Legal & Compliance

AML Policy & Risk Disclosure

Last updated: May 2026  ·  Kowry Technologies Ltd  ·  Company No. 17202314

⚠ Important: Using the Kowry platform for money laundering, terrorist financing, or any financial crime is strictly prohibited and will be reported to relevant authorities. All accounts are subject to ongoing monitoring.

Part A — Anti-Money Laundering (AML) Policy

A1. Our Commitment

Kowry Technologies Ltd is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We operate in accordance with:

A2. Know Your Customer (KYC)

All users must complete identity verification before accessing full platform functionality. Our tiered KYC process includes:

We use third-party identity verification providers to validate documents. KYC information is retained for a minimum of 5 years from the end of the business relationship as required by law.

A3. Transaction Monitoring

All transactions on the Kowry platform are subject to automated and manual monitoring. We flag and investigate:

A4. Suspicious Activity Reporting

Where we identify suspicious activity, we are legally required to submit a Suspicious Activity Report (SAR) to the UK National Crime Agency (NCA) and/or relevant authorities in applicable jurisdictions. We are prohibited by law from informing users ("tipping off") when such a report has been made.

A5. Sanctions Screening

All users and transactions are screened against international sanctions lists, including:

Accounts matching sanctioned individuals or entities will be frozen immediately and reported to the relevant authority.

A6. Politically Exposed Persons (PEPs)

Users identified as Politically Exposed Persons (PEPs) or their close associates are subject to Enhanced Due Diligence (EDD), including additional documentation requirements and senior management approval before account activation.

A7. High-Risk Jurisdictions

We apply Enhanced Due Diligence to transactions involving jurisdictions identified as high-risk by the FATF or UK government. We do not onboard users from jurisdictions subject to comprehensive international sanctions.

A8. Record Keeping

We maintain records of all customer due diligence, transactions, and compliance decisions for a minimum of 5 years as required under MLR 2017. These records are available to regulatory authorities upon request.

A9. Compliance Officer

Kowry has designated a Money Laundering Reporting Officer (MLRO) responsible for overseeing our AML/CTF programme, receiving internal suspicion reports, and making SARs to the NCA where required. Contact: compliance@kowry.io

A10. Staff Training

All Kowry staff with access to customer data or transaction systems receive AML training upon joining and on an ongoing basis. We maintain training records and assess competency regularly.

Part B — Risk Disclosure

The following risks are not exhaustive. You should seek independent financial and legal advice before using Kowry's services. Only use funds you can afford to lose.

B1. Key Risks

Currency Risk

Exchange rates fluctuate constantly. The value of your holdings in any currency can decrease, sometimes significantly, due to market movements, political events, or economic factors.

Digital Asset Risk

Digital assets are highly volatile and largely unregulated. Their value can fall to zero. They are not legal tender and are not covered by the UK Financial Services Compensation Scheme (FSCS).

Liquidity Risk

In certain market conditions, it may be difficult or impossible to execute transactions at quoted prices. P2P trades depend on counterparty availability.

Regulatory Risk

Laws governing digital assets and cross-border payments are evolving rapidly. Regulatory changes may restrict or prohibit certain services in your jurisdiction without notice.

Technology Risk

Platform outages, cyberattacks, software bugs, or mobile money network failures may temporarily prevent access to your funds or cause transaction errors.

Counterparty Risk

In P2P transactions, Kowry acts as escrow but cannot guarantee the solvency or good faith of counterparties beyond our escrow and dispute resolution procedures.

Operational Risk

Errors in transaction amounts, destination addresses, or mobile money numbers may result in irreversible loss of funds. Always verify transaction details carefully before confirming.

Earn / Yield Risk

Returns on Earn products are variable and not guaranteed. They depend on market conditions and the underlying yield mechanisms, which may change or fail.

B2. No Financial Advice

Nothing on the Kowry platform constitutes financial, investment, legal, or tax advice. All content is provided for informational purposes only. You are solely responsible for your financial decisions. We strongly recommend seeking independent professional advice before making any significant financial transaction.

B3. No FSCS Protection

Kowry Technologies Ltd is not currently authorised by the UK Financial Conduct Authority (FCA) as a regulated financial institution. Funds held on the Kowry platform are not protected by the UK Financial Services Compensation Scheme (FSCS). You may lose funds held on the platform in the event of Kowry's insolvency.

B4. Mobile Money Risks

Mobile money services (M-Pesa, MTN MoMo, Airtel Money, Orange Money) are operated by third-party providers. Kowry is not responsible for outages, errors, or transaction failures caused by these third-party networks. Always confirm receipt of funds through your mobile money provider independently.

B5. Reporting Concerns

If you suspect financial crime, fraud, or misuse of the Kowry platform, report it to us at compliance@kowry.io. You can also report directly to:

Contact

Kowry Technologies Ltd — Compliance Team
66 Paul Street, London, EC2A 4NA, United Kingdom
Email: compliance@kowry.io
Company No. 17202314 — Registered in England & Wales