The purpose of the following Trading Procedures, Policies, Rules and Regulations is to facilitate trading among members of Organizations by promoting a system of good business practice and understanding of the guidelines set forth by various trading networks and organizations that work together with Grassroots Economics Foundation (GEF) Sarafu Network (SC), an website of GEF, hereinafter referred to as Sarafu Network. These Trading Procedures, Policies, Rules and Regulations also form part of and are included in any voucher or community currency verified, digitally created or printed and allocated by Sarafu Network, including but not limited to: all Community Currency, Community Asset Voucher or Token Programs, Commitment Pools, Swap Pools, Sarafu, Bangla-Pesa, Gatina-Pesa, Ng'ombeni-Pesa, Lindi-Pesa and Kangemi-Pesa.
1. NATURE OF THE PARTIESA Client is an individual or legal entity that voluntarily uses the Sarafu Network to exchange commitments for goods and/or services among its members and to create vouchers and/or commitment pools to facilitate barter-based trade. By using the Sarafu Network—whether in paper form or digitally via the sarafu.network platform—the Client agrees to abide by these Trading Procedures, Policies, Rules, and Regulations. The Sarafu Network functions as a facilitator of voucher pooling systems and as an auditor of all vouchers and pools transacted through the platform.
2. NATURE OF VOUCHERS and TOKENS on SARAFU NETWORKA Voucher or Token on the Sarafu Network is a digital or physical accounting unit used to record the exchange of commitments for goods and/or services among participants. These instruments are not purchased or sold but represent commitments that can be offered, accepted, added to, or swapped within pools, or sent to other users with accounts on the Sarafu Network. Ownership of a Voucher or Token constitutes the voluntary acceptance of a gift and does not confer any legal right to redeem goods, services, or national currency. Vouchers and Tokens are not legal tender, securities, or commodities and have no guaranteed value in Kenyan Shillings. Sarafu Network disclaims responsibility for the negotiability of any Voucher or Token or the availability of goods or services from any source. Physical vouchers are issued with an expiration or maturity date (the term), after which they hold no redeemable value. All accounts holding Vouchers or Tokens may be subject to periodic holding taxes on a weekly or monthly basis.
3. STANDARDS AND TRANSPARENCYSarafu Network serves as a third-party record keeper and auditor, supporting the development and operation of peer-to-peer voucher exchange systems among Clients. Each Client undergoes a verification process that includes completing a questionnaire and identifying their commitments. This audit helps determine if a Voucher or Pool contract will be permitted on the Sarafu Network. The quantity and type of Vouchers allocated to each Client are based on the size and nature of their commitments. Sarafu Network functions as an interface to the Celo Blockchain, where Vouchers and Pool contracts are published as smart contracts. Once published, these are non-custodial—Sarafu Network does not hold or control any Client assets or tokens on their behalf.
4. COORDINATING FUNCTIONSarafu Network serves in a coordination capacity by helping to organize and facilitate exchanges of commitments among Clients and their members. Responsibility for the quality, fulfillment, and terms of any exchange lies entirely with the participating Clients. It is the accepting Client’s duty to inspect goods or services that vouchers represent for quality, quantity, and suitability. Sarafu Network may support visibility and tracking of exchanges through its platform, but it does not act as a broker or guarantor. All exchanges are voluntary, and the sole principals in each exchange are the Clients involved. Vouchers issued on the Sarafu Network are ultimately backed by the goods, services, and commitments of the issuing Client, and not by Sarafu Network itself.
5. EXCHANGE PARTICIPATIONSarafu Network, or any of its affiliated or owner entities, may maintain an account on the system and participate in the exchange of commitments, provided they abide by the same terms and conditions as all other Clients. Any Pools, Vouchers or Tokens associated with such accounts must be audited, allocated, and managed using the same verification and transparency criteria applied to all Clients. These entities shall not receive privileged access to goods, services, visibility, or special treatment within the network.
