AML/CFT Policy

1. Purpose and scope

ZYND SARL, which operates ZyndPay, applies this policy to all its services: personal accounts and the ZyndPay Wallet, the P2P marketplace, business accounts, and payments made to ZyndPay merchants.

It is based on the uniform law of the West African Economic and Monetary Union (UEMOA) on anti-money laundering and countering the financing of terrorism and proliferation, as applicable in Mali, on the Recommendations of the Financial Action Task Force (FATF), and on the sanctions of the United Nations Security Council. Where we work with payment partners, their own controls also apply.

2. Risk-based approach

The checks we carry out are proportionate to risk. We take into account the type of customer and activity, countries involved, amounts and frequency of operations, payment methods, the risk associated with digital assets and blockchain addresses, and any information from sanctions lists, public sources or authorities.

3. Knowing our customers

Individuals. Personal accounts have verification levels. Higher limits require more information, such as identity documents and, where applicable, information about the source of funds.

Businesses. Before processing real money, we verify the business, its activity, its beneficial owners, directors and representatives, and the expected use of our services. Live services also require a signed Merchant Service Agreement.

Enhanced checks. We carry out additional checks for politically exposed persons, higher-risk countries or activities, and unusual operations. We may ask for additional documents.

Ongoing checks. We keep customer information up to date and review it when circumstances change. If we cannot complete the required checks, we may refuse or end the relationship.

4. Sanctions

We check customers, beneficial owners and, where relevant, counterparties against the United Nations sanctions lists, the asset-freeze lists applicable in Mali and the UEMOA, and other international lists that we consider relevant, such as those of the European Union, the United States and the United Kingdom. We also screen digital asset transactions.

We do not provide services to sanctioned persons, or to people in countries subject to comprehensive sanctions or to a FATF call for action. Where the law requires, we freeze the assets concerned and inform the competent authorities.

5. Monitoring operations

We monitor operations to detect activity that is unusual or inconsistent with what we know about the customer. An operation may be delayed, blocked or rejected while it is reviewed.

On the P2P marketplace, each user must pay and be paid from accounts in their own name. Payments from third parties are prohibited.

6. Reporting and cooperation with authorities

Where required, we report suspicious transactions to the competent financial intelligence unit, including the Cellule Nationale de Traitement des Informations Financières (CENTIF) in Mali. The law prohibits us from telling the people concerned that a report has been made. We respond to lawful requests from competent authorities.

7. Record keeping

We keep identification and verification records, transaction records and records of our analyses and reports for 10 years after the end of the relationship or the operation, or longer if required by an authority. Our Privacy Policy explains how this data is protected.

8. What we expect from you

• give accurate information and respond promptly to our requests for information or documents;
• use your account only for yourself or for the business that holds it;
• tell us about changes in your situation, your activity or, for a business, its owners and representatives.

If you do not, or if we detect a risk, we may delay or refuse operations, restrict or close your account and, where the law requires, report to the authorities. These measures are described in our Terms of Service.

9. Governance and training

Compliance is overseen by designated persons who report to management, and the staff concerned are trained. This policy is reviewed regularly and when our services, risks or the law change.

10. Contact

For questions about this policy, or to report suspected fraud or misuse of ZyndPay, write to compliance@zyndpay.io. Never send your password, PIN or verification codes.