Last Reviewed: July 14, 2026
Ognimohub is committed to preventing its services from being used for money laundering, terrorist financing, fraud, or other illicit financial activities. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy establishes the framework and controls used to detect, prevent, and report such activities and to comply with applicable laws and regulations.
The Policy applies to all Ognimohub employees, agents, contractors, services, and platforms, including the Website, User App, Agent App, and Merchant App.
Ognimohub is committed to:
Complying with applicable AML/KYC laws, regulations, and regulatory guidance.
Maintaining effective controls to mitigate money laundering and terrorist-financing risks.
Conducting Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) where required.
Monitoring transactions and reporting suspicious activity to relevant authorities.
Providing ongoing AML/KYC training.
Cooperating with law enforcement and regulatory agencies.
Ognimohub follows international AML/KYC standards, including FATF recommendations, and applicable national requirements.
The framework includes, as applicable:
AML and counter-terrorist financing laws.
KYC and customer identification requirements.
Data protection and privacy laws, including GDPR or equivalent requirements.
Sanctions regimes, including OFAC, UN, EU, and national sanctions.
Payment-services and electronic-money regulations.
In Kenya, Ognimohub complies with the Proceeds of Crime and Anti-Money Laundering Act (POCAMLA), associated regulations, and guidance issued by the Central Bank of Kenya (CBK) and Financial Reporting Centre (FRC).
This Policy applies to:
All Ognimohub services and products, including mobile financial services, payment processing, money transfers, virtual cards, microfinance, and investments.
All customers, including individual users, agents, and merchants.
Employees, agents, and contractors involved in activities exposing Ognimohub to AML/CTF risks.
All Ognimohub systems and platforms.
Ognimohub applies a risk-based approach, with the intensity of CDD determined by customer, product, geographic, and delivery-channel risk.
Risk assessments consider:
Customer identity, occupation, source of funds/wealth, and location.
Product or service risk, including high-value and cross-border transactions.
Geographic risk, including high-risk countries or regions.
Delivery-channel risk, including online and agent-based services.
Low Risk: Standard CDD.
Medium Risk: Additional CDD or increased monitoring may apply.
High Risk: EDD and continuous, intensified monitoring are required.
CDD requires Ognimohub to identify and verify customers and understand the nature and purpose of their relationship with the Platform.
Required information may include:
Full legal name, date of birth, nationality, and residential address.
Valid government-issued ID, passport, or driver's license.
Verified phone number and email address.
Selfie/liveness verification where required.
Agents must provide individual-user requirements for the principal, plus:
Business name and registration documents.
Business address and proof of agent status.
Bank details and beneficial ownership information.
Merchants must provide:
Legal entity name and business registration documents.
Registered and operating addresses.
TIN, bank details, and nature of business.
Beneficial ownership and identification of directors/senior management.
Ognimohub may use:
Documentary verification for authenticity, tampering, and expiry.
Non-documentary verification against public databases and credit bureaus.
Biometric verification, including facial recognition and liveness detection.
Proof of address such as utility bills, bank statements, or government documents.
CDD is ongoing and may include periodic reviews, event-driven reviews, and monitoring for changes in customer behaviour, beneficial ownership, or business activity.
EDD may be required for:
Politically Exposed Persons (PEPs), their family members, or close associates.
Customers connected to high-risk jurisdictions.
Unusual or complex transactions without a clear lawful or economic purpose.
High-value transactions above predefined thresholds.
Negative media or adverse public information.
Opaque ownership structures.
Measures may include:
Additional identification from independent sources.
Detailed source-of-funds or source-of-wealth documentation.
Senior-management approval of high-risk relationships.
On-site visits for high-risk corporate customers or agents.
Enhanced sanctions, PEP, background, and adverse-media screening.
Ognimohub uses automated systems for real-time and post-transaction monitoring, rule-based scenarios, behavioural analytics, and threshold-based alerts.
Alerts are reviewed by trained AML officers, who may gather additional information, analyse transaction patterns, and document findings.
Examples include:
Sudden increases in transaction volume or value.
Frequent transactions just below reporting thresholds.
Transactions involving high-risk jurisdictions without clear rationale.
False or misleading information, reluctance to provide information, or unusual urgency.
Structuring transactions to avoid detection.
Transactions without an apparent legitimate purpose.
Employees must promptly report suspected activity to the MLRO.
The MLRO investigates and gathers relevant documentation.
Where suspicion is formed, the MLRO files an SAR/STR with the relevant FIU within the legally required timeframe.
Ognimohub prohibits tipping off customers or third parties about SAR/STR filings.
Internal reports, investigations, and SAR/STR filings are retained for the period required by applicable law, typically 5–7 years.
Ognimohub screens customers against applicable sanctions lists, including OFAC SDN, UN Security Council, EU Consolidated, and national lists. Transactions, particularly cross-border transactions, may be screened in real time or in batches. False positives are investigated and resolved.
A sanctions match may result in:
Immediate freezing of the relevant account or transaction.
Prompt reporting to relevant authorities.
Escalation to the MLRO, senior management, and legal counsel.
Ognimohub may collect financial and personal information, optional messages, app-performance data, photos, and contacts as described in its data policy, for functionality, fraud prevention, security, compliance, and account management.
Records are retained for at least five (5) years from the end of the business relationship or transaction date, or longer where required by applicable law.
Data is encrypted in transit.
AML/KYC data access is limited to authorized personnel on a need-to-know basis.
Users may request data deletion subject to legal retention requirements.
