AML Policy

01Our Commitment

Rezato adopts a zero-tolerance approach to money laundering, terrorist financing, proliferation financing, and all other forms of financial crime. We conduct our business with the highest standards of integrity and ethical conduct, and we adhere strictly to all applicable laws, regulations, and guidelines designed to prevent financial crime.

02Regulatory Framework

Our AML/CFT/CPF framework complies with:

• Proceeds of Crime and Anti-Money Laundering Act, 2009 (POCAMLA, Kenya), as amended
• Proceeds of Crime and Anti-Money Laundering Regulations, 2023
• Anti-Money Laundering and Combating of Terrorism Financing and Proliferation Financing (Amendment) Act, 2025
• Prevention of Terrorism Act (Cap. 59B) as amended
• Central Bank of Kenya (CBK) AML/CFT Prudential Guidelines
• Anti-Money Laundering Act, 2006 (Tanzania) and related regulations
• Financial Action Task Force (FATF) Recommendations
• United Nations Security Council Resolutions relating to ML/TF/PF

We acknowledge Kenya’s placement on the FATF grey list since February 2024 and incorporate enhanced measures to address the strategic deficiencies identified by FATF and ESAAMLG.

03Core Controls

As a licensed payment service provider, we operate:

• Customer Due Diligence (CDD / KYC) — identity verification and beneficial ownership checks for all customers, with enhanced due diligence for higher-risk relationships (including PEPs, high-risk jurisdictions, and non-face-to-face customers)
• Sanctions screening — real-time screening of all customers, beneficial owners, and transaction participants against UN Security Council Consolidated List, OFAC SDN, and other applicable lists
• Transaction monitoring — automated and manual monitoring for unusual patterns, structuring, or typologies linked to financial crime
• Suspicious Transaction Reporting (STR) — reports filed with the Financial Reporting Centre (FRC, Kenya) via the goAML system within the timelines prescribed by Section 44 of POCAMLA
• Record keeping — a minimum of seven (7) years retention of customer, transaction, and reporting records, as required by POCAMLA and CBK guidelines
• Staff training — mandatory, ongoing AML/CFT/CPF training for all employees and agents
• Independent audit — annual independent review of the AML/CFT/CPF programme, with findings reported to the Board of Directors

04Data Privacy and Protection

Personal data collected for AML/CFT/CPF purposes is processed in strict compliance with the Kenya Data Protection Act, 2019 and the Tanzania Personal Data Protection Act, 2022. Our lawful basis for processing is primarily the legal obligation imposed by POCAMLA and related regulations. Data is retained for the statutory minimum of 7 years and securely disposed of thereafter.

For details, see our Privacy Policy.

05Requesting the Full Policy

The full Rezato AML/CFT/CPF Policy and Programme (Document Reference RR-AML-001-2026) is an internal document made available to partners, correspondent institutions, regulators, and auditors on a confidential basis.

06Contact Us