AML & KYC Policy

PeerMarkt is committed to preventing money laundering, terrorist financing, and sanctions evasion through a robust, risk-based compliance program aligned with FATF Recommendations and applicable national laws across all operating jurisdictions. This public summary describes our approach to Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.

We operate a risk-based tiered verification model. Higher trading volumes require more comprehensive verification.

Where technically available, we verify national IDs directly against government databases (e.g., NIMC API for Nigeria, NIA API for Ghana) to reduce fraud. We store cryptographic hashes of document images where permissible under local law to minimize sensitive data exposure.

All users and transactions are screened against the following lists on account opening, on each transaction, and when lists are updated:

• OFAC Specially Designated Nationals (SDN) list and consolidated list
• UN Security Council consolidated sanctions list
• EU consolidated sanctions list
• UK HM Treasury financial sanctions list
• Nigeria: EFCC watchlist and NFIU designated persons list
• South Africa: FIC targeted financial sanctions list
• Kenya: ARC and CBK sanctions designations
• FATF high-risk and other monitored jurisdictions list
• International PEP databases (current and former senior officials globally)
• Adverse media screening (negative news from reputable sources)

Blockchain wallet addresses are screened using forensics tools against known criminal wallets (mixers, darknet markets, ransomware, exchange hacks) before crediting deposits or processing withdrawals.

We operate automated transaction monitoring that flags the following for compliance review:

• Structuring — multiple transactions below reporting thresholds from a single account within a 24-hour period (total exceeding USD 900)
• Volume spikes — weekly volume increasing by more than 300% compared to prior 4-week average
• Velocity — more than 5 trades in 24 hours for accounts less than 30 days old
• Geographic anomalies — IP address inconsistent with KYC country; VPN or Tor usage detected
• Dormancy then activity — account inactive for 90+ days followed by sudden high-volume activity
• Round-number patterns — repeated transactions at exactly USD 5,000, USD 10,000 etc.
• Rapid cycle — deposit followed immediately by withdrawal pattern
• High-risk wallet sources — incoming funds from addresses flagged by blockchain analytics

For transfers at or above applicable thresholds, we collect and transmit originator and beneficiary information in compliance with FATF Recommendation 16 (Travel Rule):

For transfers to unhosted (self-custody) wallets above threshold, we collect and verify beneficiary information and apply a risk-based approach to verification.

We file Suspicious Transaction Reports (STRs) / Suspicious Activity Reports (SARs) with relevant Financial Intelligence Units when we have knowledge, suspicion, or reasonable grounds to suspect money laundering, terrorist financing, or sanctions violations:

We retain all compliance records for a minimum of 5 years from the date of transaction or account closure, whichever is later. This includes:

• All KYC documents and verification outcomes
• Complete transaction records including wallet addresses, amounts, timestamps, and counterparties
• Sanctions screening results and compliance investigation records
• All SAR/STR filings and supporting documentation
• Travel Rule information
• Dispute resolution records
• Staff training records

Records are maintained in encrypted storage and are available to competent authorities within 3 business days of a lawful request (48 hours for priority regulatory requests).