Kini Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Last Updated: 24 August 2026

Kini is committed to providing a safe, transparent and responsible platform for families to fund and coordinate care for aging loved ones.

Because Kini enables contributors, including people living outside South Africa, to make payments that are used to purchase care-related products and services for beneficiaries in South Africa, we take measures to prevent our platform from being used for fraud, money laundering, terrorist financing, sanctions evasion or other financial crime.

This policy explains the measures Kini may use to identify customers, understand transactions, verify beneficiaries and third-party recipients, and identify activity that may require further review.

1. Purpose of this Policy

The purpose of this policy is to:

• Prevent Kini from being used to facilitate financial crime.
• Verify the identity of customers and, where appropriate, beneficiaries and other parties involved in a transaction.
• Understand the purpose and nature of transactions conducted through the Kini platform.
• Identify unusual, suspicious or potentially fraudulent activity.
• Apply appropriate controls based on the level of risk associated with a customer, transaction or relationship.
• Comply with applicable South African laws and regulations relating to financial crime, sanctions and consumer protection.

Kini applies a risk-based approach, meaning that additional verification may be required where a customer, transaction or activity presents a higher level of risk.

2. How Kini Uses Customer Payments

Kini is a family care coordination platform.

Customers may use Kini to contribute towards the care of an aging family member and to purchase approved care-related products and services, including vouchers and services provided by third-party partners.

Examples include:

• Grocery vouchers.
• Pharmacy and healthcare vouchers.
• NetcarePlus or other approved healthcare-related products.
• Prepaid electricity.
• Airtime.
• Other approved care-related products and services.

Kini is not intended to be used as a general-purpose money transfer, cash withdrawal, remittance or digital wallet service.

Where applicable, funds received through Kini are applied to the customer's designated Care Pool and used to facilitate the purchase or fulfilment of the selected care-related product or service.

3. Know Your Customer (KYC)

Kini may collect and verify information about customers when they register, make payments or use certain features of the platform.

Depending on the nature and risk of the transaction, this may include:

• Full name.
• Date of birth.
• Residential or billing address.
• Email address.
• Telephone number.
• South African identity number or passport details.
• Country of residence.
• Payment information.
• Information relating to the purpose of the Care Pool.
• Relationship to the beneficiary.
• Other information reasonably required to verify identity or assess risk.

The level of information requested may vary depending on the customer's circumstances, transaction value, payment method and risk profile.

4. Beneficiary Verification

Because Kini is designed to help one family member support another, the person making the payment and the person receiving the care-related benefit may be different individuals.

Where appropriate, Kini may therefore verify information relating to the beneficiary.

This may include:

• Full name.
• Contact information.
• Relationship to the contributor.
• South African residential or delivery information.
• Other information reasonably necessary to confirm the beneficiary and intended purpose of the transaction.

Kini may request additional information where the relationship between the contributor and beneficiary is unclear or where a transaction presents an increased risk.

5. Third-Party Service Providers

Kini may purchase or facilitate care-related products and services from approved third-party providers.

These may include voucher providers, retailers, pharmacies, healthcare providers, utility providers and other service providers.

Kini will take reasonable steps to ensure that third-party providers used within the platform are legitimate and appropriate for the services being provided.

Where a transaction involves payment or fulfilment to a third party, Kini may retain information necessary to demonstrate:

• Who made the payment.
• Who the intended beneficiary is.
• What product or service was purchased.
• The value of the transaction.
• The date of the transaction.
• The relevant third-party provider.
• The purpose of the transaction.

6. Source and Purpose of Funds

Kini may request information about the purpose or source of funds where this is reasonably necessary to assess risk.

Customers may be asked to provide additional information or supporting documentation where:

• A transaction is unusually large or inconsistent with the customer's normal activity.
• Multiple unusual transactions occur.
• A payment appears to be made on behalf of an unrelated third party.
• The source or purpose of funds cannot reasonably be established.
• Information provided by the customer cannot be verified.
• A transaction appears inconsistent with the intended use of the Kini platform.

Kini may restrict or delay a transaction while additional information is being reviewed.

7. Risk-Based Transaction Monitoring

Kini may monitor transactions and account activity for indicators of fraud, money laundering, terrorist financing, sanctions evasion or other financial crime.

Monitoring may consider factors such as:

• Transaction value.
• Transaction frequency.
• Changes in normal customer behaviour.
• Multiple payment attempts.
• Multiple payment methods.
• Unusual beneficiary relationships.
• Unusual geographic activity.
• Payments involving higher-risk jurisdictions.
• Attempts to circumvent Kini's controls.
• Unusual cancellation or refund activity.
• Transactions that do not appear consistent with the stated purpose of the Care Pool.

Monitoring does not mean that every transaction will be manually reviewed.

8. Enhanced Due Diligence

Where Kini identifies a higher-risk customer, beneficiary, transaction or relationship, we may conduct additional checks.

Enhanced due diligence may include:

• Requesting additional identification documents.
• Requesting proof of address.
• Requesting information about the source of funds.
• Requesting information about the relationship between the contributor and beneficiary.
• Reviewing transaction history.
• Requesting supporting documentation relating to the intended care expense.
• Obtaining additional information from reliable and independent sources.
• Requiring additional internal approval before a transaction can proceed.

Kini may decline to provide or continue a service where the relevant information cannot be satisfactorily verified.

