AML & KYC Policy

1. Our Approach — and What PropTraka Is Not

PropTraka, a product of PropTraka Ventures, helps landlords, property managers, and agents verify the identity of prospective tenants (know-your-customer screening) and takes reasonable steps to keep the platform from being misused for illicit activity — an approach informed by anti-money-laundering (AML) good practice.

Importantly, PropTraka is not a "reporting institution" under Kenya's Proceeds of Crime and Anti-Money Laundering Act (POCAMLA). PropTraka does not accept deposits, hold or move client funds, or operate as a financial institution — payments are processed by licensed providers such as Safaricom (M-Pesa via Daraja) and Paystack — and it is not a designated real-estate agency. PropTraka therefore does not carry AML/CFT transaction-monitoring, suspicious-transaction-reporting, enhanced-due-diligence, or politically-exposed-person screening obligations. The measures described below are good-practice identity screening and fraud prevention, not a regulated AML programme.

Personal data collected for verification is handled under the Kenya Data Protection Act, No. 24 of 2019; PropTraka Ventures is registered with the Office of the Data Protection Commissioner (ODPC) as a Data Controller (Reg. No. 684-4423-0396).

2. Identity Verification (KYC)

To support the integrity of our TrustTraka™ screening, landlords may ask prospective tenants (and, where relevant, other users) to complete a verification process, which may include:

• Verification of National ID or Passport.
• KRA PIN format check for tax compliance (live verification via the Kenya Revenue Authority API is rolling out subject to KRA system availability).
• Liveness checks (selfies) to help detect impersonation.
• Corporate documentation for property-management companies.
• Tenant KRA PIN verification for eTIMS invoice generation (optional for residential, recommended for commercial tenancies).
• Applicant identity verification: prospective tenants submit a national-ID photo and a selfie during screening. An AI-powered liveness check compares the selfie to the ID photo to help confirm identity and detect impersonation.

3. Screening Fraud Detection

The screening pipeline includes automated fraud-detection measures to help landlords make informed decisions:

• Duplicate-applicant checking across landlords — to help identify an individual applying under multiple identities. This shares only a match count(how many times an identity has appeared) — never another landlord's name, notes, or decision.
• Application-velocity monitoring — to flag unusually high volumes of applications from a single identity or device.

These checks are non-blocking: they can flag a possible concern, but they do not automatically prevent an applicant from being created — in line with the principle of proportionality.

4. Acceptable Use

• You must not knowingly use PropTraka for money laundering, terrorism financing, or any other illicit activity. Money laundering is a criminal offence under POCAMLA.
• Providing false, misleading, or incomplete verification information may result in suspension or termination of your account.
• If you notice activity by a tenant, counterparty, or other user that appears fraudulent or unlawful, you can report it to compliance@proptraka.ke or through the in-app reporting mechanism.

5. Cooperation with Authorities

PropTraka cooperates with law-enforcement agencies and regulators in response to lawful requests, and may report activity to the appropriate authorities where it is required to do so by law or where the activity is clearly unlawful. Because PropTraka is not a reporting institution, it does not operate a suspicious-transaction-reporting regime, but it will act responsibly on credible evidence of criminal misuse of the platform.

6. Record Keeping

Verification and financial records are retained as described in our Privacy Policy: tax and financial records are kept for the statutory five-year period (Tax Procedures Act, 2015, s.23), and identity / screening data is kept for a purpose-limited period tied to the screening plus a limited dispute-and-audit window, after which it is deleted. We do not retain this data under a POCAMLA reporting-institution obligation, because PropTraka is not one.