6. AVAILABILITY OF PRODUCTS OR SERVICESSarafu Network will use its best efforts to invite and support new Clients who offer to create pools and commitments to goods or services that meet the needs of the network. Due to high demand or limited supply, certain items or services may only be available intermittently or in restricted quantities (e.g., appliances, electronics, furniture, travel services, tools, etc.). Sarafu Network remains committed to transparently reflecting the actual availability of commitments, goods, and services within the exchange system.
7. DEFINITION OF CLIENT IN GOOD STANDINGA Client—and all associated members—who exchanges commitments in accordance with this agreement, maintains current payment of any applicable fees to Sarafu Network, and holds valid, unexpired Vouchers, is considered a ‘Client in good standing’. Only Clients in good standing are entitled to continued access to the Sarafu Network’s services. However, this status does not imply any guarantee or endorsement by Sarafu Network regarding the reputability, reliability, or quality of any buyer, seller, goods, or services within the network. If a Client, by action or omission, fails to meet basic standards of quality, is charged with fraudulent activity or misconduct, or significantly damages their reputation, Sarafu Network—through Grassroots Economics Foundation—reserves the right to suspend or terminate the Client’s participation. Restoration of privileges may require evidence of corrective actions and a return to acceptable standards of quality and transparency.
8. DUTIES OF CLIENTIf a Client fails to inform Grassroots Economics Foundation (GEF) of membership or regisred voucher changes for more than sixty (60) days, the Client waives all rights to use any Voucher beyond their original allotments. In such cases, each member of the Client may be required to return the Vouchers initially allotted to them. At the discretion of Sarafu Network, an account closed due to lack of transparency may be reactivated within one hundred and eighty (180) days, during which time the Client may reclaim their trade Vouchers. Additionally, 0.5% of a Client’s balance will be deducted weekly and added to a reward pool, which is distributed to active users.
10. CHARITABLE DONATIONSA Client may choose to donate Vouchers or Tokens to a qualified charitable organization or individual in the form of a Pool. A ‘qualified charitable organization’ is one that holds recognized charitable status from the Kenya Revenue Service and is, or agrees to become, a registered Client on the Sarafu Network. Sarafu Network may facilitate the donation by allocating the Client’s Vouchers accordingly - such as into a pool; however, the donation is considered to originate from the Client. The Client bears full responsibility for confirming the charitable status of the recipient and for any applicable tax implications. Transfers of donated Vouchers will be made upon written notification from the Client specifying the amount and the intended recipient organization. Any receipts required for tax or legal purposes must be issued directly by the charitable organization to the Client.
11. LAWS AND REGULATIONSClients are responsible for complying with all applicable local, county, and national laws and regulations relevant to their business operations and any exchanges conducted on the Sarafu Network. Sarafu Network assumes no liability for a Client’s failure to comply with such laws. Clients agree to hold Sarafu Network harmless for any actions it may take in good faith to comply with applicable legal or regulatory requirements.
12. TIPS AND GRATUITIESAll tips and gratuities must be paid in cash by the buying Client at the point of exchange. Sarafu Network does not record or facilitate the tracking of tips or gratuity payments.
13. TAXESClients offering Vouchers to others in return for National Currency are responsible for charging and collecting any applicable sales tax or VAT in cash at the time of the exchange, and must document these amounts on the invoice. Sarafu Network does not collect taxes on behalf of its Clients. Clients are advised that exchanges involving Vouchers or Tokens may be treated as taxable events by the Kenya Revenue Authority and relevant local authorities. The responsibility for declaring, reporting, and paying all applicable Local, County, and National taxes rests solely with the Client. Clients agree to hold Sarafu Network harmless for any actions it may take to comply with Kenyan tax laws.
