AML, KYC, and Fraud Policy

Version: v1 draft Status: Internal/user-facing hybrid draft for Nigerian counsel, compliance, provider, and operations review

This policy explains why ZenWave may require verification, limit payment features, and investigate suspicious activity. It is not legal advice.

V1 Position

ZenWave v1 should avoid acting as an unlicensed holder of customer funds or issuer of stored value. Payment and wallet features should run through licensed providers where required and remain behind launch gates until legal, provider, compliance, fraud, and reconciliation readiness is approved.

KYC and Trust Checks

ZenWave may request phone, email, identity, business, payout account, name-match, location, device, or additional checks before allowing higher-risk actions.

Users must not provide false identity information, use someone else's documents, use mule accounts, rent verified accounts, or hide beneficial ownership of a business profile.

Fraud Monitoring

ZenWave may review transactions, support tickets, reports, account behavior, device signals, payment-provider responses, chargebacks, and sanctions/fraud indicators.

Where necessary, ZenWave may block, delay, reverse, hold, or restrict accounts and payment features.

Suspicious Activity

Potentially suspicious activity includes scams, impersonation, account takeover, fake payment proof, phishing, rapid movement of funds, unusual payout behavior, linked banned accounts, forged documents, sanctions concerns, or attempts to evade provider rules.

Provider and Regulatory Cooperation

ZenWave may cooperate with payment providers, banks, lawful regulators, the NFIU reporting framework, law-enforcement agencies, and competent authorities where required or appropriate.

User Support

If a restriction was applied by mistake, users can contact support-intl@zenwaveng.com. Some details may not be disclosed where doing so could undermine fraud controls, legal obligations, or user safety.