AML & CFT Policy

1. Policy Objective

 

QuickPe is committed to preventing its platform from being used for money laundering, terrorist financing, fraud, or other financial crimes.

 

This AML & CTF Policy establishes a risk-based, technology-enabled framework to:

 

• Verify customer identity

• Detect and prevent suspicious activity

• Comply with applicable AML / CFT regulations

• Protect users, partners, and the financial ecosystem

 

 

2. Scope & Applicability

 

This policy applies to:

 

• All QuickPe users and customers

• Intelligent eKYC and video verification processes

• Credit Ladder, BNPL, and device-financing services

• Merchants, agents, and onboarding partners

• Employees, contractors, and service providers

 

The policy applies across all jurisdictions where QuickPe operates.

 

 

3. Regulatory Alignment

 

QuickPe’s AML framework is aligned with:

 

• FATF (Financial Action Task Force) Recommendations

• Global Customer Due Diligence (CDD) standards

• Enhanced Due Diligence (EDD) for higher-risk cases

• Risk-Based Approach (RBA) to AML / CFT

 

This policy is country-agnostic and adaptable to local laws where required.

 

 

4. AML Governance & Responsibility

 

 

4.1 Senior Management Oversight

 

Senior management is responsible for:

 

• Approving and reviewing this policy

• Defining risk appetite

• Ensuring adequate AML controls and resources

 

 

4.2 Compliance & Risk Function

 

The Compliance function is responsible for:

 

• Implementing AML controls

• Monitoring compliance and risk

• Investigating suspicious activity

• Liaising with regulators and partners

 

 

4.3 Employees & Partners

 

All staff, agents, and partners must:

 

• Follow AML procedures and SOPs

• Complete AML training

• Escalate suspicious activity immediately

• Maintain confidentiality

 

 

5. Risk-Based Approach

 

QuickPe applies a Risk-Based AML Framework, assessing risk across:

 

• Customer risk (profile, behavior, verification strength)

• Geographic risk (location, cross-border exposure)

• Product risk (credit, BNPL, device financing)

• Behavioral risk (usage patterns, anomalies)

 

Users are classified as Low, Medium, or High Risk, with controls applied accordingly.

 

 

6. Customer Due Diligence (CDD)

 

 

6.1 Standard Due Diligence

 

At onboarding, QuickPe performs:

 

• Identity verification via Intelligent eKYC

• AI-based document verification

• Live selfie with liveness detection

• Automated fraud and consistency checks

 

This establishes the user’s baseline AML risk profile.

 

 

6.2 Enhanced Due Diligence (EDD)

 

EDD is triggered when:

 

• Risk indicators exceed thresholds

• Inconsistencies or anomalies are detected

• Regulatory or partner requirements apply

 

EDD measures may include:

 

• Consent-based recorded video verification

• Human review by trained agents

• Additional documentation or validation

• Manual approval before credit activation

 

 

7. Prohibited Activities

 

QuickPe strictly prohibits:

 

• Anonymous or fictitious accounts

• Forged or stolen identity documents

• Attempts to bypass verification controls

• Use of the platform for illegal or deceptive purposes

 

Accounts may be restricted, suspended, or terminated upon detection.

 

 

8. Credit Ladder & AML Controls

 

QuickPe integrates AML controls into its Credit Ladder model:

 

• Users start with low-risk starter credit

• Credit access increases only after verified, positive behavior

• Continuous monitoring is applied at every ladder level

 

This ensures responsible, controlled exposure at all times.

 

 

9. Ongoing Monitoring

 

QuickPe conducts continuous monitoring using:

 

• Automated behavioral and risk analytics

• Transaction and usage pattern analysis

• Periodic review of higher-risk users

 

Monitoring is supported by human oversight and escalation mechanisms.

 

 

10. Suspicious Activity Detection & Reporting

 

 

10.1 Detection

 

Suspicious activity may include:

 

• Identity mismatches or repeated failures

• Unusual usage or repayment behavior

• Attempts to manipulate credit limits

• Signals of fraud or impersonation

 

 

10.2 Escalation & Action

 

When detected:

 

• Account activity may be temporarily restricted

• Additional verification may be requested

• Internal escalation is initiated

 

Where required by law, QuickPe may:

 

• File reports with relevant authorities

• Cooperate with law-enforcement agencies

 

 

11. Record Keeping

 

QuickPe securely maintains records of:

 

• KYC and verification data

• Video verification sessions

• Risk assessments and decisions

• Account activity and monitoring logs

 

Records are retained only for legally required periods.

 

 

12. Technology & AI Use

 

QuickPe uses AI and automation to:

 

• Detect fraud and inconsistencies

• Perform OCR, facial matching, and liveness checks

• Identify high-risk behavior patterns

 

Automated decisions affecting users are reviewable and supplemented by human review.

 

 

13. Data Protection & Confidentiality

 

All AML-related data:

 

• Is handled per QuickPe’s Privacy Policy

• Is encrypted and access-controlled

• Is used strictly for compliance and risk purposes

 

 

14. Training & Awareness

 

QuickPe ensures:

 

• Regular AML training for employees and agents

• Awareness of emerging risks and typologies

• Clear internal reporting and escalation channels

 

 

15. Policy Review & Updates

 

This policy is:

 

• Reviewed periodically

• Updated for regulatory or risk changes

• Approved by senior management

 

Material updates are communicated where required.