Our commitment to preventing money laundering, terrorism financing, and financial crime across the Send2Bank platform.
Send2Bank is committed to full compliance with all applicable anti-money laundering and counter-terrorism financing laws. All users are subject to identity verification, transaction monitoring, and sanctions screening. Accounts engaged in prohibited activities will be immediately suspended and reported to authorities.
Send2Bank maintains a comprehensive Anti-Money Laundering and Counter-Terrorism Financing programme designed to detect, prevent, and report financial crime. We take a zero-tolerance approach to money laundering, terrorism financing, proliferation financing, sanctions evasion, and all forms of financial crime. Our AML programme is built on international best practices and complies fully with the laws of Uganda, Kenya, and other jurisdictions in which we operate.
This policy applies to all Send2Bank services including multi-currency wallets, mobile money transactions, Bitcoin and cryptocurrency services, invoicing, subscription billing, and all payment processing activities. Every user, transaction, and business relationship is subject to the controls described in this policy, regardless of account type, transaction volume, or geographic location.
Our AML programme is overseen by a designated Compliance Officer who reports directly to senior management and has the authority to make independent decisions regarding suspicious activity, account restrictions, and regulatory reporting. The programme is reviewed and updated at least annually to reflect changes in regulations, business operations, and emerging financial crime typologies.
Send2Bank's AML programme is designed to comply with the following regulatory frameworks and international standards. At the national level, we adhere to the Anti-Money Laundering Act of Uganda, the Proceeds of Crime Act, and all directives issued by the Financial Intelligence Authority of Uganda. In Kenya, we comply with the Proceeds of Crime and Anti-Money Laundering Act and regulations issued by the Financial Reporting Centre.
At the international level, our programme aligns with the Financial Action Task Force 40 Recommendations on money laundering and terrorism financing, as well as relevant United Nations Security Council Resolutions concerning sanctions and terrorist financing. We also follow guidance issued by the Eastern and Southern Africa Anti-Money Laundering Group, of which Uganda and Kenya are member states.
Where we operate across borders or serve customers in multiple jurisdictions, we apply the higher standard between applicable local laws and our internal global policy. We monitor regulatory developments continuously and adjust our controls accordingly.
All Send2Bank users must complete identity verification before accessing full platform features including higher transaction limits, multi-currency wallets, cryptocurrency services, and business tools. Our KYC process is designed to establish with reasonable certainty the true identity of every customer.
The KYC process involves the following steps. First, we collect core identifying information including full legal name, date of birth, phone number, and country of residence. Second, we require a government-issued photo identification document — accepted documents include national identity cards, valid passports, and driver's licences. Third, we perform facial biometric verification through our certified KYC partner didit.me, comparing a live selfie against the photo on the submitted identification document to confirm liveness and identity match.
In addition to identity verification, we screen every user against international sanctions lists, watchlists, and Politically Exposed Persons databases before account activation and on an ongoing basis thereafter. Users who fail or refuse to complete KYC requirements are limited to reduced transaction thresholds and may have their accounts suspended if verification cannot be completed within a reasonable timeframe.
Standard Customer Due Diligence is applied to all Send2Bank users at account opening and on an ongoing basis. CDD measures include verifying the customer's identity using reliable, independent source documents and data, understanding the nature and purpose of the customer's intended use of Send2Bank services including expected transaction volumes, currencies, and counterparties, and ongoing monitoring of the business relationship to ensure transactions are consistent with the customer's profile and stated purpose.
For business accounts, we conduct additional due diligence including verifying the legal existence and registration of the business entity, identifying the ultimate beneficial owners holding 25% or more ownership or control, understanding the business's ownership and control structure, and verifying the identity of authorized representatives and directors.
Customer profiles are periodically reviewed and updated. Significant changes in account activity, transaction patterns, or customer circumstances may trigger a CDD refresh. Failure to provide requested information during a CDD review may result in account restrictions.
Enhanced Due Diligence measures are applied to customers and transactions that present a higher risk of money laundering or terrorism financing. Circumstances that trigger EDD include identification of the customer or beneficial owner as a Politically Exposed Person, customers from or transacting with high-risk jurisdictions identified by FATF, unusually large or complex transactions with no apparent economic or lawful purpose, business relationships or transactions involving countries subject to sanctions or embargoes, and customers operating in high-risk industries such as money services businesses, precious metals dealers, or gambling operators.
EDD measures may include obtaining additional identification documents and source-of-wealth information, requiring senior management approval to establish or continue the business relationship, conducting enhanced ongoing monitoring including more frequent transaction reviews, and requiring the first payment to be carried out through an account in the customer's name with a regulated financial institution. EDD decisions are documented with a clear rationale and are subject to independent review.
Send2Bank employs automated transaction monitoring systems that analyze all transactions in real time and on a batch basis to identify potentially suspicious activity. Our monitoring systems evaluate transactions using risk-based rules and behavioral analytics designed to detect patterns indicative of money laundering, terrorism financing, fraud, or sanctions violations.
