AML / KYC Policy – Viapa AI

Effective Date: September 15th, 2025

1. Purpose

Viapa is committed to preventing its platform from being used for:

• Money laundering

• Terrorist financing

• Fraud

• Financial crime

• Sanctions evasion

This AML/KYC Policy establishes the framework through which Viapa identifies customers, assesses risk, monitors activity, and cooperates with regulated partners and authorities.

2. Scope

This policy applies to:

• All Viapa employees and contractors

• All users of the Viapa platform

• All products, services, and integrations

• All third-party service providers involved in onboarding, payments, or identity verification

3. Viapa’s Operating Model 

Viapa operates a non-custodial, technology-only model:

• Viapa does not hold customer funds

• Viapa does not perform settlement or custody

• Regulated financial institutions and payment providers retain custody and are responsible for transactional AML controls

Viapa’s AML/KYC responsibilities therefore focus on:

• User identity verification

• Risk assessment

• Platform-level monitoring

• Suspicious activity detection and escalation

• Cooperation with regulated partners

4. Regulatory Alignment

This policy is aligned with:

• Financial Action Task Force (FATF) recommendations

• Nigeria AML/CFT Regulations

• Applicable international AML laws

• Data protection requirements under GDPR and NDPR

5. Governance & Oversight

5.1 Compliance Responsibility

Viapa maintains a Compliance & Risk Function responsible for:

• AML/KYC policy oversight

• Risk assessment

• Staff training

• Incident escalation

• Partner coordination

5.2 Senior Management Oversight

Senior management provides oversight, resources, and authority to enforce this policy.

6. Risk-Based Approach

Viapa applies a risk-based approach to AML/KYC, considering:

• User type

• Geography

• Transaction patterns

• Product usage

• Behavioral indicators

Users are classified as:

• Low risk

• Medium risk

• High risk

Controls scale according to risk level.

7. Customer Due Diligence (CDD)

7.1 Identity Verification (KYC)

Viapa verifies user identity using:

• Government-issued identification (where applicable)

• Contact verification (email, phone)

• Device and behavioral signals

• Third-party KYC/identity verification providers

7.2 Information Collected

Depending on risk level, this may include:

• Full name

• Date of birth

• Contact details

• Identity document details

• Biometric or liveness checks (via partners)

8. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied where higher risk is identified, including:

• High-risk jurisdictions

• Unusual activity patterns

• Politically Exposed Persons (PEPs)

• Sanctions-related indicators

EDD may include:

• Additional identity checks

• Source-of-funds confirmation (through partners)

• Ongoing monitoring

9. Sanctions & Watchlist Screening

Viapa supports screening against:

• Sanctions lists

• PEP databases

• Watchlists

Screening is performed:

• At onboarding

• Periodically thereafter

• When risk indicators arise

10. Transaction & Activity Monitoring

While Viapa does not process or settle funds, it monitors platform activity patterns, including:

• Unusual usage behavior

• Repeated failed transactions

• Abnormal interaction patterns

• Attempts to bypass controls

Potentially suspicious activity is escalated to:

• Internal compliance review

• Relevant regulated partners

11. Suspicious Activity Reporting & Escalation

Viapa maintains procedures to:

• Identify suspicious behavior

• Escalate internally

• Notify relevant regulated partners

• Cooperate with lawful requests from authorities

Viapa does not independently file regulatory Suspicious Activity Reports where not legally required but supports partners who do.

12. Record Keeping

Viapa maintains AML/KYC records in accordance with legal requirements, including:

• Identity verification records

• Risk assessments

• Monitoring logs

• Escalation records

Records are retained securely and only for as long as legally required.

13. Data Protection & Privacy

All AML/KYC data is processed in accordance with:

• GDPR

• NDPR

• Viapa’s Privacy Policy and DPA

Access to AML/KYC data is strictly limited and logged.

14. Staff Training & Awareness

Employees involved in relevant functions receive:

• AML/KYC awareness training

• Fraud and financial crime detection training

• Regular updates on emerging risks

Training is documented and refreshed periodically.

15. Third-Party & Partner Coordination

Viapa works closely with:

• Regulated banks

• Payment processors

• Identity verification providers

All third parties are subject to due diligence and contractual compliance obligations.

16. Breach, Non-Compliance & Enforcement

Violations of this policy may result in:

• Disciplinary action

• Termination of access

• Contract termination

• Reporting to appropriate authorities where required

17. Policy Review & Updates

This policy is reviewed:

• At least annually

• Upon regulatory changes

• Upon material changes to Viapa’s services

18. Contact & Reporting

For AML/KYC questions or concerns:

Viapa – Compliance & Risk Team

📧 Email: Privacy@viapaai.com