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Where your money sits, and who is checking

Three places, three sets of rules, none of them a Pepea Technologies account. Every status below says who is reviewing it and since when.

How money is kept

KES ยท savings and shares

With the SACCO, under SASRA rules

Pepea Sacco Society Ltd holds member deposits and share capital. Lent only under the by-laws, from Phase 1.

KES ยท wallet float

Trust accounts at [sponsor bank]

Money in transit to and from M-Pesa sits in segregated trust accounts under the e-money application.

USD ยท live

BacBon custody, CBK VASP licence

Dollars are held by BacBon in segregated accounts under its licence. Pepea does not custody dollars. Conversion runs at one published spread; nothing in local currency depends on the dollar layer.

Licences and registrations

InstrumentRegulatorState
SACCO registration (non-withdrawable deposit-taking)

Pepea Sacco Society Ltd holds member deposits and share capital.

Commissioner for Co-operative Development ยท SASRA granted ยท [ref] ยท [date]
E-money issuer / PSP โ€” Pepea Payments Ltd

Money in transit to and from M-Pesa sits in segregated trust accounts.

Central Bank of Kenya granted ยท [ref] ยท [date]
Data controller registration

Pepea is registered to process membersโ€™ personal data.

Office of the Data Protection Commissioner granted ยท [ref] ยท [date]
VASP wallet licence โ€” held by BacBon, not Pepea

USD is held under BacBonโ€™s CBK VASP wallet licence โ€” Pepea does not hold this licence and does not custody dollars.

Central Bank of Kenya partner ยท granted ยท [ref] ยท [date]

Deposit protection

Until a statutory Deposit Guarantee Fund covers SACCO members, Pepea holds private deposit cover with [provider] up to KES [limit] per member. The policy document and its exclusions are published here. Share capital is not covered โ€” it is ownership, not a deposit.

If something goes wrong

Fraud or an unauthorised transaction
ack 1 h ยท resolve 5 bd
Credit-decision review
10 bd
Circle dispute
Circle vote โ†’ Pepea mediation
Monthly dispute statistics
/own โ€บ Governance

Fraud rules we publish

A 24-hour hold on the first withdrawal to a new destination above a threshold; device, velocity and SIM-swap checks on every login and transaction; Circle-level rules on sudden order changes and payouts to new numbers. Thresholds are withheld (see the redactions list on /own).

Your data

DPIA summary: what we collect (phone, ID for KYC, device, transactions), why, for how long (seven years for ledger records), who processes it (Smile ID, Africaโ€™s Talking, Meta, [sponsor bank]). Every automated decision stores its model version and a plain-language reason.

Security disclosure: [security@pepea.xyz], response within 3 business days.

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