Compliance and Regulatory Framework

1. Compliance statement and commitment

RshopRefills maintains a zero-tolerance policy toward financial crime in all its forms, including money laundering, terrorist financing, fraud, bribery, corruption and sanctions evasion. We are committed to conducting business lawfully and ethically, and to upholding the highest standards of regulatory integrity in every jurisdiction we serve across Africa and globally.

2. Anti-money laundering (AML) and counter-terrorist financing (CTF)

We operate a risk-based AML and CTF program aligned with the recommendations of the Financial Action Task Force (FATF) and with the laws of the jurisdictions in which we operate. Our framework includes the following controls:

• Automated transaction monitoring that screens activity in real time and flags patterns inconsistent with a customer's profile.
• Anomaly detection for sudden high-volume purchases and other unusual behaviour.
• Velocity controls on gift card purchases and cross-border utility top-ups, designed to detect structuring and smurfing.
• Escalation and reporting of suspicious activity to the relevant Financial Intelligence Units, in line with statutory obligations.
• Record-keeping of transactions and verification data for the periods required by law.

3. Know Your Customer (KYC) and identity verification stages

We apply a tiered, risk-based approach to identity verification. Verification requirements increase progressively with the value and risk of the activity, so low-value retail stays simple while higher-value and higher-risk activity carries stronger checks.

Where a customer or transaction presents a higher risk, we apply Enhanced Due Diligence, which may include additional documentation, source-of-funds checks and senior management approval before activity is permitted.

4. Sanctions and geographic restrictions

We run automated daily screenings of customers and counterparties against global sanctions lists, including those maintained by the US Office of Foreign Assets Control (OFAC), the United Nations, the European Union and the United Kingdom HM Treasury. Screening is performed at onboarding and on an ongoing basis, and we also screen for Politically Exposed Persons (PEPs).

5. Fraud prevention and payment integrity

We protect our international payment rails with machine-learning fraud-prevention protocols that score activity in real time and challenge or block high-risk transactions. Our controls include:

• Device fingerprinting to recognise trusted devices and detect suspicious ones.
• Card-velocity checks to identify rapid or abnormal payment attempts.
• 3D-Secure enforcement on card payments to confirm cardholder identity.
• Geolocation and IP risk analysis to detect anomalous cross-border activity.

Card payments are processed through regulated, secure gateways. We do not store complete card numbers on our servers.

6. Digital real estate and asset compliance

Our digital real estate offerings strictly adhere to the property ownership laws and the fractionalization and asset-compliance requirements of the jurisdiction in which each physical property resides. Where local law requires it, allocations, title and fractional contracts are structured and recorded through licensed local entities and qualified professionals.

We provide clear disclosures to participants and honour any cooling-off periods or investor-protection rules mandated in the relevant region. We do not offer these products where doing so would conflict with local law.

7. Compliance contact for regulators and partners

Banking partners, payment providers, law enforcement, regulators and corporate compliance teams may contact our compliance department directly for due-diligence questionnaires, audit requests, regulatory enquiries and lawful information requests.