Anti-Money Laundering, Counter-Terrorist Financing & KYC Policy

Effective: [EFFECTIVE DATE] · Version 1.0

This is the public summary of how [COMPANY LEGAL NAME] prevents SP-Heavy from being used for money laundering or terrorist financing. It tells merchants what we will ask for and why.

1. Our commitment

Moving money creates an obligation to know who is moving it. We are committed to preventing SP-Heavy from being used to launder criminal proceeds or finance terrorism, and to cooperating fully with the authorities.

We apply a risk-based approach: the depth of our checks is proportionate to the risk a merchant presents, judged on their activity, jurisdiction, transaction patterns and ownership.

2. Applicable framework

Our obligations arise under, among others:

• The CEMAC/UMAC anti-money-laundering and counter-terrorist-financing regulation, as supervised by COBAC and coordinated regionally by GABAC
• Cameroonian law implementing those obligations, including reporting to the national financial intelligence unit, ANIF (Agence Nationale d'Investigation Financière)
• International standards issued by the Financial Action Task Force (FATF)
• Applicable United Nations and regional sanctions regimes

[For counsel: confirm the specific regulation references, the current registration/declaration obligation to ANIF, and whether the entity itself is a "reporting entity" or reports through a licensed partner.]

3. Governance

• A nominated Compliance Officer — [COMPLIANCE OFFICER NAME / ROLE] — is responsible for this programme and is the point of contact for ANIF and supervisors.
• Staff receive AML/CFT training on joining and at least annually.
• The programme is reviewed at least annually and after any material change to our services or regulatory obligations.
• Records of training, decisions and reports are retained per §8.

4. Know Your Customer (KYC)

No merchant may process live payments before verification is approved. The sandbox is open to everyone, because it moves no real money.

Businesses — what we require

• Certificate of incorporation / business registration (RCCM)
• Taxpayer identification (NIU)
• Registered and trading address
• Identity documents for directors and authorised signatories
• Beneficial ownership — the identity of every natural person owning or controlling [THRESHOLD — commonly 25]% or more, with documentation
• A description of the business activity and its expected volumes
• Bank account details in the business's name
• Website or app, and published terms

Sole traders and individuals

• Government-issued photo identity
• Proof of address issued within the last [e.g. 3] months
• Taxpayer identification where applicable
• Description of the commercial activity

Screening

Every merchant, director and beneficial owner is screened against:

• Applicable sanctions lists
• Politically Exposed Person (PEP) status, including close associates and family members
• Adverse media

A PEP relationship is not itself a refusal, but it requires senior approval and enhanced ongoing monitoring.

Enhanced due diligence

We apply deeper checks where a merchant is a PEP, operates in a high-risk sector or jurisdiction, has opaque ownership, presents unusual volumes for their stated business, or where a payment pattern does not match what they described. This may include evidence of source of funds and source of wealth.

5. Ongoing monitoring

Verification is not a one-off. We monitor on a continuing basis for:

• Transactions inconsistent with the merchant's stated business or expected volume
• Sudden changes in volume, value, or geography
• Patterns suggesting structuring — splitting value to stay under thresholds
• Repeated failed or reversed transactions
• Payments concentrated among a small number of payer numbers
• Signs of transaction laundering — processing for an undisclosed third party
• Sanctions-list changes affecting an existing merchant

We may ask you to explain a transaction. Answering promptly and accurately is a condition of your account.

6. Reporting, and what we cannot tell you

Where we have grounds to suspect that funds derive from crime or relate to terrorist financing, we are legally required to report to ANIF.

We are prohibited by law from telling you that a report has been made, or from disclosing its content. This is the "tipping off" prohibition. It means that if your account is restricted for this reason, we may be unable to explain why, and our support team will not be able to help — this is a legal constraint, not evasiveness.

We may also be required to freeze funds, or to decline to execute a transaction, pending instruction from the authorities.

7. Sanctions

We do not do business with, and will freeze funds relating to, any person or entity subject to applicable sanctions. Where a match is confirmed we will block the transaction, freeze the balance, and report as required.

8. Record keeping

We retain identification documents, verification records, transaction records and the supporting audit trail for `[RETENTION PERIOD]` after the relationship ends. AML rules typically require a minimum of ten years.

These records cannot be deleted at your request. A data-deletion request does not override this obligation — see the Privacy Policy §7.

9. What we expect from merchants

• Give accurate, complete information, and update it when it changes — particularly ownership and bank details
• Respond to information requests within the time we specify
• Process only your own business's payments, for the activity you declared
• Comply with the Acceptable Use Policy
• Tell us promptly if you become aware of fraudulent or suspicious activity on your account

Failure to cooperate is grounds for suspension of processing, withholding of settlement, and termination.

10. Consequences

Where an AML/CFT concern arises we may, without prior notice:

• Request further information or documentation
• Decline or delay a transaction
• Suspend processing or withhold settlement
• Freeze a balance
• Terminate the relationship
• Report to ANIF, law enforcement, regulators, or the payment providers

Contact

Compliance: [COMPLIANCE EMAIL] Compliance Officer: [COMPLIANCE OFFICER NAME / ROLE]

[COMPANY LEGAL NAME] · [REGISTERED ADDRESS] · RCCM [RCCM NUMBER]