VukaPay AML Compliance Policy

Introduction and Purpose

Vuka Pay Limited is committed to maintaining an effective, risk-based compliance program designed to safeguard its payment infrastructure from money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion, and other unlawful financial activities.

We recognise that strong compliance is not merely a regulatory obligation, but an essential part of protecting our customers, partners, regulators, and the wider financial ecosystem.

This Policy forms an integral part of Vuka Pay Limited’s Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and Counter-Proliferation Financing (CPF) framework and is binding upon all employees, management, contractors, and designated agents.

Vuka Pay Limited remains committed to complying with recognised international AML/CFT/CPF standards, including the Financial Action Task Force (FATF) Recommendations, as well as applicable regulations and guidance issued by the Central Bank of Kenya (CBK), the Financial Reporting Centre (FRC), and other relevant regulatory authorities.

This includes compliance with the applicable legal and supervisory framework, including but not limited to:

• The Proceeds of Crime and Anti-Money Laundering Act (POCAMLA) – Kenya

• The National Payment System Act, 2011

• The National Payment System Regulations

• The Prevention of Terrorism Act (POTA)

Vuka Pay Limited applies robust Customer Due Diligence (CDD), Know Your Customer (KYC), and Know Your Business (KYB) measures. We also conduct sanctions screening, Politically Exposed Person (PEP) screening, adverse media checks, and ongoing customer monitoring throughout the customer lifecycle.

In addition, we verify Ultimate Beneficial Owners (UBOs) where applicable. Vuka Pay Limited does not engage with anonymous persons, fictitious identities, sanctioned individuals or entities, prohibited businesses, shell companies, or parties whose activities cannot reasonably be verified as lawful.

This Policy forms part of Vuka Pay Limited’s broader governance and internal control framework. It guides our approach to:

• Customer onboarding

• Transaction monitoring

• Suspicious activity detection and reporting

• Regulatory reporting to the Financial Reporting Centre (FRC)

• Record keeping

• Staff training and awareness

• Independent compliance testing

• Continuous monitoring and improvement

This Policy is implemented and overseen by the Risk and Compliance Department and is reviewed at least annually, or whenever required by regulatory developments, internal audits, or operational changes, to ensure that it remains effective and up to date.

Vuka Pay Limited maintains a strict zero-tolerance approach toward money laundering, terrorist financing, proliferation financing, fraud, sanctions violations, and other forms of financial crime. Any suspicious activity identified through our systems or operations may result in enhanced due diligence, transaction restrictions, account suspension, regulatory reporting, or termination of business relationships where necessary.

Contact Information

For AML/CFT inquiries:

Email: support@vukapay.com
Address: Nairobi, Kenya

VukaPay Privacy Policy

1. Introduction
VukaPay is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our services. By accessing or using VukaPay, you agree to the terms outlined in this policy.

2. Information We Collect
We collect the following types of information:

• Personal Information: Name, email address, phone number, business details, and payment information.

• Transaction Data: Payment history, transaction details, and related financial information.

• Technical Data: IP address, device information, and browsing behavior.

• Compliance Data: Information necessary to meet legal and regulatory requirements.

3. How We Use Your Information
We use your information for the following purposes:

• To provide and manage our payment services.

• To process transactions securely.

• To comply with legal and regulatory requirements.

• To prevent fraud, unauthorized access, and security threats.

• To communicate with you regarding updates, promotions, and service-related matters.

• To improve our services and enhance user experience.

4. Sharing and Disclosure of Information
We do not sell or rent your personal information. However, we may share your information with:

• Service Providers: Third-party partners who assist in payment processing, fraud prevention, and customer support.

• Regulatory Authorities: When required by law or regulatory obligations.

• Business Transfers: In case of mergers, acquisitions, or other business changes.

5. Data Security
We implement industry-standard security measures to protect your data. However, no online platform is completely secure, and we encourage users to take appropriate precautions.

6. Your Rights and Choices
You have the right to:

• Access, update, or delete your personal information.

• Opt-out of marketing communications.

• Request information on how your data is processed.

7. Retention of Data
We retain your information only as long as necessary for legal, regulatory, and operational purposes.

8. Changes to This Policy
We may update this Privacy Policy from time to time. Significant changes will be communicated through our platform or via email.

9. Contact Us
If you have any questions about this Privacy Policy, please contact us at:
Email: support@vukapay.com
Address: Nairobi, Kenya

VukaPay Terms & Conditions

1. Introduction

Welcome to VukaPay, a trusted payment service provider based in Nairobi, Kenya, serving businesses and individuals across 17 countries in Africa. By accessing or using VukaPay, you agree to comply with and be bound by these Terms and Conditions. Please read them carefully. If you do not agree to these terms, do not use VukaPay.

2. Use of the Service

Eligibility: To use VukaPay, you must be at least 18 years old and capable of forming a binding contract.
Account Registration: You must create an account to use VukaPay. You agree to provide accurate, current, and complete information during the registration process and to keep such information updated. You are responsible for safeguarding your password and any activities or actions under your account.
License: Subject to these Terms, we grant you a non-exclusive, non-transferable, revocable license to access and use VukaPay strictly in accordance with these Terms.

3. Prohibited Uses

You agree not to:

• Use VukaPay for any unlawful purpose or in any way that could harm us, our partners, or other users.

• Engage in fraudulent activities, including money laundering, financing terrorism, or processing illegal transactions.

• Attempt to gain unauthorized access to VukaPay’s systems or interfere with its functionality.

• Use VukaPay in any manner that could disrupt its services for other users.

4. Fees and Payment

Transaction Fees: VukaPay charges fees for processing payments, which will be clearly communicated on our platform.
Billing & Payments: Fees will be deducted automatically from transactions. Users are responsible for ensuring sufficient funds are available for transactions.
Refunds: Transaction fees are generally non-refundable except where mandated by applicable laws or policies.

5. Account Suspension & Termination

We may suspend or terminate your account without prior notice if:

• You violate these Terms.

• Your activities are deemed suspicious or fraudulent.

• Required regulatory compliance actions necessitate such a measure.
  Upon termination, your access to VukaPay services will cease immediately.

6. Limitation of Liability

To the fullest extent permitted by law, VukaPay, its affiliates, officers, directors, employees, or partners shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including loss of profits, data, or goodwill, arising from:

• Your use or inability to use VukaPay.

• Unauthorized access to or use of our systems.

• Any interruptions, bugs, or cyber threats affecting VukaPay.

• Errors or inaccuracies in transaction processing.

  
  

7. Changes to the Terms

We reserve the right to update these Terms at any time. If a revision is material, we will provide at least 30 days' notice before the new terms take effect. Your continued use of VukaPay after updates constitutes acceptance of the revised terms.

8. Governing Law

These Terms shall be governed by and construed in accordance with the laws of Kenya, without regard to conflict of law provisions.

9. Contact Us
For any questions or concerns regarding these Terms, please contact us at:
Email: support@vukapay.com
Address: Nairobi, Kenya