Aml Policy

Policy scope and objectives

Kirgo AML Policy establishes the mandatory framework to detect and prevent money laundering and terrorist financing in connection with all Kirgo products and services. The policy covers customer onboarding, ongoing account management, and all payment flows, and sets out the actions Kirgo may take to comply with applicable laws and regulatory expectations.

Legal framework and regulatory obligations

Kirgo operates in accordance with applicable anti money laundering and counter terrorist financing laws and regulations in the jurisdictions where Kirgo provides services. Kirgo implements customer due diligence measures in line with the risk profile of the customer and will report suspicious activity to the competent authorities as required by law. Sanctions screening and politically exposed persons checks are conducted as part of the risk based approach.

Onboarding and identity verification

On registration and during onboarding Kirgo conducts KYC checks. The following identity verification steps may be required:

• Valid government issued photo identity such as a passport, national identity card or driving license
• Proof of address not older than six months such as a utility bill or bank statement
• Verification of ownership of the payment method used to fund the account, which may include a copy of the card, a statement, or an e-wallet screenshot
• Where required, a live photo holding the identification document or a notarised certified ID may be requested
• In certain circumstances additional documents or data may be requested including contact details and source of funds information

Kirgo reserves the right to suspend or restrict activity on an account pending completion of checks. If verification cannot be completed to Kirgo satisfaction, access to the account or the ability to deposit or withdraw funds may be blocked or the account may be closed.

Source of funds and wealth

Customers must provide information about the source of funds used to fund the Kirgo account and the source of wealth for substantial deposits or unusual activity. Kirgo may require documentation such as bank statements, payslips, tax returns, or a wealth declaration. The information requested will be treated as confidential and used solely for AML purposes. If the customer fails to provide requested information Kirgo may restrict deposits or suspend withdrawals until verification is completed or the account is closed.

Risk assessment and enhanced due diligence

Kirgo applies a risk based approach to customer due diligence. Based on the information available and ongoing monitoring, customers may be subject to enhanced due diligence for higher risk indicators including elevated transaction volumes, irregular funding patterns, or involvement of high risk jurisdictions. Enhanced due diligence may require additional documentation and extended verification and shall be approved by Kirgo compliance personnel before continuation of activities.

Ongoing monitoring and transaction screening

Kirgo monitors all transactions and account activity for AML and fraud indicators. Transactions flagged as suspicious will be reviewed by the compliance function. Kirgo may request additional information at any time to support ongoing monitoring, including updated identity documents, source of funds information, and purpose of funds details. Kirgo may suspend or block transactions or accounts pending investigation or to prevent further illicit activity.

Suspicious activity reporting and cooperation with authorities

Kirgo may report suspicious activity to the relevant authorities in accordance with applicable law. Kirgo may share information with financial institutions, payment processors, and other service providers as required to investigate or prevent illicit activity. If required, Kirgo may freeze or close accounts and withhold funds while a full assessment is conducted. Kirgo cooperates fully with law enforcement and regulatory authorities and will provide information to the extent permitted by law.

Account restrictions and payment withholdings

In cases of suspected AML concerns Kirgo may restrict access to the account, block deposits or withdrawals, or require additional verification. Where an account is closed or funds are seized due to AML concerns Kirgo may retain or withhold funds in accordance with legal requirements and internal policy until clearance is obtained.

Data protection records and retention

Kirgo maintains records of all identity verification data, due diligence documentation, and transaction records for the period required by applicable law and as determined by Kirgo policy. Access to AML data is restricted to authorised personnel and kept secure. Data subject requests where permissible by law will be handled in accordance with Kirgo privacy policy.

Customer rights and communications

Customers will be informed of material AML related actions including verification requests and any restrictions on their account. Customers may contact Kirgo compliance or privacy teams to submit questions or appeals related to AML actions. Kirgo will provide reasonable opportunities to furnish additional information to resolve concerns where possible.

Governance updates and changes

The AML policy is approved by Kirgo compliance leadership and reviewed at least annually or upon material changes in law or business operations. Material amendments will be communicated to customers in accordance with Kirgo terms and conditions. Existing customers may be required to comply with updated policy within a reasonable time frame.