1. Our commitment
Zelo is committed to preventing money laundering (ML), terrorism financing (TF), fraud, sanctions evasion, and any other illegal use of the Platform. We apply a risk-based programme that combines mandatory identity verification, continuous transaction monitoring, sanctions screening, and timely reporting of suspicious activity to relevant authorities.
This policy applies to every user, every transaction, and every staff member. It is reviewed at least annually and updated whenever the regulatory landscape or our risk profile changes.
2. KYC verification
Every user must complete Know Your Customer (KYC) verification before performing any wallet activity. The standard KYC pack includes:
- A valid government-issued photo ID (passport, national ID, or driving licence);
- A live selfie taken at the time of submission;
- A recent address proof not older than three months.
Documents are reviewed by trained compliance staff. Where verification cannot be completed, the account is placed in a restricted state and may be terminated.
3. Risk-based approach
We classify each user into a risk band (low, medium, high) based on factors such as country of residence, KYC document quality, transaction patterns, and adverse-media findings. Higher-risk users are subject to enhanced due diligence, lower transaction limits, and more frequent reviews.
4. Transaction monitoring
All transactions are recorded in an immutable ledger and continuously monitored for suspicious patterns including:
- Unusual transfer velocity or amounts inconsistent with the user's profile;
- Rapid splitting of large amounts into smaller transfers (structuring);
- Atypical settlement requests, particularly to newly added payout destinations;
- High-volume coupon redemption from disposable or pooled sources;
- Inbound transfers from accounts that have themselves been flagged.
Triggered alerts are reviewed by compliance staff and either cleared, escalated, or actioned (account freeze, request for additional information, or report to authorities).
5. Sanctions screening
We screen all users at onboarding and periodically thereafter against widely used international sanctions and politically-exposed-person (PEP) lists. We do not knowingly serve users on sanctions lists. Settlement requests to sanctioned counterparties or destinations are blocked.
6. Reporting suspicious activity
Where we identify activity that we know, suspect, or have reasonable grounds to suspect involves the proceeds of crime, terrorism financing, or sanctions evasion, we will file a Suspicious Transaction Report (STR) with the appropriate authority and may freeze the account during investigation.
7. Recordkeeping
We retain KYC documents, transaction records, monitoring alerts, and STRs for the period required by applicable law (typically a minimum of five years from the date of the transaction or account closure, whichever is later).
8. Staff training
All staff with access to user data or compliance systems receive role-appropriate AML/CFT training at hire and refresher training at least annually. Training covers red flags, escalation procedures, sanctions, and data protection.
9. Account freezes and terminations
We may, without prior notice, freeze any account or reject any transaction where we suspect a breach of this policy. Frozen funds are held pending investigation. Where unlawful conduct is confirmed, the account will be terminated and the funds dealt with in accordance with applicable law.
10. Cooperation with authorities
Zelo cooperates fully with lawful requests from regulators, law-enforcement agencies, and courts, subject to applicable due process. Where permitted, we will notify the affected user; in some cases (for example, where tipping off is prohibited) we are required to keep the request confidential.
11. Contact
To report suspicious activity or to contact our compliance team, email care@zelopay.online. Reports may be made anonymously.