Specific monitoring scenarios include detection of large or unusual cash deposits that are inconsistent with the customer's stated profile and expected activity, rapid movement of funds through multiple accounts suggesting layering activity, transactions involving jurisdictions associated with higher money laundering risk, structuring or smurfing patterns where transactions are deliberately split to avoid reporting thresholds, unusual cross-border patterns inconsistent with the customer's business model, and transactions with individuals or entities appearing on sanctions or watchlists.
When the monitoring system generates an alert, it is reviewed by trained compliance analysts who determine whether the activity warrants further investigation, escalation to the Compliance Officer, or filing of a Suspicious Transaction Report. All alerts, investigations, and decisions are documented and retained in accordance with our record-keeping obligations.
When we have reasonable grounds to suspect that funds are the proceeds of criminal activity or are related to terrorism financing, we are legally obligated to file a Suspicious Transaction Report with the relevant Financial Intelligence Authority. In Uganda, reports are filed with the Financial Intelligence Authority; in Kenya, with the Financial Reporting Centre.
Suspicious Transaction Reports include detailed information about the transaction, the accounts involved, the nature of the suspicious activity, and the grounds for suspicion. By law, we do not notify customers or any other unauthorized parties when a Suspicious Transaction Report has been filed — doing so would constitute "tipping off" and is itself a criminal offense. We also cooperate fully with law enforcement investigations and may place holds on accounts or freeze funds as directed by competent authorities.
Our Compliance Officer is responsible for ensuring that all Suspicious Transaction Reports are filed promptly, accurately, and in compliance with applicable reporting timelines and formats. We maintain confidentiality around all reporting activities and limit internal knowledge to personnel with a legitimate need to know.
Send2Bank maintains a robust sanctions compliance programme to ensure we do not provide services to individuals, entities, or jurisdictions subject to economic or trade sanctions. We screen all customers, beneficial owners, and counterparties against sanctions lists maintained by the United Nations Security Council, the United States Office of Foreign Assets Control, the European Union Consolidated List, the United Kingdom HM Treasury Sanctions List, and any other sanctions lists applicable to the jurisdictions in which we operate.
Screening is performed at account opening, at the time of each transaction where counterparties are involved, and through ongoing batch screening of our entire customer base against updated sanctions lists. Any match against a sanctions list triggers immediate investigation and escalation. Confirmed matches result in account freezing, rejection of the transaction, and reporting to the relevant sanctions enforcement authority.
We also monitor transactions for involvement of comprehensively sanctioned jurisdictions and territories. Send2Bank does not operate in or facilitate transactions involving North Korea, Iran, Syria, Cuba, or the Crimea region of Ukraine, in compliance with applicable sanctions regimes.
Send2Bank maintains comprehensive records of all customer identification documents, transaction data, account files, business correspondence, AML investigations, and Suspicious Transaction Reports. All records are retained for a minimum of seven years from the date of the relevant transaction or the end of the customer relationship, whichever is later, in compliance with applicable financial record-keeping regulations.
Records are stored securely with access limited to authorized compliance and legal personnel. Our record-keeping systems ensure that records are readily retrievable and can be produced promptly upon lawful request from regulatory authorities, law enforcement agencies, or courts. Records include both the original documentation and any updates or amendments made during the customer relationship.
All Send2Bank employees, contractors, and agents who have access to customer data, transaction systems, or are involved in customer-facing roles receive mandatory AML and CTF training. Training is conducted at the time of onboarding and on an annual refresher basis thereafter. The training programme is designed to ensure that all relevant personnel understand their AML obligations, can recognize red-flag indicators of money laundering and terrorism financing, know the procedures for escalating suspicious activity to the Compliance Officer, and are aware of the legal prohibition against tipping off.
Training content is updated regularly to reflect changes in regulations, emerging typologies, and lessons learned from internal investigations. Specialized training is provided to compliance staff, senior management, and personnel in higher-risk roles. Training completion is tracked and documented, and non-completion is escalated to management for remediation.
The following activities are strictly prohibited on the Send2Bank platform and will result in immediate account suspension, freezing of funds, and reporting to the relevant authorities: money laundering in any form, including the conversion, transfer, concealment, or disguise of the proceeds of crime; financing of terrorism or proliferation of weapons of mass destruction; processing payments for or on behalf of sanctioned individuals, entities, or jurisdictions; operating an unlicensed money services business or money transmission service through our platform; willful evasion or attempted evasion of KYC, CDD, or AML controls including providing false or misleading information; and structuring transactions to avoid triggering reporting or monitoring thresholds.
Violations of this AML Policy may result in permanent account closure, forfeiture of funds where authorized by law, referral to law enforcement or regulatory authorities, and potential civil or criminal liability for the account holder. Send2Bank cooperates fully with all lawful investigations and will disclose account information and transaction records to competent authorities as required or permitted by law.
If you observe suspicious activity on the Send2Bank platform or have concerns about potential money laundering or terrorism financing, please report it immediately to [email protected]. All reports are treated confidentially and investigated promptly by our compliance team.