Keeping Reback safe and legal protects everyone who uses it. This statement explains how we verify identity, screen for sanctions and monitor for financial crime across the countries we serve.
1. Our commitment
Reback is committed to preventing money laundering, terrorist financing, sanctions evasion and other financial crime. Because we facilitate payments and hold funds in escrow, we operate a risk-based anti-money-laundering (“AML”) and know-your-customer (“KYC”) / know-your-business (“KYB”) program. This statement summarises that program for our users; it is not the full internal policy.
2. Regulatory framework
Reback operates across several countries and aligns its program with applicable AML/counter-terrorist-financing laws and with the requirements of its licensed payment and financial partners. Reback itself is not a bank.
The specific laws, regulators, and licences or registrations that apply to Reback in each country, and the identity of the responsible regulated entity or partner, are [to be confirmed by legal/compliance].
3. Customer due diligence and verification tiers
We verify the identity of the people and businesses that use Reback before allowing full access to funds-related features. Verification is risk-based and tiered: higher transaction and balance limits require a higher verification level. In our African markets we operate tiered customer due diligence (from an unverified starting level up through higher tiers); in the United States, United Kingdom and Germany we operate a risk-based customer identification and due-diligence model with enhanced due diligence where risk is higher.
Verification is time-limited and must be renewed periodically (currently on the order of every 24 months), and we may require re-verification or additional information at any time based on risk.
4. Identity information we verify
Depending on your country, verification level and whether you are an individual or a business, we may collect and verify:
| Country | Examples of identity / business information |
|---|---|
| Nigeria | BVN, NIN, government photo ID, proof of address; business: CAC/RC number |
| Ghana | Ghana Card, SSNIT, proof of address; business: RGD registration |
| Kenya | National ID, KRA PIN, proof of address; business: BRS registration |
| South Africa | SA ID, proof of address; business: CIPC registration |
| United States | SSN/ITIN and government ID (risk-based); business: EIN |
| United Kingdom | Passport and proof of address; business: Companies House |
| Germany | Personalausweis and proof of address; business: Handelsregister |
We also collect a live selfie for a liveness/face check, and we may verify beneficial owners for business accounts. Identity verification is performed with the help of specialist providers — QoreID in our African markets and Sumsub in the United States, United Kingdom and Germany. How this data is handled is described in our Privacy Policy.
5. Sanctions and PEP screening
We screen users and, before funds leave the platform, payout beneficiaries against sanctions and watchlists, and we consider politically-exposed-person (PEP) status as part of our risk assessment. Screening is designed to fail closed: if a match is found, or if screening cannot be completed, the payout is blocked and the event is recorded for review.
Our screening is architected to use recognised sanctions and watchlist sources (such as OFAC, UN and EU lists) and PEP data. The exact list sources and data feeds active in production, and their update cadence, are [to be confirmed by compliance].
6. Ongoing transaction monitoring
We monitor activity for signs of financial crime and fraud. Signals include mismatches between device-GPS location and IP location, unusual transaction patterns, and other risk indicators. Device location is required for certain money-moving actions (see our Terms). Where risk is identified, we may request more information, apply holds or limits, pause or block a transaction or payout, or restrict an account.
7. Record keeping
We keep identity-verification records and transaction records for the periods required by law and by our partners. Fund movements and dispute decisions are written to an append-only, tamper-evident audit ledger. Retention of financial and verification records typically continues for a period after your relationship with Reback ends; see the retention section of our Privacy Policy.
8. Reporting and cooperation
Where required, we report suspicious activity to the relevant authorities and cooperate with law enforcement, regulators and our financial partners. Laws may prohibit us from telling you when a report has been made. We may decline, suspend or terminate a relationship where we cannot meet our AML obligations.
The specific reporting obligations and thresholds that apply to Reback in each country are [to be confirmed by legal/compliance].
9. Governance
Our AML program is intended to be overseen by a designated compliance function with appropriate independence and authority.
The appointment and contact details of a Money Laundering Reporting Officer (MLRO) / compliance officer, and the program’s governance and independent-review arrangements, are [to be confirmed by legal/compliance].
10. Your obligations
You must provide accurate, truthful information, complete verification when asked, and not use Reback to facilitate money laundering, terrorist financing, sanctions evasion or any other financial crime, as set out in our Acceptable Use Policy. Providing false information or attempting to evade these controls is a serious breach of our Terms.
11. Contact
For questions about this statement, contact us through the Reback support portal or the Reback support portal.