Anti-Money Laundering Policy

  1. Introduction and Background
    1. This Policy sets out the obligations of DusuPay, a company registered in Uganda, whose registered office is at Kampala hereinafter referred to as “DusuPay” regarding taking measures to prevent criminals or their associates from holding or being the beneficial owner of a significant or controlling interest or holding a management function in a DusuPay account or its contents. The Policy is also meant to ensure that DusuPay or any service offered by it is not used by a person to commit or facilitate the crime of money laundering and financing of terrorist activities.
    2. Our business operations are guided by the Anti-Money Laundering Act, 2013 and the Regulations made thereunder. Our management and employees are fully conversant with all Anti-Money Laundering guidelines and are aware of their responsibilities in the monitoring, reporting and disclosure of any actions that raise suspicion or give cause for concern.
    3. DusuPay has thus created this policy to regulate transactions with its customers who own DusuPay private as well as Business accounts and to ensure funds and their source are fully traced and accounted for in light of the requirements set out by Bank of Uganda and the Financial Intelligence Authority (FIA).
    4. This policy is also in compliance with obligations as set out under international Anti-Money Laundering legislation and it encompasses the need to have adequate controls and systems in place to avoid or limit the risks of DusuPay being used to facilitate financial crime, economic or otherwise.
  1. Prohibition of Money Laundering
    1. The Anti- money laundering Act, 2013 defines “money laundering” as the process of turning illegitimately obtained property into seemingly legitimate property and it includes concealing or disguising the nature, source, location, disposition or movement of the proceeds of crime and any activity which constitutes a crime under the Act;
    2. It is prohibited for any person to through DusuPay intentionally convert, transfer, transport or transmit property, knowing or suspecting that such property to be the proceeds of crime, for the purpose of concealing or disguising the illicit origin of the property or making use of their DusuPay account to assist any person who is involved in the commission of the crime generating the proceeds to evade the legal consequences of his or her actions.
    3. It is prohibited to use one’s DusuPay account to conceal, disguise, or impede the establishment of the true nature, source, location, or ownership with respect to property knowing that such property are the proceeds of crime. This prohibition also applies to assisting another to benefit from known proceeds of crime or to facilitate a conspiracy, participation, association, attempting, aiding or betting the commission of a crime.
    4. It should be noted that money laundering is a crime distinct from and in addition to other crimes under the laws of Uganda, including the crime generating the proceeds subject to the money laundering and you may be charged without having been convicted of the crime of generating the proceeds of money laundering.
  1. Know Your Customer (KYC)
    1. Knowing your customer (KYC) entails the process of identification and verification of the identity of clients. This process involves the consistent review, verification and recording of customer identification and transaction information, as well as the handling of inaccurate, incomplete or suspicious information.
    2. In order to avert crimes related to money laundering and counter terrorism financing, DusuPay has developed the following keystone procedures to ensure it is compliant with the regulations set forth in the Anti-Money Laundering Regulations, 2015;
  2. Customer Identification Requirements
    1. DusuPay employees are required to review customer identification and ensure they are:
      1. Currently valid
      2. Government issued
      3. Contain a photograph
      4. Contain the customer’s name.
    2. DusuPay employees must determine that the form of identification is acceptable by the Competent Authority. As such, the only acceptable identification documents shall be a valid Passport and a National I.D
    3. In the case of Corporate Bodies, employees are required to review the copies of the relevant documents, that is:
      1. Certificate of incorporation or business registration certificate;
      2. Memorandum and articles of association;
      3. Company headed paper;
      4. Tax Identification Number (TIN); in case of need
      5. Trading License in case of need
      6. DusuPay employees are required to review the identification of the individual representing the Corporate Body and the evidence that he/she has the necessary authority to do so and verify this with the company’s board resolution.
      7. They are further required to review identification of the principal or substantial shareholders, the directors (including the managing director) and all authorized signatories in line with the requirements for individual customer as provided hereinabove.
      8. Each DusuPay employee is required to look at and handle the customer’s ID to verify their identity and its authenticity. If an ID is not provided, does not match the customer or is fake; the employee must refuse the transaction.
  3. Anti-Money Laundering Monitoring
    1. DusuPay has taken measures to identify customers who maintain accounts with DusuPay to ensure that they maintain such accounts in the true name of the account holder, and do not open or keep anonymous accounts or accounts which are in fictitious or incorrect names.
    2. DusuPay shall not initiate a business relationship or carry out an occasional transaction, including the opening of a new account or entering into a fiduciary transaction, performing a cash transaction over a capped amount, without undertaking customer due diligence measures, including recording and verifying by reliable means the identity of the client, including their true name as provided by the authorised identification document. Subject to our Privacy Policy, the information you give to us may enable us access your address including postal and residential, employment, and occupation and this may also apply to your representative or whoever has been appointed to act on your behalf.
    3. DusuPay also undertakes further customer due diligence measures to verify the DusuPay customer’s identity using reliable, independent source documents, data or information, such as passports, birth certificates, driver’s licenses, identity cards, voter’s card, utility bills, bank statements, partnership contracts and incorporation documents or other identification documents prescribed by regulations made under the law.
