KYC & AML Policy

This policy explains how Starbiss LTD verifies users and manages compliance on Cominy.

Effective Date: September 1, 2026

Cominy is operated by Starbiss LTD, a company registered in the Federal Republic of Nigeria.

This policy explains how we verify users and help prevent fraud, money laundering, terrorism financing, and other unlawful activities on Cominy.

1. Identity Verification

Cominy may require users to complete identity verification before accessing certain features.

Verification may require:

• legal name and date of birth;
• government-issued ID number;
• photograph or scan of a valid ID;
• live selfie or liveness verification; and
• other information reasonably required for verification.

We may use approved third-party providers to verify identity documents, perform facial matching, and conduct liveness checks.

Submitting false information, another person's ID, altered documents, or manipulated selfies is prohibited.

2. Customer Due Diligence

We may review user information and account activity to understand and manage risk.

For higher-risk accounts or transactions, we may request additional information such as proof of address, source of funds, business information, or supporting documents.

We may also screen users against relevant sanctions, watchlists, or politically exposed person databases where appropriate.

3. Transaction Monitoring

Cominy may monitor activity for suspicious or fraudulent behaviour, including:

• unusual or high-value transactions;
• use of stolen payment methods;
• multiple accounts linked to the same identity;
• suspicious withdrawals or payouts;
• misuse of bill-payment or VTU services;
• campaign or reward manipulation; and
• attempts to avoid limits or verification requirements.

4. Suspicious Activity

Where we reasonably suspect fraud, money laundering, terrorism financing, or other unlawful activity, we may:

• request additional information;
• delay or restrict transactions;
• limit withdrawals or other features;
• suspend or terminate an account;
• retain relevant records; or
• report information to competent authorities or regulated service providers where required by law.

5. Prohibited Use

You must not use Cominy to:

• launder or conceal unlawful funds;
• finance terrorism or prohibited organisations;
• use stolen or unauthorised payment methods;
• impersonate another person;
• evade sanctions or transaction limits;
• disguise the source or destination of funds; or
• carry out fraudulent or unlawful financial activity.

6. Record Keeping

Cominy may retain identity, transaction, and compliance records for as long as required by applicable law, fraud-prevention needs, disputes, or regulatory obligations.

Personal information is handled in accordance with the Cominy Privacy Policy.

7. Third-Party Providers

Cominy may use third-party providers for:

• identity and liveness verification;
• payments and payouts;
• fraud detection;
• sanctions screening; and
• bill-payment and VTU processing.

These providers may perform their own compliance checks and may reject or delay transactions where necessary.

8. Account Restrictions

If you fail to complete required verification, provide false information, or create significant compliance risk, Cominy may restrict or terminate your account or access to certain features.

9. Changes to This Policy

We may update this policy as our services or legal obligations change.

The latest version will always display its effective date.

Last updated: 2026-09-01