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KYC & AML Policy

Effective 1 March 2026

Spondula Ltd is committed to preventing the use of its platform for money laundering, terrorist financing, and other financial crimes. This policy outlines the identity verification and monitoring procedures we apply to meet our regulatory obligations.

1. Why We Verify Identity

Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations require financial service providers to verify the identity of their users. Verification helps us:

  • Prevent fraud and identity theft.
  • Detect and report suspicious transactions.
  • Comply with UK, EU, and international AML directives.
  • Protect the Spondula community.

2. Verification Tiers

Tier 1 — Basic (email verification)

  • Required for all accounts at signup.
  • Enables limited transaction amounts and basic features.

Tier 2 — Standard (document verification)

  • Government-issued photo ID (passport, driving licence, or national ID card).
  • Proof of address (utility bill, bank statement, or government letter dated within 3 months).
  • Selfie for identity matching.
  • Enables higher transaction limits and full platform features.

Tier 3 — Enhanced (additional due diligence)

  • May be required for very high transaction volumes, merchant accounts, or users in higher-risk jurisdictions.
  • May include source of funds documentation, additional identity checks, or ongoing monitoring.

3. Verification Process

  1. You submit your documents through the in-app KYC flow.
  2. Documents are securely uploaded to encrypted storage.
  3. Our review team (and, where applicable, automated checks) verifies your documents.
  4. You are notified of the outcome — approved, or rejected with a reason and the option to resubmit.

We aim to complete standard reviews within 24 hours. Enhanced due diligence may take longer.

4. Document Handling

  • KYC documents are stored in an encrypted, access-restricted storage bucket.
  • Only authorised personnel involved in the review process can access your documents.
  • Documents are retained for a minimum of 5 years after account closure, as required by regulation.
  • Selfie images are used solely for identity matching and are not shared with third parties.

5. Transaction Monitoring

We monitor transactions for patterns that may indicate suspicious activity, including but not limited to:

  • Unusually large or frequent transactions.
  • Transactions inconsistent with the user's stated purpose or profile.
  • Rapid movement of funds through multiple accounts.
  • Transactions involving jurisdictions subject to sanctions.

Suspicious activity may be reported to the relevant Financial Intelligence Unit (FIU) as required by law. We are not required to inform you if such a report is made.

6. Sanctions Screening

We screen users against applicable sanctions lists, including those maintained by the UK Office of Financial Sanctions Implementation (OFSI), the EU, and the UN. Users identified on sanctions lists will be denied service.

7. Politically Exposed Persons (PEPs)

Enhanced due diligence is applied to users identified as Politically Exposed Persons or their close associates, in accordance with applicable regulations.

8. Record Keeping

We maintain records of all identity verification decisions, supporting documents, and suspicious activity reports for a minimum of 5 years, as required by UK Money Laundering Regulations.

9. Your Obligations

  • Provide accurate and genuine documents for verification.
  • Notify us if your personal details change (name, address, nationality).
  • Do not attempt to circumvent verification requirements.

Providing false or fraudulent documents is a criminal offence and will result in immediate account termination and potential referral to law enforcement.

10. Contact

For questions about our KYC and AML procedures, contact compliance@spondula.com.