Terms of Service for Virtual KES account


3rd December, 2025* 

  1. Introduction

Welcome to NALA’s Virtual KES account service. These Terms of Service (“Terms”) govern your use of NALA’s virtual account, which allows eligible users to hold and transact in Kenyan Shillings (KES) through the NALA platform (the “Service”). By using this Service, you agree to these Terms and those of the Partner so please read them carefully. If you do not agree, you must not use the Service.

NAL partners with licensed & regulated partners (the “Partner”) to deliver the Service. Any funds you hold in respect of the Service are managed by our Partner in compliance with applicable laws and regulations.

  1. Definitions

For clarity in these Terms:

“NALA” (or “we”, “us”) refers to NALA 

“User” (or “you”) refers to the individual using the Service

“Virtual KES Account” or “KES Account” means a digital account enabling you to store, send, receive, withdraw, and convert Kenyan Shillings (KES) through the Nala App, with all KES funds issued, stored, and managed by the Partner.

“Partner” refers to the institution licensed and regulated by the Central Bank of Kenya (CBK), responsible for the issuance, storage, safeguarding, and processing of all KES funds associated with the Service.

“Service(s)” refers to all features and functionalities offered through the Nala App relating to the KES account, including storing, sending, receiving, withdrawing, and converting KES funds.

“Platform” means NALA’s mobile application and any associated websites or services through which you access the Services from time to time. 

  1. Eligibility and Account Registration

Who Can Use the Service: 

  • You must be at least 18 years old and capable of entering into a legal contract. 
  • You may register and use only one KES Account in your name (no joint or multiple accounts per person). 
  • By registering, you represent that you are not violating any laws by using this service.

Identity Verification (KYC): 

  • You agree to provide accurate personal information and any documents required for identity verification as part of our Know-Your-Customer (KYC) and Customer Due Diligence process. This may include your full name, date of birth, contact information, valid government-issued ID (e.g., passport, national ID), and any other information we request to verify your identity and source of funds. 
  • You authorize NALA, directly or through third parties, to make any inquiries necessary to validate your identity and information. This can include checking the details you provide against databases or through third-party verification services. We may also require you to undergo verification steps (such as selfie verification or one-time passwords) to authenticate your account usage.

Compliance with AML/CFT: 

  • This identity verification is done to comply with anti-money laundering (AML) and countering financing of terrorism (CFT) laws and to secure the platform against illicit use.

Updates to Your Information:

  •  You are responsible for keeping your registration information up-to-date. If your personal details, including ID, phone number, etc., change, you must promptly update them in the NALA app or notify us. Providing false or outdated information may lead to suspension of your account.

Account Security

  • Upon successful registration and verification, you will have access to the Services via the NALA app 
  • You must keep your login credentials, PINs, one-time passwords, and any other security codes confidential. Do not share your account access with anyone. 
  • You are solely responsible for all activities under your account. If you suspect unauthorized access or a security breach, you must notify NALA immediately. We may block or suspend your account to protect you and the platform if fraudulent or unauthorized activity is detected.
  1. Description of the Virtual KES Account Service

Holding a KES Balance: 

  • The Virtual KES Account allows you to store, transfer, receive, and manage funds in Kenyan Shillings (KES) within the NALA platform.

  • Deposit and withdraw funds through supported channels
  • Convert funds between KES and other supported currencies

  • You may convert their foreign currency into KES at the prevailing exchange rate shown in the NALA app

  • You will not earn interest on the account & it is purely for payment/transfer purposes.

  • All funds are held by our Partner,

  • While we cannot guarantee coverage beyond regulatory schemes, we ensure our Partner complies with all safeguarding requirements. 

Switching Partners: 

  • NALA may change the Partner at any time.
  • We will ensure that any new Partner is appropriately licensed and that your funds are transferred safely to the new Partner with minimal disruption. 
  • These Terms govern the service regardless of which specific institution we use. If a change of Partner requires any amendments to the Terms, we will notify you.

Topping up funds

  • You can add money to your KES Account through the supported channels & undertake conversion  
  • The App will display the exchange rate and any fees before you confirm the conversion. Upon conversion, the KES amount will be credited to your Account balance. 
  • Exchange rates can fluctuate & we are not responsible for any gain or loss due to currency fluctuations

Fee Disclosure: 

  • NALA may charge a fee or commission for the conversion or transfer, which will be clearly disclosed to you before completing a transaction. 
  • By proceeding, you accept the exchange rate and fees shown.

Accuracy of Recipient Details: 

  • You are responsible for providing the correct recipient information.

