Summary of the anti-money laundering and counter-terrorist financing programme operated by Kyvra Ltd. The full programme is available to acquirers, auditors and regulators on request.
Scope and governance
The programme applies to all merchants, payouts and staff. A nominated officer reports to the board quarterly.
Risk assessment
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Merchant due diligence
Identity and ownership verification for all owners over 25%, licence checks for regulated verticals and source-of-funds enquiries where indicated.
Ongoing monitoring
Transaction monitoring rules per vertical, chargeback and refund ratio review, and periodic refresh of merchant files.
Sanctions and PEP screening
Every merchant, owner and payout recipient is screened against UK, EU, UN and OFAC lists at onboarding and on each list update.
Reporting
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Record keeping
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Training
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