1. Policy Objective

This Next of Kin/Beneficiary Fund Access Policy (the “Policy”) sets out the procedure for the release of funds held in the account of a deceased user (the “Deceased User”) on Grey’s platform (the “Platform”). The objective of this Policy is to establish a transparent, fair, and legally compliant framework for handling such requests from verified Claimants (hereinunder defined), while ensuring the protection of the Deceased User’s interests, upholding the rights of legitimate Claimants, and mitigating risks such as fraud or unauthorised claims.

Grey will facilitate this process in a manner that is respectful, efficient, and consistent with applicable laws, including succession, probate, data protection, and anti-money laundering regulations in the relevant jurisdiction.

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2. Scope

2.1. This Policy applies to:

1. All individual accounts maintained on the Platform;
2. All Claimants of Deceased Users, including Next of Kin (NOK), Legal Representatives, and Beneficiaries;
3. All jurisdictions in which Grey operates, subject to jurisdiction-specific legal requirements or procedural modifications;
4. All relevant internal departments of Grey, including but not limited to Customer Support, Risk, Compliance, Legal, and Finance.

2.2. This Policy governs the end-to-end procedure for receiving, verifying, and processing claims for access to or disbursement of funds from a Deceased User’s account.

3. Definitions

For the purpose of this Policy:

“Beneficiary” means an individual entitled to a share of a Deceased User's estate either by virtue of a valid will or in accordance with applicable intestacy laws.

“Claimant” means a person (including a NOK, Beneficiary, or Legal Representative) seeking access to funds held in the Deceased User’s Grey account.

“Deceased User” refers to a registered and verified Grey account holder whose death has been confirmed by acceptable documentary evidence.

“Grey” means Grey Inc., its subsidiaries, affiliates, and all entities offering financial services via the Platform.

“Legal Representative” means a person appointed by a court to act on behalf of a Deceased User’s estate, including executors and administrators.

“Next of Kin” or “NOK” refers to the closest living relative of the Deceased User under applicable law or as designated by the Deceased User prior to death.

“Platform” includes all interfaces through which Grey delivers its services, including websites, mobile applications, and other digital platforms.

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4. General Principles

4.1. Grey will only release a Deceased User funds upon the receipt of satisfactory evidence of the user’s death and the legal entitlement of the Claimant.

4.2. The following principles shall guide the administration of claims:

1. Disbursement shall be made in accordance with the applicable succession laws governing the Deceased User’s domicile or account.
2. Grey reserves the right to request additional documentation or clarification as may be necessary to ascertain the validity of any claim.
3. All claims shall be handled with discretion, sensitivity, and respect for the privacy of all parties concerned.
4. Grey may seek legal counsel in complex or disputed cases and may withhold disbursement pending resolution of such issues.

5. Notification of Death

5.1. To initiate the claims process, the Claimant shall notify Grey of the death of a user in writing, through any of the following approved channels:

1. Email: support@grey.co
2. Customer Support Portal: 

5.2. The notification should contain the following information:

1. Full name of the Deceased User;
2. Email address or phone number registered with the account;
3. Date of death;
4. Contact information of the Claimant.

5.3. Grey will acknowledge receipt of the death notification within forty-eight (48) hours and provide further guidance on the next steps and documentation required.

6. Account Handling Upon Notice of Death

6.1. Upon confirmation of a Deceased User’s death, Grey shall take the following immediate steps:

1. Flag and temporarily freeze the Deceaser User’s account to prevent further access, withdrawals, or transfers;
2. Suspend all automated transactions, linked cards, and financial instruments;
3. Disable login access and terminate communication functionalities associated with the account.

6.2. These measures will remain in place pending the completion of the verification and claims process.

7. Documentation Requirements

To assess and validate any claim, Grey requires the submission of the following documents:

7.1. Mandatory Documentation

1. A certified copy or original Death Certificate of the Deceased User;
2. A valid, government-issued photo identification of the Claimant;
3. Proof of relationship to the Deceased User, such as:
   
   1. Birth Certificate (for children);
   2. Marriage Certificate (for spouse);
   3. Sworn Affidavit or notarised Family Declaration (for other relatives);

Proof of account ownership, which may include:

• The email address or mobile number linked to the account;
• Recent transaction references or account statements.