    4. Alongside this, we shall verify the beneficial owner of the account and take reasonable measures to understand the ownership, control and structure of the customer obtaining information. This shall include conducting on going due diligence on the business relationship and where necessary the source, purpose and destination of the funds.
    5. DusuPay shall verify the identity of the customer and beneficial owner before or during the course of opening a DusuPay account or conducting a transaction through DusuPay and this shall apply to each of our customers although the extent may be dependent on the risk sensitiveness of each customer so that for higher risk classified customers, we shall perform an enhanced due diligence.
    6. In that regard, DusuPay shall undertake enhanced customer due diligence measures to determine the true identity of the client if—
      1. there are any doubts that a client is acting on his or her own behalf, particularly in the case of a juridical person who is not conducting any commercial, financial, or industrial operations in Uganda where it has its headquarters or domicile;
      2. the client is a high risk Politically Exposed Person (PEP);
      3. there are any doubts about the veracity or adequacy of obtained customer identification data;
      4. there is a suspicion of money laundering or terrorist financing;
      5. in addition to normal due diligence measures, in relation to politically exposed persons DusuPay shall have appropriate risk management systems to determine whether a customer is a politically exposed person;
      6. establish appropriate guidelines to monitor business relations with such customers;
      7. take reasonable measures to establish the source of wealth or funds;
      8. conduct on-going monitoring of the business relations; and;
      9. obtain the approval of senior management before establishing a business relationship with the customer;
    7. at the point of withdrawing or depositing, the source of funds shall be questioned through a reference system;
    8. no bank transfers are allowed in our system, only peer to peer transfers;
    9. the Anti-Money Laundering Officer shall monitor accounts which have been idle for a long time and have them blocked;
    10. DusuPay operate an open API linking the system to Anti-Money Laundering authorities’ databases like the Financial Intelligence Authority.
  4. Data Protection and Retention
    1. DusuPay as a Data Controller shall comply with its obligations under the Data Protection and Privacy Act, 2019 Laws of Uganda.
    2. DusuPay as a Data Controller shall archive or destroy data after 10 years upon request by the Data Subjects.
    3. DusuPay shall store Customer Data on the cloud through Amazon Web Services (AWS).
  5. Politically Exposed Persons
    1. Politically Exposed Persons”(PEP’s) means individuals who are or have been entrusted with prominent functions in a country, for instance, Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, and important party officials as well as family members or close associates of such individuals;
    2. These at times, pose a significant risk in the financial sector as they may be agents or beneficiaries of economic crime. DusuPay’s Anti-Money Laundering Officer shall therefore implement appropriate risk management systems to determine whether a person or customer is a politically exposed person.
    3. DusuPay considers Ugandans from the political level of L.C.5 and above as PEP’s.
    4. DusuPay’s Anti-money Laundering Officer shall take the following measures where a person or customer is a Politically Exposed Person—
      1. Obtain written approval from senior management to transact or establish a business relationship with that person;
      2. Take adequate measures to establish the source of wealth and the source of funds involved in the proposed business relationship or transaction;
      3. Obtain information on the immediate family members or close associates of the person who may have transaction authority over the account;
      4. Determine the purpose of the transaction or account and the expected volume and nature of account activity;
      5. Review public sources of information on the politically exposed person; and
      6. Conduct enhanced on-going monitoring of the business relationship, once the account has been established.
      7. DusuPay shall take such measures as are reasonably necessary toensure that neither it nor any service offered by it is used by a person to commit or facilitate the crime of money laundering and financing of terrorist activities.
      8. DusuPay shall establish and maintain for at least ten years the information obtained about the true identity of the person on whose behalf a business relationship is initiated or a transaction is conducted and establish and maintain, during the period in which business relations are in effect, and for at least ten years after their conclusion, in readily recoverable form, the records of the information and documentation required this policy.
      9. DusuPay shall carry out annual reviews on these PEP’s.
  6. Risk Classification
    1. The Risk classification of DusuPay Users will be divided into:
      1. Low Risk; these are by and large nationals of a country who are not PEP’s or on any sanction list of any country or from non-restricted countries.
      2. High Risk; these are foreigners from restricted countries or people that trade with restricted countries or people that deal in high risk businesses or PEP’s.
    2. The determination of whether or not one is a Low or High Risk will be determined at on-boarding from the additional information gathered from that individual or from the nature of transactions carried out by DusuPay User.
  7. Customer Refresher
    1. DusuPay shall from time to time update its data about its customers by sending them messages to update their information or else have them lose their accounts.
  8. Statement of our Policy
    1. The company supports the fight against money laundering and terrorism by adopting this AML Compliance Policy to prevent the DusuPay’s financial services from being used to promote such criminal activity.
    2. Cooperate with all the authorities, to the extent that is permitted by applicable Laws, so as to help them in their efforts to prevent or fight money laundering, and the financing of terrorism proliferation.
    3. DusuPay will fully comply with both the intent and letter of all laws and Regulations relating to AML, the prevention of terrorist financing and economic sanctions.
    4. DusuPay will train its employees to comply with these laws and Regulations.
    5. Maintain all customer/transactions related records for at least 10 years or for longer period if the Law in the country requires so.

