Last updated: January 2, 2026
Welcome to Lockpesa. These Terms and Conditions ("Terms") govern your use of our platform and services. By accessing or using Lockpesa, you agree to be bound by these Terms. If you disagree with any part of these Terms, you may not access the service.
To use Lockpesa services, you must:
You agree to use Lockpesa services only for lawful purposes and in accordance with these Terms. You agree not to:
Lockpesa provides escrow services to facilitate secure transactions between buyers and sellers. By using our escrow services, you agree that:
Lockpesa charges fees for certain services. All fees are clearly disclosed before you complete a transaction. You agree to pay all applicable fees and charges. Fees are non-refundable unless otherwise stated in these Terms or required by law.
In the event of a dispute between buyers and sellers:
To the maximum extent permitted by law, Lockpesa shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses resulting from your use of the Platform.
The Platform and its original content, features, and functionality are owned by Lockpesa and are protected by international copyright, trademark, patent, trade secret, and other intellectual property laws.
We may terminate or suspend your account and access to the Platform immediately, without prior notice or liability, for any reason, including if you breach these Terms. Upon termination, your right to use the Platform will cease immediately.
We reserve the right to modify or replace these Terms at any time. If a revision is material, we will provide at least 30 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.
These Terms shall be governed by and construed in accordance with the laws of Kenya, without regard to its conflict of law provisions.
1.6. Police Abstract: means an official report or reference
number issued by a recognized law enforcement agency documenting a formal
complaint related to the transaction, where applicable and as specified herein.
13.1. A Dispute may be initiated by the Client within a
reasonable period following the completion of a payment to a Lockpesa account.
A "reasonable period" shall be determined by Lockpesa based on the
nature of the transaction but is typically aligned with the agreed delivery period
plus a defined grace period.
13.2. Valid grounds for initiating a Dispute are:
a) Non-Delivery: Failure of the Seller to
dispatch or provide the agreed-upon goods/services.
b) Damaged Product: Receipt of goods that
are materially damaged, defective, or not as described.
c) Expired
Delivery Period: Failure to deliver within the Seller’s stated and agreed
delivery timeframe.
d) Seller Breach: Any
other scenario where the Seller fails to meet their material obligations under
the agreed Transaction Conditions.
13.3. The responsibility for clearly defining, communicating, and agreeing upon the Transaction Conditions lies solely with the Client and the Seller. Lockpesa is not a party to this agreement but will rely on the evidenced Transaction Conditions during resolution.
14.1. Provision of Police Abstract: For disputes involving
allegations of fraud, non-delivery where criminal intent is suspected, or other
applicable scenarios as determined by Lockpesa, the Client must provide a valid
Police Abstract to substantiate the claim. FAILURE TO PROVIDE A REQUIRED POLICE
ABSTRACT WITHIN THE TIMEFRAME SPECIFIED BY LOCKPESA WILL RESULT IN THE DISPUTE
BEING CLOSED AND LOCKPESA AUTHORIZING THE COMPLETE TRANSACTION, RELEASING FUNDS
TO THE SELLER.
14.2. Return of Goods: In any dispute resolution outcome where a refund to the Client is contingent upon the return of the product (e.g., damaged goods, client error), the Client must return the product to the Seller using an official shipping channel verified by Lockpesa, with valid tracking and proof of delivery. FAILURE TO INITIATE THE RETURN OR PROVIDE VALID PROOF OF DELIVERY TO THE SELLER WITHIN THE TIMEFRAME SPECIFIED BY LOCKPESA WILL RESULT IN LOCKPESA AUTHORIZING THE COMPLETE TRANSACTION, RELEASING FUNDS TO THE SELLER.
The following steps constitute the formal Dispute Resolution
Procedure:
15.1. Initiation: The Client must formally initiate the
dispute resolution process through the designated channel within the Lockpesa
platform.
15.2. Notification & Hold: Upon initiation, Lockpesa will
automatically notify the Seller of the Dispute and place a hold on any funds
related to the transaction, pending resolution.
15.3. Customer Care Intervention & Evidence Submission: Lockpesa's
customer care team will contact both parties. The Client will be required to
provide a detailed abstract of the issue and all supporting evidence, including
a Police Abstract if mandated under Section 3.1. The Seller will be given a
stipulated timeframe to respond.
15.4. Adjudication: Lockpesa will review all submitted
evidence against the documented Transaction Conditions.
15.5. Outcome Implementation:
a) In Favor of
Client: If the Dispute is validated and all Client obligations under Section 3
are fulfilled, Lockpesa will effect a complete reversal of payment. The Seller
bears return shipping costs, and the product must be returned per Section 3.2.
b) In Favor of
Seller / Client Default: If the Dispute is ruled in favor of the Seller, OR if
the Client fails to meet the mandatory obligations outlined in Section 3,
Lockpesa will authorize the complete transaction, releasing all funds to the
Seller.
c) Client Error:
If the Client’s claim is erroneous, any refund issued will be returned to the
Seller, and the Client bears all associated costs.
