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KYC/AML Policy

Last Updated: April 19, 2025

1. Introduction and Purpose

SARF Exchange Ltd. ("SARF Exchange", "we", "us", or "our") is committed to preventing money laundering, terrorist financing, and other financial crimes. This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy outlines our procedures for verifying customer identity, monitoring transactions, and reporting suspicious activities in compliance with applicable laws and regulations.

The purpose of this policy is to:

  • Establish a framework for customer identification and verification
  • Define procedures for ongoing monitoring of customer activities
  • Outline our approach to risk assessment and management
  • Ensure compliance with applicable AML/CFT laws and regulations
  • Protect our platform from being used for money laundering or terrorist financing

2. Regulatory Framework

SARF Exchange is committed to complying with all applicable laws and regulations related to anti-money laundering and counter-terrorist financing, including but not limited to:

  • Anti-Money Laundering Act, 2020 (Act 1044) of Ghana
  • Anti-Terrorism Act, 2008 (Act 762) of Ghana
  • Bank of Ghana Notices and Directives on AML/CFT
  • Financial Intelligence Centre (FIC) Guidelines
  • Financial Action Task Force (FATF) Recommendations

We continuously monitor changes in the regulatory landscape and update our policies and procedures accordingly.

3. Risk-Based Approach

SARF Exchange adopts a risk-based approach to KYC and AML compliance. This approach allows us to allocate resources efficiently by focusing enhanced due diligence on customers and transactions that present higher risks of money laundering or terrorist financing.

Our risk assessment considers various factors, including:

  • Customer risk (e.g., occupation, source of funds, PEP status)
  • Geographic risk (e.g., high-risk countries, sanctions)
  • Product/service risk (e.g., transaction volumes, anonymity)
  • Channel risk (e.g., non-face-to-face onboarding)

Based on these factors, customers are categorized as low, medium, or high risk, with corresponding levels of due diligence applied.

4. Customer Identification and Verification

SARF Exchange implements a comprehensive Customer Due Diligence (CDD) program to verify the identity of all customers before allowing them to use our Services.

4.1 Basic Customer Due Diligence

For all customers, we collect and verify the following information:

  • Full legal name
  • Date of birth
  • Residential address
  • Contact information (email address, phone number)
  • Government-issued identification document (e.g., passport, national ID card, driver's license)
  • Proof of address (e.g., utility bill, bank statement)
  • Selfie or video verification

4.2 Enhanced Due Diligence

For customers categorized as high-risk, we conduct Enhanced Due Diligence (EDD), which may include:

  • Additional identification documents
  • Information on source of funds and wealth
  • Information on intended nature of the business relationship
  • Verification of employment or business activities
  • Senior management approval for establishing the business relationship
  • More frequent and detailed transaction monitoring

4.3 Politically Exposed Persons

We identify and apply EDD measures to Politically Exposed Persons (PEPs), their family members, and close associates. This includes:

  • Screening against PEP databases
  • Obtaining senior management approval
  • Establishing the source of wealth and funds
  • Conducting enhanced ongoing monitoring

4.4 Corporate Customers

For corporate customers, we collect and verify:

  • Company name and registration number
  • Registered address and principal place of business
  • Nature of business
  • Corporate structure and ownership
  • Identity of beneficial owners (individuals who own or control 25% or more)
  • Identity of directors and authorized signatories
  • Certificate of incorporation or equivalent document
  • Memorandum and articles of association

5. Ongoing Monitoring

SARF Exchange conducts ongoing monitoring of customer relationships and transactions to detect suspicious activities. Our monitoring program includes:

  • Regular review and update of customer information
  • Transaction monitoring using automated systems
  • Screening against sanctions lists and adverse media
  • Review of unusual transaction patterns
  • Periodic risk reassessment

The frequency and intensity of monitoring are determined by the customer's risk profile.

6. Suspicious Activity Reporting

SARF Exchange has established procedures for identifying and reporting suspicious activities to the appropriate authorities. Our employees are trained to recognize red flags that may indicate money laundering or terrorist financing activities.

When suspicious activity is detected, our compliance team conducts an investigation and, if warranted, files a Suspicious Transaction Report (STR) with the Financial Intelligence Centre (FIC) of Ghana.

Examples of suspicious activities include:

  • Transactions that appear to have no legitimate business purpose
  • Transactions that are inconsistent with the customer's profile
  • Multiple transactions just below reporting thresholds
  • Unusual patterns of transactions
  • Transactions involving high-risk jurisdictions
  • Attempts to circumvent identification or reporting requirements

7. Record Keeping

SARF Exchange maintains records of all customer identification information, transaction data, and compliance activities for a minimum of five years after the end of the business relationship or completion of the transaction.

These records include:

  • Customer identification documents
  • Transaction records
  • Risk assessments
  • Reports of suspicious activities
  • Training records
  • Compliance reviews and audits

All records are maintained in a secure manner and are readily available to authorized personnel and regulatory authorities when required.

8. Sanctions Compliance

SARF Exchange is committed to complying with all applicable sanctions programs. We screen customers and transactions against relevant sanctions lists, including:

  • United Nations Security Council Consolidated List
  • Ghana National Sanctions List
  • OFAC Specially Designated Nationals and Blocked Persons List
  • EU Consolidated Financial Sanctions List
  • UK HM Treasury Consolidated List

We do not establish or maintain relationships with individuals or entities on these lists, and we block transactions that violate applicable sanctions.

9. Employee Training

SARF Exchange provides regular training to all employees on KYC and AML requirements, procedures, and responsibilities. Training includes:

  • Overview of AML/CFT laws and regulations
  • Customer identification and verification procedures
  • Transaction monitoring and red flags
  • Reporting suspicious activities
  • Record-keeping requirements
  • Consequences of non-compliance

New employees receive training as part of their onboarding process, and all employees receive refresher training at least annually or when there are significant changes to regulations or procedures.

10. Compliance Officer and Program Oversight

SARF Exchange has appointed a dedicated Compliance Officer responsible for implementing and overseeing our KYC/AML program. The Compliance Officer reports directly to senior management and has the authority and resources to effectively discharge their responsibilities.

The Compliance Officer's responsibilities include:

  • Developing and implementing KYC/AML policies and procedures
  • Monitoring compliance with regulatory requirements
  • Reviewing and investigating suspicious activities
  • Filing regulatory reports
  • Conducting regular risk assessments
  • Providing guidance to employees on compliance matters
  • Coordinating training programs

Our KYC/AML program is subject to regular independent audits to assess its effectiveness and identify areas for improvement.

11. Policy Updates

This KYC/AML Policy is reviewed and updated regularly to reflect changes in regulatory requirements, industry best practices, and our business operations. Any significant changes to this policy will be communicated to all employees and, where appropriate, to customers.

12. Contact Information

If you have any questions about our KYC/AML Policy or procedures, please contact our Compliance Department at:

SARF Exchange Ltd.
Independence Avenue
Accra, Ghana
Email: compliance@sarfexchange.com
Phone: +233 (0) 302 123 456