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

Effective Date: [16/10/2026]

1. Purpose

GTSmartAI is an AI-powered software-as-a-service platform offering tools for content creation, research, coding, document analysis, automation, AI agents, and related services. This Policy explains how we seek to prevent fraudulent payments, identity misuse, money laundering, terrorist financing, sanctions evasion, and other unlawful conduct connected with the platform.

2. Scope and Regulatory Position

This Policy applies to customers, account holders, business administrators, and persons making payments for GTSmartAI services. GTSmartAI is not presented as a bank, money-transfer service, cryptocurrency exchange, or custodian of customer funds. Payments may be handled by independent regulated payment providers. Our statutory AML registration, verification, recordkeeping, and reporting duties depend on our actual business activities and legal classification. Where an applicable law imposes additional obligations, those obligations take precedence.

3. Customer Identification

To create an ordinary account, we may request basic information such as a name, email address, and account credentials. Depending on transaction risk, account type, legal requirements, or a payment provider’s rules, we or our authorized providers may request further evidence, including business registration information, proof of authority to represent a business, contact details, or identity verification documents. We will request only information reasonably necessary for the relevant purpose.

4. Business and Enterprise Verification

For business or enterprise accounts, we may verify the organization’s legal name, registration status, authorized representative, and, where legally required, beneficial ownership or control. We may decline onboarding or additional services when information is materially inaccurate, incomplete, unverifiable, or connected to prohibited activity.

5. Risk-Based Review

We may apply proportionate controls when indicators suggest a heightened risk, including unusual payment patterns, repeated chargebacks, inconsistent account information, suspected stolen payment methods, attempts to bypass usage controls, sanctions concerns, or credible indications of illegal activity. Reviews may include asking for clarification, temporary transaction restrictions, or referral to a payment processor.

6. Payments and Third-Party Processors

GTSmartAI’s checkout and subscriptions may be facilitated by third-party payment companies. Payment processors can conduct their own identity, transaction, anti-fraud, and AML screening under their respective legal obligations and privacy notices. GTSmartAI does not claim to perform the regulated activities of those providers merely by accepting subscription payments.

7. Prohibited Conduct

Customers must not use GTSmartAI accounts or payments to launder proceeds of crime, finance terrorism, circumvent applicable sanctions, use stolen financial credentials, impersonate another party, or facilitate fraud or unlawful transactions. Users must also comply with our Terms & Conditions and Acceptable Use Policy.

8. Monitoring and Escalation

Where lawful and appropriate, we may review account, access, and payment information to detect security threats, abuse, and suspicious conduct. We may suspend transactions or accounts, request information, cooperate with payment providers, or disclose information to a competent authority where legally authorized or required. If statutory suspicious-transaction reporting duties apply to us, we will follow the prescribed reporting process and deadlines. We will not notify affected persons about restricted reports where disclosure is prohibited by law.

9. Recordkeeping and Confidentiality

Verification and transaction-related records are collected and retained only where needed for legitimate operational purposes or legal requirements, with access limited to authorized persons and providers. Applicable statutory retention periods prevail over routine deletion requests where the law requires preservation. Sensitive records are handled according to our Privacy Policy and Nigeria Data Protection Policy.

10. Refusal, Suspension, and Appeals

We may refuse a payment, delay verification, suspend a feature, or restrict an account for a legitimate security, compliance, or legal reason. A customer who believes a restriction is mistaken may request a review through our support or compliance contact, subject to limits on information we can legally disclose. Refund rights remain governed by applicable law and the Refund & Cancellation Policy.

11. Policy Review and Contact

We may update this Policy to reflect changes in our operations or legal obligations. Questions about verification or compliance may be sent to [email protected].