16.1. Evidence-Based Resolution: Lockpesa's decision shall be
final and binding in the context of the platform and the held funds. Lockpesa's
liability is limited to the facilitation of the resolution based on provided
information and the execution of the financial outcome.
16.2. Cooperation: Both parties agree to cooperate fully and
in good faith with Lockpesa during the dispute resolution process. Failure to
provide requested information or meet obligations within specified timeframes
may result in an adverse decision.
16.3. Legal Recourse: This dispute resolution mechanism does
not preclude either party's right to pursue independent legal action. However,
Lockpesa's adjudication regarding the release of funds held on the platform is
final.
16.4. Amendments: Lockpesa reserves the right to amend these
Dispute Resolution Terms and Conditions at any time. The version effective at
the time of the transaction initiation shall apply.
The AML policy:
Prevents and detects money laundering, terrorist financing, fraud, corruption, and other illicit financial activity.
Ensures compliance with national AML/CFT laws (e.g., the laws of Kenya).
Protects the integrity of Lockpesa’s escrow mechanisms and safeguards its users.
In Kenya, financial services, including e-money and trust intermediaries, are regulated to prevent money laundering and terrorism financing. Broadly, these include:
Know-Your-Customer (KYC) requirements to verify identities.
Reporting obligations to relevant authorities (e.g., filing Suspicious Transaction Reports).
Transaction monitoring and record keeping.
Escrow providers must integrate AML controls across their operations and maintain compliance with regulators.
Before a customer can use LOCKPESA services:
Individuals must provide government-issued photo ID (e.g., passport, national ID).
Businesses must provide corporate documentation (e.g., certificate of incorporation) and authorized signatory details.
Verification ensures that LOCKPESA knows who its customers are and helps prevent anonymous misuse of funds.
Customers are risk-rated based on factors including:
Transaction volumes and values.
Geographic location of parties.
Business types and industries.
Frequency of disputes.
Higher-risk customers may be subject to enhanced due diligence (EDD), including obtaining source-of-funds documentation.
For business accounts, LOCKPESA identifies and verifies all beneficial owners — individuals who ultimately own or control the entity — to prevent shell companies or front persons from being used to launder funds.
Large transaction amounts well above typical customer activity.
Rapid movement of funds shortly after account opening.
Multiple back-to-back high–value transactions.
When suspicious activity is detected, transactions can be temporarily held and reviewed.
If LOCKPESA’s compliance team identifies transactions that may indicate money laundering or terrorist financing:
A Suspicious Transaction Report (STR) is filed with its Compliance department or relevant authority.
Account restrictions or freezes may be applied while investigations proceed.
Large fiat deposits, withdrawals, or conversions above regulatory thresholds must be reported as per jurisdictional AML laws.
A key AML control is setting transaction and daily limits to prevent misuse of escrow systems for rapid or high-value movement of illicit funds.
Customer verification status.
Product type.
Jurisdiction.
For LOCKPESA, we have limits of KES 50,000 per single transaction for payments and transfers.
The limit helps reduce the risk of large-scale money laundering through a single transaction.
To limit daily movement of funds, LOCKPESA impose:
A daily per customer transaction limit of KES 250,000.
Daily limits ensure that multiple smaller transactions still do not exceed a threshold that would raise AML concerns.
18.6.3 Cumulative and Aggregate Limits
Weekly or monthly cumulative limits tied to customer risk rating.
Limits that increase with ongoing activity history and enhanced documentation.
Limits must be published in user agreements and updated as regulatory environments change.
To comply with AML regulations, LOCKPESA:
Retains transaction records (including escrow flows, user documentation, KYC evidence) for at least five years after the end of the customer relationship.
Stores logs of all AML reporting (STRs, CTRs).
Provides copies of records to regulators or law enforcement upon lawful request.
A designated MLRO oversees:
Monitoring and reviewing alerts.
Filing AML reports.
Training staff.
Liaising with regulators and law enforcement.
Regular AML training for all staff.
Internal audit of AML effectiveness.
Automated alert systems for transaction patterns.
Lockpesa’s compliance systems screen:
Customers against domestic and international sanctions lists (e.g., UN, EU, OFAC).
PEP lists to identify individuals in sensitive positions (e.g., government officials).
Accounts linked to sanctioned individuals/entities are not onboarded, and existing accounts are flagged with risk controls.
As LOCKPESA interacts with regulated payment systems (e.g., M-Pesa, bank transfers), it must align with AML and KYC standards set by regulators such as the Central Bank of Kenya and other relevant authorities.
For example, in mobile wallets and payment systems:
Single-transaction and daily transaction thresholds are enforced to limit misuse.
Providers file regular AML reports and follow punitive measures for non-compliance.
LOCKPESA incorporates such frameworks into its escrow AML controls.
Publish its AML policy and transaction limits in Terms of Service.
Inform customers of the requirements for high-risk transactions.
Provide guidance on how to lift limits (e.g., submitting additional KYC documents).
If you have any questions about these Terms, please contact us at:
Email: support@lockpesa.com
Phone: +254 119 091 062