Transaction Limits: 

  • For security and compliance, NALA and or/ the Partner may impose limits on transactions.
  • These can include maximum amounts per transaction, daily or monthly send limits, or maximum Account balance.
  • Limits may vary depending on your verification status and the regulatory requirements
  • We will inform you of relevant limits in the app or on our website. NALA (or the Partner) may also delay or hold a transaction if it needs to verify that the transaction complies with law and these Terms. 
  • In some cases, additional information may be requested from you before a transaction can proceed 

Transaction History: 

  • You can view your KES Account balance and a history of transactions at any time via the NALA app. It is your responsibility to review your transaction history regularly and promptly report any errors.
  1. User Obligations and Acceptable Use

By using the Virtual KES Account, you agree to the following:


Lawful Purposes Only:

  •  You will only use the service for legitimate purposes that comply with all applicable laws and regulations.
  • You will not sell, rent, or transfer your account to any other person.
  •  Prohibited activities include, but are not limited to: money laundering, terrorist financing, fraud, sanctions violations, or any activity that would violate applicable law 


Compliance with AML/CFT: 

  • You will not attempt to circumvent KYC/AML procedures. 
  • You will cooperate with any requests for additional information or documentation regarding your identity or transactions, as required for compliance. 
  • If we and or/Partner detect any transaction that may violate AML/CFT laws or our internal policies, we reserve the right to reject, block, or hold such a transaction and freeze your account while we investigate.
  •  We and or/our Partner may, without liability, refuse to execute any transfer or allow any withdrawal if we reasonably suspect it’s connected to unlawful activity.
  • You acknowledge that NALA may share your relevant information with the Partner as needed to provide the service, and vice versa, the Partner may share information with NALA

No Unauthorized or Fraudulent Use: 

  • You must not misrepresent your identity or the purpose of transactions. 
  • You will not use the service to defraud anyone or engage in any form of financial scam. If you receive funds in your Account that you know or suspect were sent in error or through fraud, you must notify NALA and not withdraw or use those funds. We may reverse or hold funds that are reported as mistaken or fraudulent.

 Information Accuracy: 

  • Any information you provide (to NALA, to our Partner) must be truthful and accurate. This includes personal details, recipient details, and transaction descriptions. 
  • Providing false information is a breach of these Terms and could also be a legal offense.
  1. No Warranty by NALA for Third Parties:
  • NALA and its third-party providers strive to keep services available, secure, and accurate, but we make no guarantee that the Service will always be error-free or uninterrupted. The Service is provided on an “as-is” basis 
  • We may need to perform updates to improve the service or address issues. 
  • We are not liable for any losses due to planned downtime.
  • NALA will not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, arising from your use of or inability to use the Virtual KES Account service.
  • We are not liable for losses caused by unauthorized access to your account (unless such access was due to our failure to implement reasonable security measures), losses or fees due to incorrect information you provided, or losses arising from actions taken by regulatory authorities or third parties.
  • The Service may also be limited or suspended in certain extraordinary circumstances, including force majeure events (natural disasters, major internet outages, etc.), war, civil unrest, or if required by government order. We will inform you as soon as feasible of any such suspension.
  1. Indemnification: 
  • You agree to indemnify and hold harmless NALA and its affiliates, officers, employees, and agents from any claim, demand, losses, or damages (including legal fees) arising out of or related to your breach of these Terms or your violation of any law or rights of a third party in using the Service. 
  1. Unclaimed Funds: 

If you have a balance in your KES Account that remains unused and you have not logged into the NALA app or transacted for an extended period, NALA may be required by law to consider the account dormant. 

We will attempt to contact you using the information we have before taking steps such as sending funds to a government authority if applicable. Kenyan law on dormant accounts will be followed, which may involve transferring unclaimed funds to authorities after a dormancy period. To avoid this, keep your contact details updated and respond to any communications about inactivity.

  1. Customer Support: 

We encourage you to contact NALA’s customer support for any issues or disputes. Many problems can be resolved quickly by contacting us through the in-app chat or via our support email/phone. 

We will do our best to resolve your complaint or query promptly and fairly. When you contact us, please provide your name, registered phone/email, and a clear description of the issue.

  1. Governing Law and Jurisdiction: 

These Terms and any dispute arising from them or the Virtual KES Account service are governed by the laws of the Republic of Kenya.

If a dispute results in a legal action, it shall be resolved in accordance with the Arbitration Act,1995 of Kenya. The language of the arbitration shall be English, and the decision of the arbitrator(s) shall be binding. However, we encourage resolution through dialogue or mediation before resorting to arbitration.

  1. Changes to the Service or Terms

NALA is constantly improving its services. 

We may add, modify, or remove features of the Virtual KES Account from time to time. We may also amend these Terms as needed to reflect changes in the service or for legal reasons.

  1. Notification of Changes:

If we make material changes to these Terms, we will notify you in advance by email or via an in-app notification, except in cases where changes must be implemented due to legal/regulatory requirements.