Ognimohub does not share user data with third parties except where required by law or regulation.
Ognimohub appoints a qualified MLRO with sufficient authority to oversee this Policy. The MLRO is responsible for maintaining the framework, investigating internal reports, filing SARs/STRs, liaising with regulators, and overseeing AML/KYC training.
Senior management and the Board approve the AML/KYC Policy, provide resources, receive MLRO reports, and support a strong compliance culture.
Independent internal audit periodically tests the AML/KYC programme, identifies weaknesses, recommends corrective action, and reports to senior management and the Board.
Training covers AML/KYC requirements, CDD, transaction monitoring and red flags, reporting and no-tipping-off rules, sanctions, data protection, and regulatory updates.
Training is provided:
On joining Ognimohub.
Annually for relevant personnel.
On an ad-hoc basis following significant regulatory changes or identified risks.
Ognimohub uses specialized AML/KYC technology for identity verification, sanctions and PEP screening, transaction monitoring, case management, and SAR/STR processes.
Third-party API integrations are subject to due diligence to ensure compliance with Ognimohub standards and applicable regulations.
Ognimohub states that it does not share user data with third parties except where legally or regulatorily required and uses encryption in transit. Data-collection practices are communicated through in-app privacy policies.
Ognimohub states that it holds required licenses and approvals in its operating jurisdictions and discloses financial services and applicable terms to users.
The AML/KYC framework is intended to protect users, secure the Platform, and maintain the integrity of Ognimohub services.
The MLRO and senior management will review this Policy at least annually to assess effectiveness, legal and regulatory compliance, business changes, and risk-profile changes. Updates require senior-management approval and are communicated to relevant personnel.
For questions regarding this Policy or to report suspicious activity:
Address: PR89+2WP, Pioneer House, Kenyatta Avenue, Nairobi, Kenya
Email: support@ognimohub.com
Phone: +254 745 497444
Ognimohub offers investment products, with specific AML-aligned withdrawal controls designed to protect users, maintain settlement integrity, and prevent investment modules from being used for layering or structuring illicit funds.
Products include:
Hourly Investments — cycles settled within the same hour.
Daily Investments — cycles settled at the end of each calendar day.
Weekly Investments — seven (7) calendar days.
Monthly Investments — thirty (30) calendar days.
Quarterly/Long-Term Investments — periods exceeding thirty (30) days.
Hourly and Daily Investments: Proceeds may be withdrawn or transferred after the applicable cycle has successfully completed and settled.
Weekly, Monthly, and Long-Term Investments: For products lasting more than twenty-four (24) hours:
Principal and earned returns may only be withdrawn after full maturity and official completion.
Partial withdrawals and early redemptions are not permitted.
The restriction applies to cashouts, bank transfers, mobile-money transfers, P2P transfers, and other withdrawal or transfer mechanisms.
The stated rationale is that currency fluctuations can affect investment values and mid-cycle withdrawals could create settlement uncertainty or facilitate manipulation of gains or fund origin.
Investment activity remains subject to transaction monitoring. Additional controls include:
Source-of-funds verification above defined thresholds.
Review of sudden or repeated large investments, especially where followed by maximum withdrawals at cycle end.
Review of rapid movement through multiple investment cycles without a clear economic rationale as a potential layering red flag and possible EDD trigger.
Sanctions screening before processing investment transactions.
Ognimohub may be required to report investment returns to tax authorities in certain jurisdictions. Users are responsible for their own tax obligations, and Ognimohub will cooperate with lawful tax-authority requests.
Ognimohub may identify multiple accounts belonging to the same individual or entity to prevent circumvention of AML/KYC controls and maintain platform integrity.
Detection methods may include:
Biometric matching.
National ID, passport, or other government-ID matching.
Phone and email linkage.
Device fingerprinting and IP correlation.
Behavioural analytics.
Where multiple accounts are identified, the first account created, based on the earliest verified registration timestamp, is designated the Primary Account.
Only the Primary Account may initiate:
Cashout or withdrawal to registered mobile-money wallets.
Direct bank transfers to registered bank accounts.
The designation is automatic upon detection and cannot be circumvented.
Secondary Accounts retain access to other available features, including:
P2P payments.
Investment products, subject to Section 16.
Merchant or agent capabilities where separately approved.
Virtual cards.
Bill payments and other in-app financial services.
Secondary Accounts may not be used indirectly to access cashout or bank transfers, including by transferring funds to a third party for withdrawal on the account holder's behalf. Such activity may constitute a policy violation and trigger AML investigation.
Restricting cashout and bank transfers to the Primary Account helps:
Prevent structuring across multiple accounts.
Preserve identity integrity.
Maintain a clear audit trail.
Reduce the risk of layering through multiple accounts.
When multiple accounts are detected, Ognimohub will:
Notify the user.
Identify the designated Primary Account.
Allow the user to appeal the designation with supporting documentation.
Compliance will review appeals within ten (10) business days and communicate the outcome. Ognimohub reserves the right to make the final determination.
Users may not:
Create multiple accounts to circumvent AML/KYC controls, transaction limits, or withdrawal restrictions.
Use secondary accounts to aggregate funds for withdrawal through the Primary Account.
Provide false identity information to avoid account linkage.
Violations may result in suspension or permanent closure of all related accounts, reporting to the relevant FIU, and, where applicable, referral to law enforcement.
This document constitutes the official AML/KYC Policy of Ognimohub.
Last Reviewed: April 2026 | Next Scheduled Review: January 2027
Approved by Senior Management & Board of Directors
