1. Purpose
Vav is the trading name of Sterick Limited, a company incorporated in Hong Kong (Company Registration No. 80436340). References to “Vav”, “we” and “us” in this policy mean Sterick Limited.
Vav is committed to preventing money laundering, terrorist financing, sanctions evasion, fraud and other financial crime. This policy explains, in summary, how we and our partners verify customers and monitor activity, and what we need from you. It is a public summary of our approach; our detailed internal procedures are confidential.
2. Our role and our partners’ role
Vav is a technology layer. Regulated financial services accessed through Vav are provided by independent, appropriately authorised partners (“Partners”) who are themselves subject to anti-money-laundering, counter-terrorist-financing and sanctions laws in the jurisdictions in which they operate.
Vav runs onboarding and day-to-day customer checks in the app and works with our Partners and specialist identity and screening providers so that every customer and transaction meets the standards required by the law and by each Partner. Where a Partner applies stricter requirements, those apply.
3. Who this applies to
Vav accounts on vav.global are available to businesses only; we do not open personal or individual accounts. This policy applies to every business customer, to its beneficial owners, directors, controllers and authorised users, and to every transaction made through the Platform.
4. Verifying business customers (KYB)
Before a business can use financial services we will ask for information and documents about the business and the people behind it. Depending on the business’s country, the products it uses and its risk profile, this may include:
- registered name, registration number, registered and trading addresses and date of incorporation;
- incorporation documents and evidence of good standing;
- a description of the business, its website, products, customers, countries of operation and expected volumes;
- the identity of directors, of anyone who owns or controls 10% or more, and of authorised users;
- the ownership and control structure;
- the purpose of the account, the source of the funds the business sends or receives and, where needed, the source of its wealth; and
- any licences the business needs for its activity.
Verifying the people behind the business. We verify the identity of the business’s directors, beneficial owners, controllers and authorised users. For each of them this may include their full name, date of birth, nationality and residential address; a valid government-issued photo ID, such as a passport or national identity card; a selfie or short video with a liveness check, matched against their ID using facial recognition; and proof of address, such as a recent utility bill or bank statement.
Age: anyone who opens or uses a business account must be 18 or over. Certain payout partners apply an upper age limit under their own rules.
5. Enhanced checks
We apply enhanced due diligence where risk is higher, for example for politically exposed persons and their close associates, customers connected with higher-risk countries, complex ownership structures, unusually large or frequent transactions, or activity that does not fit the customer’s profile. This can include additional documents, source-of-funds and source-of-wealth evidence, and senior approval.
6. Sanctions screening
We screen customers, related persons and, where relevant, counterparties against applicable sanctions and watch lists, at onboarding and on an ongoing basis. We do not provide services to sanctioned persons or entities, to persons owned or controlled by them, or for activity involving sanctioned countries or regions.
7. Ongoing monitoring
We and our Partners monitor accounts and transactions on an ongoing basis to detect unusual or suspicious activity. We may ask you to explain a transaction or to update your information at any time, and we periodically review customer information to keep it current.
8. Prohibited customers and activity
We will not open or maintain accounts for customers or activity that fall within our Acceptable Use Policy’s prohibited categories, including anonymous or fictitious accounts, shell banks, and businesses that cannot demonstrate a legitimate source of funds or the licences their activity requires. In summary, we do not serve:
- arms, weapons and ammunition dealers;
- gambling;
- adult content and services;
- marijuana and cannabis businesses;
- unlicensed money service businesses and exchanges;
- shell banks;
- unregulated charities;
- mixers, tumblers and other privacy services;
- multi-level marketing schemes; and
- unlicensed securities or forex trading.
9. Restrictions and reporting
Where we or a Partner have concerns, we may delay or refuse a transaction, request more information, restrict features, freeze funds held by a Partner or close an account. Where the law requires, we and our Partners report suspicious activity to the relevant authorities. The law may prevent us from telling you that a report has been made or why an action was taken.
10. Record keeping
We and our Partners keep verification records and transaction records for as long as the law requires, which is typically at least five years after the end of the customer relationship, even if you close your account.
11. What we ask of you
- Give us accurate, complete and honest information and genuine documents.
- Tell us promptly if your details, ownership or business activity change.
- Respond to our information requests within the time we ask.
- Use the account only for the business that holds it, never for anyone else.
- Do not try to avoid limits or checks, for example by splitting transactions.
12. Personal data
Information collected for verification and monitoring, including biometric data used for face matching, is processed as described in our Privacy Policy, used only for these purposes and for meeting our legal obligations, and shared only with Partners, verification and screening providers and authorities where required.
13. Changes and contact
We review this policy regularly and update it when laws, our Partners or our services change. Questions: hello@vav.global.