  1. Acceptance of Changes:

Continued use of the Virtual KES Account service after notice of updated Terms constitutes your acceptance of the revised Terms.

If you do not agree to the changes, you have the right to stop using the service and request closure of your account.

  1. Termination and Suspension

User-Initiated Closure: 

You may terminate your use of the Virtual KES Account service at any time by giving notice to NALA

Upon closure, you will be prompted to withdraw any remaining KES balance. You can convert the KES to your desired currency and withdraw to your external account, or send the KES to a beneficiary of your choice. I

If you do not withdraw the balance, we will make reasonable attempts to contact you to arrange the return of funds. 

NALA-Initiated Suspension/Termination: 

We may, at our discretion, suspend or terminate your access to the service with or without notice if: (a) we suspect that you have breached these Terms or violated any applicable law; (b) we detect unauthorized or fraudulent use of your account; (c) you fail to comply with KYC/AML requirements (e.g., not providing requested identification info); (d) we are directed by a regulatory or law enforcement authority to do so; or (e) continuing to provide the service to you would expose NALA or our Partner(s) to undue risk or legal liability.

Effect of Termination: 

Upon termination, your right to use the Virtual KES Account ceases. 

These Terms, which by their nature should survive termination (such as dispute resolution, governing law, liability, and indemnity), will continue to apply even after your account is closed.

  1. No Waiver:

 If NALA does not enforce a provision of these Terms in some instance, that does not mean we have waived our right to enforce it later. Any waiver of rights by NALA must be explicit and in writing.

  1. Severability: 

If any part of these Terms is found to be invalid or unenforceable by a court (or arbitrator), the rest of the Terms shall remain in effect. We would modify the invalid part to the minimum extent necessary to make it enforceable (or, if that’s not possible, sever it and the rest still stands).

  1. Assignment: 

You may not assign or transfer any rights or obligations under these Terms to anyone else without NALA’s prior written consent. 

  1. Entire Agreement: 

These Terms (along with the Privacy Policy and any supplements we provide that are applicable, which are hereby incorporated by reference) constitute the entire agreement between you and NALA regarding the Service. They supersede any prior agreements or understandings about the Service.

Contact Information: NALA’s customer support and contact details can be found in the app and on our website.

‍

Send Love Home

Community

Our roadmapLive updatesBuild with NALANALA Merch StoreNALA Partner Programs

Company

Our StoryPurposeCareersFAQsOur BlogPressLicenses

Transparency

Terms of ServicePrivacy PolicyCookiesStay safeComplaints Procedure
In the United Kingdom, NALA Payments Ltd is a registered EMD agent of Modulr FS Limited, which is an Electronic Money Institution authorised by the Financial Conduct Authority with firm reference number 900573. Electronic Money products are not covered by the Financial Services Compensation Scheme (FSCS). Customer funds will be held in one or more segregated accounts and safeguarded in line with the Electronic Money Regulations 2011. For more information, please see Modulr’s UK Safeguarding Explanation here.

In the European Union, NALA Payments Netherlands B.V. is a partner of Modulr Finance B.V., a company registered in the Netherlands with company number 81852401, which is authorised and regulated by De Nederlandsche Bank (DNB) as an Electronic Money Institution (relationship number R182870) for the issuance of electronic money and payment services. Your account and related payment services are provided by Modulr Finance B.V. Your funds will be held in one or more segregated accounts and the full value safeguarded in line with the Financial Supervision Act.

In the United States, Nala Inc. partners with the financial services software company, Sila Inc. (“Sila”) and Priority Technology Holdings Inc. (“Priority Commerce”), either directly or through its subsidiary Finxera, Inc. (NMLS #1168701) and/or its authorized affiliates, contractors and partners (including but not limited to the following Banks: Wells Fargo, N.A., Comerica Bank, Axos Bank, and Western Alliance Bank) to offer you electronic fund transfers and provide you with an account. Nala Inc. is a financial technology company, not a bank.

Mufasa Payments LLC, a subsidiary of Nala Inc., partners with Lead Bank (NMLS #635532) to offer you electronic fund transfers and provide you with an account. Mufasa Payments LLC is a financial technology company, not a bank.

In certain states in the United States where it holds the necessary licenses, money transmission services may be provided by Nala Payments LLC (NMLS: 2530895), a subsidiary of Nala Inc., pursuant to its own state-issued money transmitter licenses and registration as a Money Services Business (MSB) with the United States Treasury Financial Crimes Enforcement Network (MSB: 31000335047569). In such cases, the partnership with Mufasa Payments LLC, Sila Inc. and Lead Bank N.A. may not be utilized or required. The availability of services and regulatory status may vary by geographic location and customer location.

© Copyright NALA INC 2026.