Introduction

Globally, there is increasing focus on tackling fraud, money laundering, and other economic crimes, particularly through greater transparency around the individuals who ultimately control a company and its operations (e.g. the UK’s Economic Crime (Transparency and Enforcement) Act 2022 and the US’ Corporate Transparency Act).

At Duffel, we are committed to providing a safe and secure travel platform. As part of our risk management efforts, we require all customers to complete a Know Your Customer (KYC) questionnaire before creating live orders via the Duffel Platform.

Jargon busting:

• Fraud is essentially a dishonest act/omission with the intention of making a gain or to cause loss to another.
• Money laundering is the process of transferring illegitimate funds through a legitimate business or activity to conceal their origin.

What is KYC?

KYC is the process for verifying the identify of a customer. Duffel uses KYC to verify the legitimacy of a prospective customer and their operations before we allow the customer to use the Duffel Platform to create travel orders. Duffel can thus:

✔️ Ensure compliance with legal and regulatory requirements, including any applicable sanctions framework

✔️ Follow international anti-money laundering (AML) standards to prevent money laundering

✔️ Meet contractual obligations to our suppliers (airlines, hotels and other travel service providers)

✔️ Meet standards placed upon Duffel as an accredited body / licensed agent authorised to sell flights (IATA/ARC)

✔️ Detect and prevent fraudulent travel bookings

✔️ Assess customer risk to promote a safe and secure travel offering

✔️ Enhance customer trust

What information do we ask for?

Information provided should be true to the best of your knowledge and supporting documents should be clear and valid.

Applicable to all

• Business information: such as registered company name, number and address, business activity and link to your website. We will also ask you to identify persons with significant control / ultimate beneficial owners, i.e. those holding more than 25% of shares / voting rights.
• Fraud prevention: our suppliers expect and demand that we minimise fraudulent transactions processed on their systems. Therefore as you control the travel UI with your end-customer / traveller, we will ask for details of your fraud prevention measures e.g. third party tools, to better understand the fraud risks associated with your orders.

For specific services

• If you are using Duffel settlement (please see clause 5.1 of the Services Agreement): as you will be topping-up the “Balance” in the Dashboard we will ask you for a bank statement (i.e. the letterhead including the account name and number). We must understand the source of funds that you will use to pay for travel on the Duffel Platform in order to meet AML standards and ensure bank transfers are legitimate.
• If you are using Duffel Payments (please see clause 16 of the Services Agreement): Stripe sets the KYC requirements as our payment service provider, and we cannot circumvent these.

How do you complete KYC?

You will need to complete Duffel’s KYC process before you can create live orders. We verify the information you provide against multiple sources such as government databases.

• PAYG: you will be asked to complete the KYC questionnaire when you click the “Go live” button in your Dashboard. Please note the questionnaire may be branded Stripe but this does not mean you are using Stripe Connect, unless you are using Duffel Payments as mentioned above. If Stripe doesn’t list your country you will be redirected to an alternative KYC form.
• Enterprise: if you are in discussion with our Sales team, they will share a pdf questionnaire for your completion.

We may also ask you to periodically complete KYC to keep the information up to date. We kindly request that you notify us of any significant changes to the information you have provided, for example change in beneficial ownership.

What do we do with the information you provide?

We treat the information you provide confidentially in accordance with our obligations under the Services Agreement.

We do not use the information you provide for any other purposes, and we take your privacy and the security of your data very seriously. Your information is safely handled in accordance with our privacy policy. If you have any questions, please contact us at [email protected].

FAQs

• Do I need to repeat KYC for each country in which I operate? Yes you will need to provide KYC information for each legal entity creating a Duffel account to use and pay for the services.
• Do I need to complete KYC for each “org” I setup in Duffel? If you are PAYG, yes you will need to follow the KYC flow for each org to create live orders. If you are Enterprise, Duffel can enable go-live for multiple orgs provided they are associated with the legal entity that has been verified.
• Why do you need to see our bank statement as that's confidential? We don’t need to see the full detail of your bank statement; only the letterhead including the account name and number. This is to verify the source of funds that you will use to pay for travel on Duffel’s platform in order to meet AML standards and ensure transfers are legitimate. You can therefore provide us with a redacted copy of your bank statement to minimise the sharing of confidential information. Please note Duffel protects the confidentiality of our customer’s information.
• Other suppliers don't ask me to share all of this information. Why does Duffel - is it a requirement or your choice? It is a crime for any company to engage in money laundering. Additionally, the travel industry is vulnerable to fraud. We therefore require KYC to meet certain requirements and to ensure a safe and secure travel offering as listed above.
• Why do you need to know about ultimate beneficial owners (UBOs)? There is increasing focus on tackling fraud, money laundering, and other economic crimes through greater transparency around the individuals who ultimately control a company and its operations. Whilst Duffel is not a regulated institution that is required to verify UBOs (e.g. under FinCEN in the US), it is considered best practice to assess this information to minimise risk and meet global standards.