14. ASSIGNMENT OF ACCOUNTA Client’s account on the Sarafu Network is not assignable or transferable to any individual, third party, or business entity without prior written consent from Sarafu Network. If assets, goods, or services previously used to support a Client’s Voucher issuance become unavailable—due to sale, transfer, or a business merger—Sarafu Network reserves the right to withdraw the associated Vouchers or request immediate settlement (see Clause 26: Termination). In the event a Client ceases trading and other Pools or Clients are holing the Client's vouchers, that obligation remains secured to Sarafu Network until the balance is restored. Vouchers may not be listed or offered for sale without explicit prior written approval from Sarafu Network.
15. FAIR PRICINGClients agree to offer all commitments for goods and services at their usual prevailing prices, consistent with what they charge outside the Sarafu Network. Sarafu Network reserves the right to investigate any complaints of overpricing, particularly if a Client is found to be charging higher rates when accepting Vouchers compared to cash or other standard terms. Repeated or verified violations of fair pricing practices may result in suspension or termination of the Client’s account.
16. SUSPENSION OF TRADING PRIVILEGESSarafu Network reserves the right, at its sole discretion, to suspend the trading privileges of any Client who:
In the event of such suspension, Sarafu Network will issue a written notice to the Client, who must immediately cease using the exchange system.
17. TERMINATIONEither party may terminate this agreement, with or without cause, by providing ten (10) days’ written notice to the other party. Upon termination, all outstanding cash fees and service charges become immediately due and payable. Transaction fees are non-refundable.
If the Client has a negative Voucher balance (i.e., exchanged more than contributed) at the time of termination, the Client must restore the account to balance using Vouchers within thirty (30) days. If the negative balance is not resolved within that time, the Client must repay the equivalent value in cash. Failure to do so may result in legal action to recover the outstanding amount in Kenyan Shillings (KSH), including legal costs. Sarafu Network also reserves the right to assign the debt to a licensed Debt Collection Agency.
If the Client has a positive Voucher balance (i.e., contributed more than exchanged) at the time of termination, the Client may remain active for up to thirty (30) days solely to use the remaining balance for purchases. During this period, the Client must prepay the applicable cash service fees. Any positive balance not used within thirty (30) days of termination shall be forfeited.
18. AMENDMENT OF TRADING PROCEDURES, POLICIES, RULES AND REGULATIONSSarafu Network may, at its sole discretion, amend these Trading Procedures, Policies, Rules, and Regulations, including changes to annual retainer fees and transaction fees. Clients will be given thirty (30) days’ prior written notice of any such changes. If the Client does not submit written rejection within this thirty (30) day period and continues to participate in the network through any exchange of commitments, this will be considered acceptance of the new terms. Any amendment to this agreement must be made in writing and signed by an authorized representative of Sarafu Network to be valid.
19. DISCLAIMER OF LIABILITYSarafu Network makes no warranties—express or implied—regarding the fitness, quality, delivery, pricing, or merchantability of any goods or services exchanged through the network. Clients acknowledge that all exchanges are voluntary and that Sarafu Network is not responsible for the outcome or fulfillment of any transaction. The Client agrees to indemnify and hold Sarafu Network harmless from any claims, debts, disputes, or liabilities arising from their participation as a buyer or seller. This includes any liability related to the use, administration, or technical operation of the Sarafu Network platform.
20. DISPUTES AND ARBITRATIONSarafu Network acts solely as a trade coordination platform and third-party record keeper, and shall not be held liable for disputes arising from transactions between Clients. In the event of a dispute between Clients, the parties agree to submit the matter to binding arbitration under the rules of the Kenyan Arbitration Association within twenty-one (21) days from the receipt of goods or services, or from the initiation of the dispute. The decision of the arbitrator(s) shall be binding and, unless both parties agree otherwise, may be submitted to a court with appropriate jurisdiction for enforcement as a judgment.
21. ENFORCEMENTEach provision of these Trading Procedures, Policies, Rules, and Regulations is independent and severable from the others. If any specific term is found to be invalid, illegal, or unenforceable, the remaining provisions shall remain fully valid and enforceable. In the event that Sarafu Network must take legal action to enforce any part of this agreement, it shall be entitled to recover legal fees, administrative costs, and late fees of $20 per month from the date of default until full payment is received.