Terms and Conditions

These Website Terms and Conditions (“Terms”) contained herein on this web page, shall govern your access to and use of this website, including all pages within this website (collectively referred to as this “Website”). These Terms apply in full force and effect to your use of this Website and by using this Website, you expressly accept all terms and conditions contained herein in full. You must not use this Website, if you have any objection to any of these Terms. PLEASE READ AND UNDERSTAND THE TERMS OF AGREEMENT CAREFULLY BEFORE BEING AGREED TO BE BOUND BY ITS TERMS.

Age Restriction

Our website and services are directed to people from the ages of 18 and above. We do not knowingly engage in people younger than the age of 18.

Intellectual Property

Unless otherwise stated, DusuPay and/or its licensors own the intellectual property rights and materials on the website subject to the license below. We do not grant you any right, license, title or interest to any of our intellectual Property rights which you may or may not have access to. You agree to take such actions including any legal or official document or other documents that may be needed to further affirm our intellectual property rights.

License to Use Our Website

We grant you a non-assignable, non-exclusive and revocable license to use the software provided as part of our services in the manner permitted by these Terms. This license grant includes all updates, upgrades, new versions and replacement software for you to use in connection with our services.

The services are protected by copyright, trademark, and other laws of both Uganda and foreign countries. Nothing in this Term gives you a right to use the DusuPay  name or any of DusuPay’s trademarks, logos, domain names, and other distinctive brand features. All right, title and interest in and to the services are and will remain the exclusive property of DusuPay and its licensors.

If you do not comply with all the provisions, then you will be liable for all resulting damages suffered by you, DusuPay and all third parties. Unless otherwise provided by applicable law, you agree not to alter, re-design, reproduce, adapt, display, distribute, translate, disassemble, reverse engineer, or otherwise attempt to create any source code that is derived from the software.

Any feedback, comments, or suggestions you may provide to us and our services is entirely voluntary and we will be free to use such feedback, comments or suggestion as we see fit without any obligation to you.

Who May Use Our Services?

You may use the Services only if you agree to form a binding contract with DusuPay and are not a person barred from receiving services under the laws of the applicable jurisdiction. If you are accepting these Terms and using the Services on behalf of a company, business, or organization, you represent and warrant that you are authorized to do so.

Your DusuPay Account

Your DusuPay Account is an electronic money account which enables you to send and receive electronic payments.

Your DusuPay Account is denominated in a currency of your choice, as selected by you from the available currencies.

You can change the currency of your DusuPay Account once you have attempted to process a payment.

The electronic money held on your DusuPay Account does not expire but it will not earn any interest.

You have the right to withdraw funds from your DusuPay Account at any time. However, you may be required to confirm your identity beforehand. There is no minimum withdrawal amount but the funds on your DusuPay Account must be sufficient to cover any applicable withdrawal fee. You can choose the method of withdrawal when submitting your withdrawal request.

Electronic money accounts are not bank accounts. By accepting these Terms of Use you acknowledge that the UK’s Financial Services Compensation Scheme (FSCS) does not apply to your DusuPay Account. In the unlikely event that we become insolvent, you may lose the electronic money held in your DusuPay Account. However, we strictly adhere to the legal requirements under the European Electronic Money Directive 2009/110/EC and UK national legislation which are designed to ensure the safety and liquidity of funds deposited in electronic money accounts. For further information on how we safeguard customer funds, please visit our Website.

The electronic money on a DusuPay Account belongs to the person or legal entity which is registered as the DusuPay Account holder. No person other than the DusuPay Account holder has any rights in relation to the funds held in a DusuPay Account, except in cases of succession. You may not assign or transfer your DusuPay Account to a third party or otherwise grant any third party a legal or equitable interest over it.

