KYC & AML Policy

Customers from non-restricted countries may apply where SYENU has enabled onboarding. Approval is not automatic: KYC, sanctions, local-law eligibility and risk controls apply. FATF Grey List status triggers risk-based review rather than automatic exclusion.

This public policy explains the main customer-facing elements of SYENU’s Know Your Customer (KYC), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), AML/CFT, sanctions, fraud-prevention and Travel Rule programme. Confidential detection rules and thresholds are not disclosed.

Customers must complete the verification required for their account before using deposit, trading, withdrawal or other financial functions enabled by SYENU.

• Full legal name, date of birth, nationality and country of residence.
• Email, mobile number and residential address.
• Government-issued identity document and document details.
• Selfie, face matching and liveness verification.
• Tax residency and TIN/tax reference information where required.
• Purpose of account and source of funds.
• Source of wealth and documentary evidence where EDD is required.
• Bank-account details for fiat services.
• Wallet, blockchain transfer, originator/beneficiary and VASP information.

SYENU intends to use Sumsub for identity/document verification, liveness and face matching, sanctions/PEP/watchlist screening, AML/CFT controls, fraud/device signals, transaction monitoring, crypto wallet screening, Travel Rule processing and VASP/CASP identification. Supplementary providers may also be used.

SYENU screens customers against applicable sanctions and jurisdiction restrictions. Persons subject to asset freezes, sanctions or terrorism-related restrictions, and residents of jurisdictions designated as Restricted by SYENU, may not use the Services. The current jurisdiction policy is published separately and may be updated.

SYENU considers FATF statements and other authoritative risk indicators. A jurisdiction subject to FATF countermeasures or serious sanctions may be prohibited. A jurisdiction under FATF increased monitoring is not automatically prohibited; customers may be subject to EDD, enhanced monitoring, additional source-of-funds checks or lower limits.

Potential PEP or watchlist matches may be manually reviewed. Where required, SYENU may obtain source-of-wealth/source-of-funds information, senior approval or enhanced ongoing monitoring.

All customers may be asked to state the source of funds. Higher-risk, higher-value or unusual activity may require evidence such as bank statements, payslips, business documents, tax records, wallet evidence or exchange statements.

KYC continues after onboarding. SYENU may monitor account behaviour, fiat activity, blockchain transfers, wallet exposure, device/location signals, changes in sanctions/PEP status and other relevant indicators.

Blockchain analytics may be used to detect exposure to theft, fraud, scams, sanctioned addresses, illicit markets, mixers/tumblers, terrorist-financing indicators or other high-risk activity.

Where applicable, SYENU may collect, verify, send, receive and retain originator, beneficiary, wallet and sending/receiving VASP information. A transfer may be delayed or rejected until required information is complete.

SYENU may ask whether a wallet is controlled by the customer or another person and may request ownership or beneficiary information where required by law or risk controls.

Re-verification may be required after identity-document expiry, account information changes, country/residence changes, security events, unusual activity, material risk changes or regulatory updates.

• Approved / Verified.
• Resubmission or additional information requested.
• Manual compliance review.
• Enhanced Due Diligence.
• Temporary transaction or withdrawal restriction.
• Rejection, suspension or closure where required by law, risk policy or the Terms.

Residents of countries not on SYENU’s Restricted Jurisdictions list may apply where onboarding has been enabled, but use remains subject to local law, product availability and SYENU approval. South Africa is the initial active fiat market. International accounts may have crypto-only functionality and do not automatically receive ZAR or other fiat services.

Kenya is a planned expansion market. KES services and any Kenya-specific exchange functionality will not be treated as active until SYENU publishes an official launch notice and any required local terms. Kenya’s FATF monitoring status, if applicable at the time, will be addressed through risk-based controls and does not by itself constitute an automatic prohibition.

Customers must provide accurate information and must not use false documents, another person’s identity, third-party accounts, structuring, false location data or other methods to circumvent SYENU controls.

KYC and verification questions may be sent to h1ihe1ir2l1jl1jbot81@1js1k5y1fz6e1gn1gju1gt5.1hc1hdo1hn4m.