7.2. Additional Documentation (Where Applicable)

1. A Will and Testament (if one exists);
2. A Letter of Administration or Grant of Probate issued by a competent court;
3. A Court Order (in the event of legal ambiguity or dispute);
4. Evidence of identification of other known beneficiaries, if multiple parties are involved.

7.3. Grey reserves the right to request further information or documentation as may be required under applicable law or internal risk controls

8. Claim Assessment and Verification Process

8.1. Initial Review

Upon submission of a complete claim, Grey’s Legal team will:

1. Acknowledge receipt within five (5) business days;
2. Review all documentation for authenticity and completeness;
3. Conduct independent verification with relevant public or issuing authorities.

8.2. Dispute Resolution

In the event of conflicting claims, legal ambiguities, or contested documentation:

Grey shall suspend disbursement until the matter is resolved;

1. A court order or a mutually executed indemnity agreement from all potential beneficiaries shall be required to proceed.

8.3. Decision Timeline

1. Where all documentation is in order and uncontested, Grey shall issue a decision within ten (10) to fifteen (15) business days;
2. Complex or disputed claims may require up to thirty (30) business days, or such additional time as required for judicial or regulatory resolution.

9. Disbursement Procedure

9.1. Payment Options

Upon successful verification and absent any legal impediments, Grey shall:

1. Permanently freeze the Deceased User’s account to prevent future transactions;
2. Disburse the available funds to the Deceased User’s estate account, if established; or
3. Transfer funds to the verified and legally entitled Claimant(s), in line with court instructions or succession laws.

9.2. Record Retention

Grey shall maintain comprehensive records of all claims, communications, and supporting documents for a minimum period of seven (7) years. All disbursement transactions will be auditable and subject to internal and regulatory scrutiny.

10. Data Protection and Confidentiality

10.1. Grey will protect the personal and financial information of all parties involved in accordance with applicable data privacy laws, including the Nigeria Data Protection Act 2023, the United Kingdom General Data Protection Regulation (GDPR) /EU GDPR, and any other relevant statutes.

10.2. All information received will be processed solely for the purposes of verifying and administering the claim;

10.3. No personal information will be disclosed to unauthorised third parties;

10.4. Data access is restricted to relevant personnel with a legitimate need to know.

11. Fraud and Dispute Management

11.1. Fraud Prevention

To safeguard against fraudulent claims:

1. All Claimants must undergo KYC verification;
2. Documents will be cross-referenced with issuing agencies where applicable;
3. Grey reserves the right to report suspected fraud to appropriate law enforcement or regulatory bodies.

11.2. Dispute Resolution

Where conflicting claims or litigation arise:

1. Grey will withhold disbursement until formal resolution is obtained;
2. A valid court order or jointly signed indemnity agreement shall be required before any funds are released;
3. Grey shall not be liable for delays resulting from disputes between Claimants or third parties.

12. Fees and Charges

Grey does not charge any administrative or processing fees for valid Claimant claims. However, Claimants shall bear any incidental costs incurred in procuring documentation (e.g., notarisation, legal representation, or court filings).

13. Governing Law

This Policy shall be governed by and construed in accordance with the laws of the jurisdiction wherein the Deceased Users are accessing Grey’s services. Any disputes arising from the application of this Policy shall be subject to the exclusive jurisdiction of the courts in the said jurisdiction.

Grey shall also comply with applicable succession and probate laws in the jurisdiction of the Deceased User, anti-money laundering (AML) and counter-terrorism financing (CTF) regulations, contractual obligations under Grey’s user agreement, relevant consumer protection and data privacy laws.

14. Policy Review and Updates

Grey’s Legal and Compliance Department will review and update this Policy annually or as required by law or internal needs.

15. Contact Information

For further information or to initiate a claim under this Policy, please contact support@grey.co