KYC & Compliance

Tiered KYC Model

Nav.Wallet implements a progressive Know-Your-Customer system that balances financial inclusion with regulatory compliance. Customers start with minimal documentation and unlock higher limits as they provide additional verification.

Tier Structure

Upgrade Path

• Customers can upgrade at any time directly from the app
• Tier upgrades take effect immediately — new limits apply to the next transaction
• The KYC Engine deterministically classifies customers based on verified documents
• Rejected documents trigger notification with reason and resubmission guidance

Biometric Identity Verification

Guided ID Document Capture (Tier 2+)

The wallet app provides an in-app guided camera experience for capturing identity documents:

1. Rear-facing camera opens with a dashed frame overlay showing “Hold your ID card steady”
2. 3-second countdown — user holds the document in frame, then auto-capture fires
3. Alternatively, users can upload a file from their gallery
4. Backend validates the document image quality before proceeding

Selfie + Face Comparison (Tier 3)

After ID capture, customers complete biometric verification:

1. Front-facing camera opens with a circular face-frame overlay
2. Active liveness challenge — “Please blink” instruction with real-time frame capture
3. Blink detection — client-side intensity analysis provides UX feedback; backend performs real validation
4. 10 frames captured during the 3-second challenge window for anti-spoofing analysis
5. Final high-quality selfie captured after liveness completes

Backend Processing (ONNX Pipeline)

All biometric verification runs on-device models deployed via ONNX Runtime:

Verification flow:

• Extract face from ID document → generate 512-dimensional embedding
• Extract face from selfie → generate embedding
• Compute cosine similarity → match threshold determines pass/fail
• Liveness score from MiniFASNetV2 must exceed threshold (rejects printed photos, screen replays)
• Active liveness frames analyzed for temporal consistency (blink pattern)

Anti-Spoofing Measures

• Passive liveness — Distinguishes real faces from printed photos, screen replays, and masks
• Active liveness — Blink detection challenge ensures a live person is present
• Frame consistency — Multiple frames captured to detect static image attacks
• Configurable thresholds — Match confidence and liveness scores tunable per environment

Limit Enforcement

The KYC Engine applies limits as a cross-cutting concern at the Wallet API layer:

1. Daily transaction limit — Sum of all outgoing transactions in a calendar day
2. Maximum balance — Post-transaction balance check prevents exceeding tier cap
3. Applies uniformly — Same limits for P2P transfers, cash-in, and cash-out
4. Actionable rejections — Limit-exceeded responses include current limits and upgrade prompt

Fraud Detection

Every transaction passes through multiple security gates:

• IFraudDetection — Real-time risk scoring; transactions above threshold are rejected
• IVelocityCheckService — Detects unusual patterns (rapid successive transfers, impossible travel)
• ISanctionsScreening — Triggered for all transfers exceeding R5,000
• PIN lockout — 3 consecutive failed PIN attempts lock the account for 30 minutes

SIM Swap Protection

• SIM swap detection triggers immediate account suspension
• Customer notified via alternative contact method
• Re-verification required before account reactivation
• All account data preserved during suspension

Security Features

Regulatory Alignment

Nav.Wallet is designed to comply with:

• SARB — South African Reserve Bank guidelines for e-money issuers
• FSCA — Financial Sector Conduct Authority requirements
• FICA — Financial Intelligence Centre Act for customer due diligence
• POPIA — Protection of Personal Information Act for data handling