9. Sanctions and Prohibited Persons

Kini may screen customers, beneficiaries and other relevant parties against applicable sanctions and restricted-party lists.

South Africa's Financial Intelligence Centre maintains a Targeted Financial Sanctions system and searchable list of designated individuals and entities.

Kini will not knowingly provide services, process transactions or make funds or economic resources available where doing so would breach applicable sanctions or other legal restrictions.

Where a potential sanctions match is identified, Kini may suspend the relevant transaction while the match is investigated.

10. Politically Exposed Persons (PEPs)

Kini may identify whether a customer, beneficiary or relevant person is a politically exposed person (PEP), family member or known close associate where required by applicable law or where relevant to Kini's risk assessment.

Being identified as a PEP does not automatically mean that a customer cannot use Kini.

However, higher-risk relationships may be subject to enhanced due diligence and additional approval.

11. Suspicious or Unusual Activity

Kini may investigate transactions or activity that appears suspicious, unusual or inconsistent with the customer's stated purpose.

Examples may include:

• Payments that appear unrelated to family care.
• Attempts to use Kini as a mechanism to transfer cash between unrelated parties.
• Unusual patterns of payments followed by cancellation or refund requests.
• Transactions involving potentially fraudulent payment methods.
• Attempts to conceal the identity of the contributor or beneficiary.
• Transactions structured to avoid Kini's verification controls.
• Activity that may indicate fraud, money laundering, terrorist financing or sanctions evasion.

Where required by applicable law, Kini may report suspicious or unusual activity to the relevant authorities.

Kini will not disclose information about a report or investigation where disclosure is prohibited by law.

12. Payment Fraud

Payments made through Kini may be subject to fraud and payment-security checks.

Kini may:

• Decline suspicious payments.
• Request additional verification.
• Temporarily hold a transaction for review.
• Restrict an account.
• Cancel a transaction where fraud is suspected.
• Work with our payment provider and relevant financial institutions to investigate suspected fraud.

A successful payment does not necessarily mean that Kini will immediately fulfil the underlying order if additional verification is required.

13. Refunds and Chargebacks

Kini may review refunds and chargebacks for potential fraud or abuse.

Where a refund is approved, it will generally be returned to the original payment method.

Kini may place restrictions on an account where there is evidence of fraudulent activity, repeated abusive chargebacks or attempts to misuse the refund process.

Nothing in this policy limits a customer's legal rights regarding disputed transactions.

14. Record Keeping

Kini maintains records relating to customer accounts and transactions as reasonably necessary to operate the platform, protect customers and comply with applicable legal and regulatory requirements.

Records may include:

• Customer identification information.
• Beneficiary information.
• Transaction records.
• Payment confirmations.
• Care Pool information.
• Voucher and service fulfilment records.
• Verification information.
• Relevant communications.
• Refund and chargeback records.
• Information relating to investigations or risk reviews.

Records will be retained for the periods required by applicable law and Kini's internal record-retention requirements.

15. Privacy and Protection of Personal Information

Information collected for KYC, AML, fraud prevention and compliance purposes will be handled in accordance with Kini's Privacy Policy and applicable South African data-protection requirements, including the Protection of Personal Information Act (POPIA).

Kini will only collect and use information that is reasonably necessary for legitimate business, security, legal or compliance purposes.

16. Account Restrictions and Refusal of Service

Kini reserves the right, subject to applicable law, to:

• Decline a transaction.
• Delay fulfilment.
• Request additional information.
• Restrict an account.
• Suspend an account.
• Refuse a transaction or service.
• Terminate an account where appropriate.

These measures may be taken where Kini cannot satisfactorily verify a customer or transaction, identifies suspected fraud or financial crime, or is required to do so by law or by a competent authority.

Where appropriate and legally permitted, Kini will provide the customer with an explanation for the restriction.

17. Third-Party Payment Providers

Kini uses third-party payment providers to process customer payments.

Payment providers may conduct their own customer verification, fraud screening, transaction monitoring and compliance checks.

Customers may therefore be asked to provide additional information or complete verification required by the payment provider.

Kini will cooperate with its payment providers where reasonably necessary to prevent fraud and financial crime.

18. Compliance with Applicable Law

Kini intends to comply with all applicable laws and regulatory requirements relating to anti-money laundering, counter-terrorist financing, sanctions, fraud prevention and financial crime.

Where Kini's activities fall within the scope of specific obligations under the Financial Intelligence Centre Act, 2001 (FIC Act) or other applicable legislation, Kini will implement the relevant controls and reporting requirements.

The Financial Intelligence Centre states that accountable institutions must apply appropriate customer due diligence and risk-based controls, and that relevant compliance programmes should address customer identification and verification, record keeping, reporting and risk management.

19. Policy Review

Kini will review this policy periodically and whenever there are material changes to:

• Kini's products or services.
• The way customer funds are received or applied.
• Third-party payment or fulfilment arrangements.
• Applicable laws or regulations.
• Kini's identified financial-crime risks.

Additional controls may be introduced where necessary.

20. Contact Us

If you have questions about this policy or our approach to financial crime prevention, please contact:

Kini Support
Email: support@kini-app.co.za
Website: https://kini-app.co.za

Kini is committed to protecting families, beneficiaries and our partners by maintaining a secure, transparent and responsible care platform.