AML & KYC Policy

1. Commitment to Compliance

PropTraka, a product of PropTraka Ventures, is committed to preventing money laundering and the financing of terrorism in accordance with the Proceeds of Crime and Anti-Money Laundering Act (POCAMLA) of Kenya. As a property management fintech, we maintain strict standards to ensure our platform is not misused for illicit financial activities.

2. Know Your Customer (KYC)

To maintain the integrity of our TrustTraka™ ecosystem, we require all landlords and tenants to undergo a verification process, which may include:

• Verification of National ID or Passport.
• KRA PIN verification for tax compliance.
• Liveness checks (Selfies) to prevent identity theft.
• 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 the screening process. An AI-powered liveness check compares the selfie to the ID photo to confirm the applicant's identity and detect impersonation.

3. Enhanced Due Diligence (EDD)

In addition to standard KYC procedures, PropTraka applies Enhanced Due Diligence for higher-risk situations, including:

• High-Value Transactions: Transactions exceeding KES 1,000,000 or unusual transaction patterns may trigger additional verification requirements.
• Complex Ownership Structures: Properties held through trusts, SPVs, or multi-layered corporate entities may require additional documentation.
• Source of Funds Verification: We may request documentation evidencing the source of funds for property acquisitions or large deposits.
• High-Risk Jurisdictions: Transactions involving parties from jurisdictions identified as high-risk by the Financial Action Task Force (FATF) are subject to enhanced scrutiny.
• Applicant KRA PIN Verification: During the applicant screening process, KRA PINs provided by prospective tenants are verified against the Kenya Revenue Authority API as an enhanced due diligence measure. Only the verification result (valid/invalid) is retained.

PropTraka reserves the right to restrict account functionality pending completion of Enhanced Due Diligence.

4. Politically Exposed Persons (PEPs)

In accordance with POCAMLA and FATF guidelines, PropTraka may in future apply enhanced scrutiny to accounts held by or associated with Politically Exposed Persons (PEPs). As our compliance infrastructure matures, this will include:

• Identification of current or former senior government officials, senior executives of state-owned enterprises, and their immediate family members or close associates.
• Enhanced monitoring of account activity and transactions.
• Senior management approval for establishing or continuing business relationships with PEPs.

PEP status does not preclude the use of PropTraka. Additional safeguards will apply as these capabilities are implemented.

5. Transaction Monitoring

PropTraka employs automated monitoring tools to detect unusual transaction patterns, high-value cash deposits (where applicable), or suspicious mobile money reconciliation activities. This includes monitoring eTIMS invoice patterns for anomalous behaviour such as duplicate invoicing, excessive credit notes, or invoices issued to unverified KRA PINs. We reserve the right to flag and report suspicious activities to the Financial Reporting Centre (FRC) of Kenya.

Applicant Fraud Detection: The screening pipeline includes automated fraud detection measures such as duplicate applicant checking across landlords (to identify individuals applying under multiple identities) and application velocity monitoring (to flag unusually high volumes of applications from a single identity or device). All checks are non-blocking — they flag potential concerns but do not automatically prevent applicant creation, in line with the principle of proportionality.

6. Customer Reporting Obligations

As a user of PropTraka, you have the following obligations:

• You must not knowingly use PropTraka for money laundering, terrorism financing, or any other illicit financial activity.
• You should report any suspicious activity by tenants, counterparties, or other users that may indicate money laundering or fraud.
• Reports can be submitted to compliance@proptraka.ke or through the in-app reporting mechanism.

PropTraka is required by law to file Suspicious Transaction Reports (STRs) with the Financial Reporting Centre (FRC) when statutory thresholds or red-flags are met. We are prohibited from informing users that an STR has been filed regarding their account ("tipping off").

7. Sanctions Screening

As our compliance programme evolves, we intend to screen users against local and international sanctions lists to ensure compliance with global financial regulations. This capability is planned and will be disclosed when implemented.

8. Penalties for Non-Compliance

Non-compliance with our AML & KYC requirements may result in:

• Account Restrictions: Provision of false, misleading, or incomplete KYC information may result in immediate suspension or termination of your account.
• Criminal Penalties: Money laundering is a criminal offence under POCAMLA, punishable by imprisonment of up to 14 years and/or a fine of up to KES 5,000,000.
• Cooperation with Authorities: PropTraka cooperates fully with law enforcement agencies and regulatory bodies upon receipt of lawful requests.
• Account Freezing: We may freeze account functionality if suspicious activity is detected, pending investigation by the relevant authorities.

9. Record Keeping

In line with POCAMLA requirements, we maintain records of all identity verification documents and financial transactions for a minimum of 7 years after the termination of the business relationship.