Legal
Creator Due Diligence Note
Creator Due Diligence and Pre-Settlement Controls Note
The due diligence, compliance, fraud prevention, and risk-control measures applied to content creators onboarding onto the Genius Home platform and prior to settlement of funds.
1. Purpose
This Note summarizes the due diligence, compliance, fraud prevention, and risk-control measures applied by ORBITE HOLDING in relation to content creators onboarding onto the Genius Home platform and prior to settlement of funds to such creators.
Genius Home is a digital learning and educational content platform operated by ORBITE HOLDING. The platform may permit approved creators, instructors, authors, publishers, trainers, or institutions to upload, distribute, and monetize educational content, digital products, and related services.
The purpose of this Note is to demonstrate the risk-based controls applied by ORBITE HOLDING to:
- verify the identity and legitimacy of creators;
- prevent fraud, money laundering, terrorist financing, sanctions breaches, identity abuse, and other illicit activity;
- ensure that settlements are made only to duly verified and compliant creators;
- maintain the integrity and lawful operation of the Genius Home platform.
2. Scope
This Note applies to:
- individual content creators;
- business entities, institutions, schools, training centers, and other organizations onboarding as creators;
- all creator accounts eligible for settlement or payout through the Genius Home platform;
- pre-onboarding, onboarding, post-onboarding monitoring, and pre-settlement review processes.
3. Due Diligence at Onboarding
Before any creator is approved to monetize content or receive settlement through Genius Home, ORBITE HOLDING performs due diligence proportionate to the creator's profile, activity, risk level, and jurisdiction.
3.1 Identification and Profile Information
For individual creators, ORBITE HOLDING collects and reviews, as applicable:
- full legal name;
- date of birth;
- nationality;
- telephone number;
- email address;
- residential address or location information;
- valid government-issued identification document.
For institutional or business creators, ORBITE HOLDING collects and reviews, as applicable:
- legal entity name;
- registration number or equivalent corporate identification;
- tax identification number, where applicable;
- registered address;
- business contact details;
- identity of authorized representative(s);
- names of directors, controllers, and beneficial owners, where applicable.
3.2 Identity Verification
ORBITE HOLDING verifies creator identity using documentation and information reasonably appropriate to the creator type and risk profile. Such verification may include:
- national identity card, passport, residence permit, or other valid official identification;
- corporate incorporation documents, RCCM extract, certificate of registration, or equivalent legal proof of existence for entities;
- confirmation that submitted details are consistent across the profile, supporting documents, and proposed payout destination.
3.3 Content and Business Activity Review
ORBITE HOLDING conducts a review of the proposed creator activity on the Genius Home platform, including, where relevant:
- content category and subject matter;
- intended business model or monetization model;
- sample content, creator profile, social media presence, website, or other public-facing information;
- assessment against prohibited, restricted, illegal, infringing, deceptive, or high-risk content categories.
Creators are required to confirm that content uploaded or offered on the platform is lawful, original or properly licensed, non-infringing, and compliant with the platform's terms and policies.
3.4 Geography and Risk Review
As part of onboarding, ORBITE HOLDING considers geographic and jurisdictional factors, including:
- country of residence or incorporation;
- country of operation;
- whether the creator is associated with a sanctioned, prohibited, embargoed, or otherwise restricted jurisdiction;
- whether enhanced due diligence is required because of elevated geographic or business risk.
3.5 Screening and Compliance Checks
ORBITE HOLDING may conduct screening and internal checks, proportionate to risk, including:
- internal blacklist screening;
- fraud history checks;
- duplicate-account detection;
- sanctions, politically exposed person, or adverse-information screening where applicable and available;
- review of prior complaints, abuse indicators, or platform policy concerns.
3.6 Payout and Settlement Profile Verification
Before approving a creator for settlement eligibility, ORBITE HOLDING reviews:
- the proposed mobile money wallet, bank account, or other payout channel;
- consistency between creator identity and payout details;
- expected activity level, expected transaction volume, and plausible business rationale;
- unusual or elevated-risk settlement patterns identified at onboarding.
3.7 Contractual Acceptance
All creators must accept the Genius Home platform terms and applicable compliance requirements, including obligations relating to:
- lawful use of the platform;
- prohibition of fraud, impersonation, misrepresentation, and illegal content;
- intellectual property compliance;
- cooperation with verification requests;
- ORBITE HOLDING's right to request additional documentation, restrict account activity, delay settlement, suspend access, or terminate the relationship where risk concerns arise.
4. Ongoing Monitoring After Onboarding
Creator due diligence is not limited to the point of onboarding. ORBITE HOLDING applies ongoing monitoring proportionate to risk, including:
- review of creator behavior and account activity over time;
- monitoring of complaints, disputes, fraud signals, abuse reports, and policy violations;
- periodic refresh of KYC/KYB documentation where necessary;
- reassessment of creators whose activity materially changes in nature, value, velocity, or geography.
5. Controls Prior to Settlement
Before settlement of funds is made to a creator, ORBITE HOLDING applies pre-settlement controls designed to ensure that payout is made only where the creator remains duly verified and no material risk indicator is present.
These controls may include:
- confirmation that onboarding due diligence is complete and current;
- confirmation that the creator account remains in good standing;
- verification that payout details remain consistent with the approved profile;
- review of unusual transaction patterns, including spikes in revenue, structuring patterns, mismatched commercial behavior, repeated disputes, or suspicious payment activity;
- review of complaints, takedown notices, copyright disputes, fraud claims, or policy breaches;
- risk-based re-screening or manual review where needed.
Where risk flags arise, ORBITE HOLDING may:
- place the settlement on hold;
- request further information or supporting documents;
- escalate the matter internally for compliance review;
- suspend or reject settlement;
- restrict or terminate the creator relationship where justified.
6. Recordkeeping
ORBITE HOLDING maintains appropriate records relating to creator onboarding, verification, activity review, settlement review, and internal decisions in accordance with applicable legal, operational, and compliance requirements.
7. Compliance Governance
Responsibility for implementation of this Note rests with GENIUS HOME / ORBITE HOLDING management and such designated operational, finance, risk, legal, or compliance personnel as may be appointed from time to time.
8. Reservation of Rights
ORBITE HOLDING reserves the right, at any time and at its sole discretion, subject to applicable law and contract, to:
- request additional identification or business records;
- re-perform due diligence;
- refuse or delay settlement;
- suspend or terminate creator access;
- report suspicious or unlawful activity to competent authorities where required.
Questions about Creator Due Diligence?
For compliance, onboarding, or verification enquiries, our team is ready to assist.
Get yourself a future as you take the endeavor to become the best
We make sure we give you every single thing you need for your online study
Scan to download Genius Home app now.
Available on Appstore & Playstore.
