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Anti-Money Laundering (AML) Policy

Glofintech Zambia Limited
Plot Number 24884, Rockfield, Chalala, Lusaka, Zambia


1. Introduction

This Anti-Money Laundering (AML) Policy outlines Glofintech Zambia Limited’s commitment to preventing money laundering and terrorist financing activities in compliance with the laws and regulations of Zambia. It serves as a guideline for our employees, partners, and stakeholders in identifying, preventing, and reporting suspicious activities.

2. Objectives

The objectives of this policy are to:

  • Ensure compliance with the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) laws and regulations of Zambia.
  • Prevent the use of Glofintech Zambia Limited’s services for money laundering or terrorist financing.
  • Establish a robust framework for identifying, monitoring, and reporting suspicious activities.

3. Scope

This policy applies to all employees, directors, officers, and agents of Glofintech Zambia Limited, including its branches and subsidiaries. It covers all aspects of the company’s operations and services, including customer onboarding, transaction monitoring, and reporting.

4. Legal Framework

Glofintech Zambia Limited is committed to complying with the following laws and regulations:

  • The Financial Intelligence Centre Act, No. 46 of 2010.
  • The Prohibition and Prevention of Money Laundering Act, No. 14 of 2001 (as amended).
  • The Banking and Financial Services Act, No. 7 of 2017.

5. Key Components

5.1. Customer Due Diligence (CDD)
  • Perform thorough identification and verification of customers and beneficial owners using reliable sources.
  • Classify customers based on their risk profile (Low, Medium, High).
  • Conduct Enhanced Due Diligence (EDD) for high-risk customers, including Politically Exposed Persons (PEPs).
5.2. Know Your Customer (KYC)
  • Maintain accurate and up-to-date customer information, including identity, business activities, and financial background.
  • Reassess and update customer information periodically and whenever there is a significant change in customer activity or behavior.
5.3. Transaction Monitoring
  • Monitor transactions on an ongoing basis for suspicious activities, such as unusual transaction sizes, patterns, or geographical locations.
  • Implement automated systems for detecting and reporting suspicious transactions.
5.4. Suspicious Activity Reporting (SAR)
  • Report any suspicious transactions or activities to the Financial Intelligence Centre (FIC) of Zambia without delay.
  • Maintain records of all SARs and the rationale for reporting or not reporting a suspicious transaction.
5.5. Record Keeping
  • Maintain comprehensive records of customer identification, transaction histories, and SARs for at least five years.
  • Ensure records are accessible and retrievable upon request by regulatory authorities.
5.6. Employee Training and Awareness
  • Provide regular AML training to all employees to ensure awareness and understanding of AML obligations and procedures.
  • Update training programs periodically to reflect changes in regulations and internal policies.
5.7. Internal Controls and Audit
  • Implement effective internal controls and procedures to manage and mitigate AML risks.
  • Conduct regular audits and reviews of AML procedures and controls to ensure compliance and effectiveness.

6. Roles and Responsibilities

  • Board of Directors: Ensure overall compliance with AML regulations and approve the AML Policy.
  • Compliance Officer: Oversee the implementation of the AML Policy, conduct risk assessments, and report suspicious activities to the FIC.
  • All Employees: Adhere to the AML Policy and report any suspicious activities to the Compliance Officer.

7. Penalties for Non-Compliance

Non-compliance with this policy and relevant AML regulations can lead to severe legal and financial penalties, including:

  • Fines and sanctions imposed by regulatory authorities .
  • Criminal prosecution and imprisonment.
  • Reputational damage to the company and its stakeholders.

8. Review and Amendments

This policy shall be reviewed annually or as required to ensure its effectiveness and alignment with legal requirements and best practices. Any amendments to the policy will be communicated to all relevant stakeholders.

9. Approval

This AML Policy has been approved by the Board of Directors of Glofintech Zambia Limited