AML / KYC policy
This page explains how Spirit AI verifies who its clients are and how it works to prevent its services being used for money laundering or the financing of crime. It is written for a normal reader, not a compliance officer, but it reflects the standards we operate by.
1. Introduction
Spirit AI applies Know Your Customer (KYC), Anti Money Laundering (AML) and, where applicable, counter terrorist financing (CTF) procedures. The purpose is simple: to make sure every client is a real person acting in their own name, to keep fraudsters and stolen identities out, and to meet the verification and reporting obligations that apply to our activity in Ghana. Verification protects honest clients most of all, because it is what allows us to refuse the criminals who would otherwise share the same system with you.
2. What KYC is
KYC (Know Your Customer) is the process of confirming the identity of each client and checking that the details they give are true and current. In practice it means collecting your legal name, date of birth, address and contact details, and checking them against an official document. Once your identity is confirmed, we also keep the information up to date, because identities change: people move house, change phone numbers and renew passports.
3. What AML means
AML (Anti Money Laundering) is the set of measures designed to stop the flow of money obtained through crime being cleaned through financial services. It includes assessing the risk each client relationship presents, monitoring transactions for patterns that do not match what we know about the client, and reporting genuinely suspicious activity through the proper channels. Screening against sanctions and politically exposed person lists is part of the same framework.
4. Why identity verification is required
Verification serves four purposes. It prevents fraud, because an impostor with your name but not your documents cannot open an account in your place. It protects accounts, because a verified identity is the anchor for recovery if you ever lose access. It keeps the platform compliant with the requirements applicable to our activity in Ghana, which preserves the service for everyone. And it reduces financial risk for all clients by making the platform an unattractive place for criminal money.
5. Documents we ask for
To confirm identity, we accept a valid government issued document with your photo: a Ghana Card, a passport or a driving licence. To confirm address where it is required, we accept a recent utility bill, a bank statement or an official letter showing your name and address. Where a check is inconclusive, we may ask for a short selfie or live video (a liveness check) to confirm that you are the person in the document. We only ask for documents we actually use; nothing is collected "just in case".
6. The verification process, step by step
The process runs in five short steps. First, you register and enter your personal details. Second, you upload the document or documents requested. Third, automatic checks compare the document with the details you entered and examine the document for signs of tampering. Fourth, if anything is unclear, a trained reviewer looks at it manually; most files never need this. Fifth, you receive the result: confirmed, or rejected with the reason stated, and with the option to submit a better image or a different document where that is the issue.
7. Enhanced due diligence
Some situations call for enhanced due diligence (EDD): large deposits relative to our normal client profile, complex ownership structures, clients resident in higher risk jurisdictions, or activity that does not match the pattern we would expect. EDD can mean extra documents, questions about the source of funds, or approval from a senior compliance officer before trading is activated. It is not an accusation; it is proportionate caution applied to a minority of files.
8. How long verification takes
Most standard checks complete within one business day, and many within an hour, because document reading is largely automatic. Manual review adds time: a file examined by a person is normally concluded within one to three business days. The process can take longer when documents are of poor quality, when names differ between documents, or during EDD. In every case you can see the current status on your dashboard, and you will be told what, if anything, is needed from you.
9. Reasons verification can be refused
A file can be rejected or suspended for reasons that include: an expired or invalid document; an unreadable photo of a document; details that do not match between the document and the registration form; suspicion that a document is forged or altered; refusal to provide information lawfully requested; a match against sanctions lists; or an unexplained inconsistency in the account's activity. Where the reason is curable, a fresh document or a correction is all that is needed; we always state the reason rather than leaving you to guess.
10. Transaction monitoring
Once an account is active, monitoring continues. Deposits, withdrawals and trading patterns are compared with what we know about you, and genuinely unusual activity is examined. Where the situation warrants it, certain functions, most commonly withdrawals, can be restricted while we ask questions. Monitoring is proportionate: normal clients trading normal amounts will never notice it, because it exists for the exceptions, not for you.
11. Your responsibility as a user
You are responsible for giving accurate, current and genuine information, and for updating it when it changes. Registering under another person's name, using invented details or sharing a single account between several people are breaches of these terms and can lead to the account being frozen and the relationship ended. If you notice an error in your details, tell us early: a small correction is a five minute matter, while a discrepancy discovered later looks, to a monitoring system, exactly like something else.
12. Storage and protection of verification data
Verification documents and the records around them are stored encrypted, with access limited to the compliance staff who must see them, and every access is logged. We keep verification records only as long as the law requires and the purpose needs, after which they are securely destroyed. The full detail of how all personal data is handled, including retention periods and your rights, is in our Privacy Policy.
13. When data can be transferred
To run verification we share the minimum necessary data with categories of recipients that include identity verification providers, IT service providers who host and secure the systems, affiliated companies within our group where they process on our instructions, and regulators or other authorities where disclosure is required by law. Every recipient is bound by contractual confidentiality and security obligations, and no data is sold, ever.
14. Compliance with applicable requirements
Spirit AI performs its verification activity with reference to the legal and regulatory requirements applicable to it in Ghana, including client verification and data protection obligations under the Data Protection Act, 2012 (Act 843). Where our activity touches payment services or securities market conduct, we take the applicable requirements of the Bank of Ghana and the Securities and Exchange Commission into account. The current regulatory standing is summarised on the Licensing and Regulation page.
15. Contact for KYC and AML questions
If you have a question about verification, a stuck file, or any part of this policy, write to [email protected] with the subject "KYC". The Client Support and Compliance Team answers these queries during Monday to Friday, 8:00 to 18:00 GMT (excluding public holidays), and status questions about an ongoing check are normally answered usually within one business hour.