Know Your Customer (KYC)

What is a KYC check and who needs to do it?

There are internationally endorsed global standards for anti-money laundering (AML) and counter-terrorism financing (CTF). These standards have been implemented at the national level in most countries around the world. These standards help countries take action against illicit use of their financial systems.

AML/CTF laws impose obligations on Financial Service Providers to perform Know Your Customer (KYC) checks, sometimes called customer due diligence. The exact types of information that must be collected and checks that must be performed are set out in national laws, and so they vary across jurisdictions.

Whenever a organisation wishes to partner with a Financial Service Provider, the provider will be bound by AML, CTF and KYC regulations. By working with Sempo to satisfy AML/CTF and KYC regulations, our partners can be assured cash is being distributed in compliance with global standards.

What are Sempo's Transaction Limits?

We implement strict velocity exchange limits, ensuring that the rapid exchange of a large amount of currency is impossible for a single individual or small group of individuals. In addition, there are transaction limits in place to manage our risk, and ensure only fully verified users have access to the full service and can "cash out" into local fiat currency.

This means:

  • Participants may be limited to receiving “vouchers” that are only spendable within a small community at a selection of vendors, if they are only on "Level 0" or "Level 1"

  • Participants who will be cashing out into local fiat currency will need to be on "Level 2" or "Level 3"

What KYC checks does Sempo perform?

Sempo completes four types of KYC checks:

  1. Ensuring that the information provided on the person is authentic, valid and current

  2. Ensuring that the person is not a Politically Exposed Person

  3. Ensuring that the person is not on any Global Sanctions List (e.g. Interpol's Most Wanted, UN Consolidated List)

  4. Ensuring there is no adverse media on the person

We engage third-party identity and document verification providers such as Namescan. These providers offer reliable in-class document verification services using advanced scanning tools and extensive data sources.

What data points does Sempo typically require to complete KYC checks?

We require that our Partners and Field Partners collect the following data points on program participants (at a minimum). The exact data points required may vary across jurisdictions.

#

Data Points (documentation or information)

1

First Name

2

Last Name

3

Gender

4

Date of Birth

5

Address - either residential address, or village location etc

6

Phone Number (or email)

7

Bank Account Details: (a) Bank Name (b) Bank Number (c) Account Number (d) Name of Bank Account Holder

8

Photograph or PDF of a bank-issued document proving bank account ownership and the given bank account details: (a) Bank name, (b) Bank Number (C) Account Number (d) Name of Bank Account Holder. Example: bank account statement, statement of account would be acceptable. Note: The image must be complete, with all corners of the document showing. Text must be legible (ie not blurry or obscured). We cannot accept photographs of computer screens.

9

Photograph of original, government-issued Photo ID of the person (e.g. national ID, driver’s licence, passport).

Note: A certified copy can also be accepted, if government-certified.

Note: The Photo ID cannot be expired. Images of both the back and front must be included, and all text must be legible (ie not blurry or obscured).

10

Photograph of person’s face where they are holding up an original photo ID (also displayed in the photograph).

Note: The person's face must be clearly shown, in well-lit conditions, and the photograph cannot be blurry.

11

(For Level 3 verification) Additional ID, varies according to jurisdiction For example: Original or certified copy of non-photographic identification document, such as a birth certificate or citizenship certificate AND a secondary identification document, such as a notice from the Government, or from a utilities provider with the individual’s residential address.

We can only accept an identification document that has not expired (the exception to this is an Australian passport that has expired within the preceding two years).

If Sempo identifies that a customer is high-risk, we will let you know as soon as possible that we need to conduct further KYC. For example, we may take the following additional KYC checks for high risk individuals:

  • checking any other names that customer is known by;

  • customer’s countries of citizenship or residence;

  • customer’s occupation nor business activities;

  • income or assets of the customer; or

  • beneficial ownership of funds

If no government-issued Photo ID will be available, please reach out to us at compliance@withsempo.com. We may be able to accept referee statements, government correspondence or other types of self-attestations depending upon the laws of the country.

What is our advice for Partners when collecting data for KYC from program participants?

When collecting information for KYC purposes, we encourage our Partners to ensure they:

  1. Use our template KoboToolbox survey forms.

  2. Only submit photographs of ID or documents which are clear, and undamaged. We cannot accept blurry or distorted images where we cannot read the text or clearly see the photo.

  3. Submit complete images of the ID or document. Please make sure that the full image of the document is included and you can see the “edges’ of the document.

  4. Provide photographs of original Photo ID. We can only accept photographs of originals.

  5. Check that ID provided is current. We cannot accept expired IDs.

  6. Remind Field Partners and vendors that the “Selfie” Photograph of a person holding up their Photo ID has to have their Photo ID displayed in it. This helps us perform a check that is similar to the check that a bank teller would perform when a person visits a bank branch in person before opening an account.

What does Sempo share with our Partners when KYC reports are completed?

When KYC reports are complete, Sempo will share a KYC report spreadsheet with you.

Checks that Sempo will perform (2/2)
Checks that Sempo will perform (2/2)

What happens if Sempo identifies that a person is on a prohibited list during a KYC check?

If a KYC check reveals that a person is on a prohibited list, Sempo is legally compelled to investigate and report to AUSTRAC.

Sempo is prohibited under AML/CTF and KYC regulations from notifying our partners if a participant in a cash program is revealed to be on a prohibited list.

How does Sempo manage the process of collecting and managing KYC data?

Sempo tracks the status of Know Your Customer (KYC) checks, and discusses progress and any issues in our weekly check-ins with partners during the set-up phase.

Indicative template of status tracker