Your DusuPay Account may be subject to upload, payment and withdrawal limits, depending on your country of residence, the verification status of your DusuPay Account and other factors used by us to determine such limits from time to time at our sole discretion.

Opening your DusuPay Account

In order to use our payment services you must first open a Dusupay Account by registering your details on our Website. As part of the signup process you will need to accept these Terms of Use and our Privacy Policy and you must have legal capacity to accept the same. If you order additional services, you may be asked to accept additional terms and conditions.

You may only open one DusuPay Account unless we explicitly approve the opening of additional accounts.

You may only open a DusuPay Account if it is legal to do so in your country of residence. By opening a DusuPay Account you represent and warrant to us that your opening of a DusuPay Account does not violate any laws or regulations applicable to you. You shall indemnify us against any losses we incur in connection with your breach of this section.

All information you provide during the signup process or any time thereafter must be accurate and truthful.

You may only add payment instruments (such as bank accounts, credit cards or debit cards) unless when using Mobile wallets or POS to your DusuPay Account if you are the named holder of that payment instrument. We take any violation of this requirement very seriously and will treat any attempt to add a payment instrument of which you are not the named holder as a fraudulent act.

Within 14 days of the date of opening your DusuPay Account, you may close your DusuPay Account at no cost by contacting Customer Service, however, if you have uploaded funds into your DusuPay Account, you may be required to provide identification documents before being able to withdraw funds. Transactions and fees for transactions undertaken before you close your DusuPay Account (including those transactions that are not revocable and have been initiated but not completed before closure of your DusuPay Account) will not be refunded.

Maintaining your DusuPay Account

You must ensure that the information recorded on your Dusupay Account is always accurate and up to date and we shall not be liable for any loss arising out of your failure to do so. We may ask you at any time to confirm the accuracy of your information or to provide documents or other evidence.

We may contact you by e-mail or in other ways described  with information or notices regarding your DusuPay Account. It is your responsibility to regularly check the proper functioning of your email account or other methods of communication that you have registered with your DusuPay Account and to retrieve and read messages relating to your DusuPay Account promptly. We shall not be liable for any loss arising out of your failure to do so.

Fund uploads, payments received, payments sent and fund withdrawals are displayed in your  account together with the fees charged are displayed on your dashboard. Each transaction is given a unique transaction ID and shown in the transaction history. You should quote this transaction ID when communicating with us about a particular transaction. You should check your DusuPay Account balance and transaction history regularly. You should report any irregularities or clarify any questions you have as soon as possible by contacting Customer Service.

Warranty Disclaimer

DusuPay  will always ensure that the website is available at all times and bug free. however, it is used at your own risk

we provide all materials “as is” with no warranty, express or implied, of any kind. we expressly disclaim any and all warranties and conditions, including any implied warranty or condition of merchantability, fitness for a particular purpose, availability, security, title, and non-infringement of intellectual property rights, without limiting the generality of the foregoing,  dusupay makes no warranty that our website and services will meet your requirements or that our website will remain free from any interruption, bugs, inaccuracies, and error free. your use of our services are at your own risk and you alone will be responsible for any damage that results in loss of data or damage to your computer system. no advice or information, whether oral or written obtained by you from our website or our services will create any warranty or condition not expressly stated.

Limitation of Liability

You agree to the limitation liability clause to the maximum extent permitted by applicable law: DusuPay will in no way be liable for any direct, indirect, incidental punitive, consequential, special or exemplary damages or any damages including damages resulting from revenue loss, profit loss, use, data, goodwill , business interruption or any other intangible losses (whether DusuPay has been advised of the possibility of such damages or not) arising out of DusuPay’s website or services (including, without limitation to inability to use, or arising from the result of use of DusuPay’s website or services) whether such damages are based on warranty, tort, contract, statute or any other legal theory.

some jurisdictions do not allow exclusion of certain warranties or limitations on the scope and duration of such warranties, so the above disclaimers may not apply to you in their entire-ties, but will apply to the maximum extent permitted by applicable law.


You hereby indemnify DusuPay and undertake to keep DusuPay  indemnified against any losses, damages, costs, liabilities and expenses (including without limitation to reasonable legal fees) arising out of any breach by you of any provision of these Terms, or arising out of any claim that you have breached any provision of these Terms.

Breaches of these Terms

Without prejudice to DusuPay’s other rights under these Terms, if you breach these Terms in any way, DusuPay may take such action as DusuPay deems appropriate to deal with the breach, including suspending your access to the website, prohibiting you from accessing the website, blocking computers using your IP address from accessing the website, contacting your internet service provider to request that they block your access to the website and/or bringing court proceedings against you.