,000. Anything above triggers an in-band manual review and additional source-of-funds documentation.
• 30-day cumulative limit: GHS 50,000 for tier-1 sellers. Tier-2 (EDD cleared) sellers are reviewed case-by-case.
• Structuring detection: deliberately splitting transactions to stay under thresholds (smurfing) is flagged automatically and reported.

5. Sanctions screening

Every seller is screened at onboarding and re-screened daily against:

• UN Security Council Consolidated Sanctions List.
• OFAC Specially Designated Nationals (SDN) List.
• EU Consolidated Financial Sanctions List.
• Bank of Ghana high-risk and PEP lists.

A positive match freezes the account immediately and triggers a Suspicious Transaction Report (STR) to the Financial Intelligence Centre within 24 hours.

6. Transaction monitoring

We run rules-based and anomaly-detection monitoring on every transaction. Triggers include:

• Velocity spikes inconsistent with the seller's declared business pattern.
• High-value transactions with new counter-parties.
• Repeated small transactions that aggregate above the EDD threshold.
• Buyer phone numbers appearing across multiple unrelated seller accounts.
• Geographic anomalies (e.g., MoMo number registered to a high-risk jurisdiction).

Flagged transactions are paused pending review. Sellers are not told a transaction is under review (the “tipping-off” prohibition under Act 1044 §43 applies).

7. Suspicious Transaction Reports

Our designated AML Reporting Officer files STRs with Ghana's Financial Intelligence Centre (FIC) within the timelines set in Act 1044. STRs are filed where there is knowledge or reasonable suspicion that funds are derived from criminal conduct, are linked to terrorism financing, or are otherwise unusual without an apparent lawful purpose.

8. Record keeping & audit

• All KYC records, transaction histories, and AML decisions are retained for seven (7) years.
• Every state transition in the escrow lifecycle is written to an immutable audit log.
• The insurance pool ledger is reconciled daily and published quarterly in our transparency report.
• Records are made available to the Bank of Ghana and the FIC on request, without notice to the customer.

9. Training & governance

• The AML Reporting Officer reports directly to the founder and the (future) board.
• Annual AML training is mandatory for every team member with access to seller or transaction data.
• This policy is reviewed annually, or sooner if law or risk landscape changes.

10. Buyer privacy notice

Because buyers do not register an account, the AML obligation on them is discharged via their MoMo operator's SIM-registration KYC. Block2Pay stores the buyer phone number for the duration of the escrow and any subsequent dispute window, plus the seven-year regulatory retention. Buyer phone numbers are encrypted at rest.

11. Contact

For AML/KYC questions, regulator enquiries, or to report a concern, contact our AML Reporting Officer at compliance@getblock2pay.com.