22. ADVERTISINGUnless otherwise agreed in writing, the Client authorizes Sarafu Network to promote the availability of the Client’s goods or services to other Clients within the network.
23. SPECIAL TRADE PROCEDURESThe following procedures apply to special orders, construction projects, service work, long-term leases, and other work-in-progress exchanges: 1) The Client should obtain a written estimate before authorizing work to begin. 2) Prior to starting, the Client should secure a deposit or down payment in Vouchers or Tokens, confirmed via the Sarafu Network platform (online, SMS authorization, or physical voucher if applicable), similar to a cash transaction.
24. CONFIDENTIALITY AND NON-DISCLOSUREAs a Client of the Sarafu Network, the Client may access confidential and proprietary information belonging to Sarafu Network or other Clients. The Client agrees not to disclose any such information—including software details, account or contact data, Client lists, or email addresses—except to authorized parties. The Client must also take reasonable steps to protect the confidentiality and security of all such information.
25. JOINT AND SEPARATE LIABILITYBy accepting this agreement and opening an account on the Sarafu Network, both the Client and the individual signing on behalf of the Client assume joint and separate responsibility for all commitments, transactions, and fees incurred under this agreement.
26. DISSOLUTIONIf Sarafu Network is terminated or ceases operations, all Clients with a negative Voucher balance (i.e., who have received more than they contributed) shall be required to repay their outstanding balances in cash, calculated at the rate of one Voucher equaling one Kenyan Shilling. These repayments will be placed into a fund. After deducting administrative expenses, the remaining fund and any available Sarafu Network inventory will be distributed proportionally to Clients who hold a positive Voucher balance. Clients in a positive position may receive cash and/or goods, depending on available resources. Sarafu Network shall have no further obligation to honor any Client’s Voucher balances beyond this final distribution. The cessation of Sarafu Network operations does not absolve any Client of outstanding obligations.
28. LAWIn the event of any legal dispute arising from these Trading Procedures, Policies, Rules, and Regulations, the laws of Kenya shall apply. All transactions using Vouchers on the Sarafu Network shall be treated as forms of barter trade.
1. Central Bank of Kenya Act Cap 491 - Section 21 states: "All monetary obligations or transactions entered into or made in Kenya shall be deemed to be expressed and recorded, and shall be settled, in Kenya currency unless otherwise provided for by law or agreed upon between the parties."
This provision affirms that parties in Kenya may agree to transact in alternative forms—including foreign currency or barter—so long as both parties consent.
2. Interpretation and General Provisions Act Cap 2 - Section 3 defines the term “sell” to include: “barter, exchange and offer to sell or expose for sale.”
These legal definitions confirm that barter is recognized as a lawful form of trade under Kenyan law, treated as a standard commercial transaction.
None of the statutes reviewed expressly prohibits or deems barter trade to be illegal activity.Conclusion: Barter trade is a legally valid and recognized method of exchange in Kenya. Legal violations would only arise if an entity attempted to counterfeit legal tender, which is a criminal offense under the Penal Code Cap 63. Notably, the use of community Vouchers such as Bangla-Pesa has been previously reviewed by the Office of the Director of Public Prosecutions and found not to have violated laws under the CBK or KRA Acts. See related comments from the Office of the D.P.P. here.
28. CLIENT ACKNOWLEDGMENTS AND WARRANTYThe Client acknowledges that they have read, understood, and agreed to the currently effective Trading Procedures, Policies, Rules, and Regulations. The Client further acknowledges that these terms may be amended from time to time by Sarafu Network, in accordance with the procedures outlined herein. The Client warrants that all information provided to Sarafu Network has been submitted in good faith and is accurate to the best of their knowledge.
29. COMMITMENTS AND REPRESENTATIONSSarafu Network shall only be held accountable for commitments and representations that are made in writing by a duly authorized officer of the organization. Brokers, agents, or employees do not have the authority to bind Sarafu Network to any obligations or representations without explicit, written authorization.
