AML & KYC Policy

Codego Group ("Codego"), operator of the Banqa brand, is committed to the prevention of money laundering, terrorist financing and other financial crime. This policy summarises the controls we apply across the Banqa Service.

1. Regulatory framework

We design our controls around international standards (FATF Recommendations), EU AML directives (4AMLD / 5AMLD / 6AMLD), UK MLR 2017 and UAE AML Federal Decree-Law No. 20 of 2018 as applicable to our card-issuing partner.

2. Customer due diligence (KYC)

Before issuing a Banqa card we verify:

• identity — government-issued photo ID + selfie liveness match;
• proof of address — recent utility bill or bank statement;
• sanctions, PEP and adverse-media screening (initial & ongoing);
• source of funds where activity exceeds risk thresholds.

Enhanced due diligence applies to higher-risk customers, jurisdictions or activities.

3. Corporate customers (KYB)

For business cardholders we collect and verify:

• certificate of incorporation, registered address;
• identification of all ultimate beneficial owners (≥25 % ownership / control);
• identification of directors and authorised signatories;
• structure chart, source of wealth, expected activity;
• tax-residency and FATCA/CRS where applicable.

4. Ongoing monitoring

• real-time transaction monitoring with risk-based rules;
• periodic refresh of customer information (every 12–36 months by risk);
• screening against sanctions and PEP updates daily;
• internal escalation and suspicious-activity reporting where required.

5. Prohibited activities

The Banqa Service may not be used for:

• money laundering, terrorist financing, fraud, theft;
• sanctioned countries, entities or persons;
• illegal drugs, weapons, human trafficking;
• unlicensed gambling or financial services;
• child sexual abuse material or any other illegal content;
• darknet markets, mixers, privacy coins where prohibited;
• any other activity prohibited by Codego's risk appetite.

6. Record-keeping

We retain customer-due-diligence records and transaction records for at least 5 years after the end of the business relationship, or longer where required by law.

7. Training & governance

All Codego staff with access to customer data complete mandatory AML and data-protection training. We have a dedicated Money Laundering Reporting Officer (MLRO).

8. Reporting concerns

If you suspect that the Banqa Service is being misused, contact our Compliance team at [email protected]. Reports are handled confidentially.