AML Policy

AML/CFT Policy

Muhas Money Link maintains a risk-based Anti-Money Laundering, Counter-Financing of Terrorism, and Counter-Proliferation Financing program including customer due diligence, transaction monitoring, sanctions screening, record keeping, staff training, and suspicious transaction reporting.

5. KYC Policy

1. Purpose

Muhas Money Link ("the Company") is committed to maintaining effective Know Your Customer (KYC) procedures to protect its business from being used for money laundering, terrorist financing, fraud, sanctions evasion, identity theft, or other financial crimes.

This KYC Policy establishes the standards and procedures for identifying and verifying customers before providing money transfer services. The policy supports compliance with applicable laws and regulations, including Anti-Money Laundering (AML), Counter Financing of Terrorism (CFT), sanctions requirements, and other regulatory obligations.

2. Objectives

The objectives of this KYC Policy are to:

• Verify the identity of customers before establishing a business relationship or processing transactions.
• Understand the nature and purpose of customer transactions.
• Assess and manage customer risk.
• Prevent the use of Muhas Money Link services for illegal activities.
• Comply with applicable legal and regulatory requirements.
• Protect the reputation and integrity of Muhas Money Link.

3. Scope

This policy applies to:

• All Muhas Money Link employees.
• Branch offices.
• Agents and authorized representatives.
• Compliance personnel.
• Senior Management.
• All customers using Muhas Money Link services.

4. KYC Principles

Muhas Money Link follows the following KYC principles:

Customer Identification

Every customer must be properly identified before a transaction is processed.

Customer Verification

Customer identity information must be verified using reliable and independent documentation.

Risk-Based Approach

Customers are assessed according to their level of money laundering and terrorist financing risk.

Ongoing Monitoring

Customer transactions are monitored to ensure they remain consistent with the customer's known profile and expected activity.

Record Keeping

Customer records are maintained securely and retained in accordance with legal and regulatory requirements.

5. Customer Identification Requirements

Before providing services, Muhas Money Link may collect the following information:

Individual Customers

• Full legal name
• Date of birth
• Nationality
• Residential address
• Occupation
• Employer (where applicable)
• Telephone number
• Email address (where available)
• Identification number
• Type of identification document

Corporate Customers

Where services are provided to businesses, the Company may collect:

• Registered business name
• Certificate of incorporation
• Business registration number
• Registered office address
• Nature of business
• Tax Identification Number (where applicable)
• Information on directors
• Beneficial ownership information
• Authorized signatories

6. Acceptable Identification Documents

Acceptable identification documents may include:

• National Identity Card
• Passport
• Driver's Licence
• Residence Permit
• Voter Identification Card (where permitted)
• Other government-issued identification accepted by Muhas Money Link

The identification document must be valid, original, and unexpired.

7. Address Verification

Where required, customers may be asked to provide proof of address, such as:

• Utility bill
• Bank statement
• Government-issued correspondence
• Tenancy agreement
• Official residence certificate

Alternative documentation may be accepted where appropriate and permitted by law.

8. Customer Risk Assessment

Muhas Money Link applies a risk-based approach to customer onboarding.

Customers may be classified as:

Low Risk

Examples include:

• Salaried employees
• Students
• Pensioners
• Individuals conducting low-value transactions

Medium Risk

Examples include:

• Small business owners
• Self-employed individuals
• Customers conducting regular international transfers

High Risk

Examples include:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Customers conducting unusually large or complex transactions
• Businesses operating in high-risk sectors

The level of due diligence applied depends on the customer's risk rating.

9. Enhanced Due Diligence (EDD)

Enhanced Due Diligence shall be applied where higher risks are identified.

EDD measures may include:

• Obtaining additional identification documents.
• Verifying the source of funds.
• Verifying the source of wealth where appropriate.
• Obtaining additional information about the purpose of the transaction.
• Increased transaction monitoring.
• Senior management approval before establishing or continuing the relationship.

10. Politically Exposed Persons (PEPs)

Muhas Money Link shall identify customers who are Politically Exposed Persons (PEPs), their immediate family members, or close associates where required.

Transactions involving PEPs may require:

• Enhanced Due Diligence.
• Senior management approval.
• Ongoing monitoring.
• Periodic review of the customer relationship.

Being identified as a PEP does not automatically prevent a customer from using our services, but it requires additional risk management measures.

11. Sanctions Screening

Muhas Money Link screens customers and transactions against applicable sanctions lists before processing transactions.

If a potential sanctions match is identified:

• The transaction may be delayed or suspended.
• Additional verification may be conducted.
• The Compliance Department will review the match.
• Appropriate legal or regulatory action may be taken where required.

12. Ongoing Customer Monitoring

Muhas Money Link continuously monitors customer activity to identify unusual or suspicious transactions.

Monitoring may include:

• Transaction frequency.
• Transaction values.
• Geographic destinations.
• Changes in customer behaviour.
• Transactions inconsistent with the customer's known profile.

Where unusual activity is detected, additional enquiries may be conducted.

13. Suspicious Activity

Employees must remain alert to indicators of suspicious activity, including:

• Unusual transaction patterns.
• Structuring transactions to avoid reporting thresholds.
• Inconsistent customer information.
• Attempts to avoid identification procedures.
• Transactions lacking an apparent economic purpose.

Any concerns must be reported immediately to the Money Laundering Reporting Officer (MLRO) in accordance with Muhas Money Link's AML/CFT Policy.

14. Record Retention

Muhas Money Link retains KYC records, identification documents, and related customer information for the period required under applicable laws and regulatory requirements.

Records are maintained securely and are accessible only to authorized personnel.

15. Employee Responsibilities

Employees are responsible for:

• Following KYC procedures.
• Verifying customer identities.
• Reporting suspicious activity.
• Protecting customer confidentiality.
• Completing mandatory compliance training.
• Escalating concerns to the Compliance Department.

Failure to comply with this policy may result in disciplinary action.

16. Training and Awareness

Muhas Money Link provides regular KYC and AML/CFT training to employees to ensure they understand:

• Regulatory obligations.
• Customer identification procedures.
• Fraud indicators.
• Sanctions compliance.
• Suspicious transaction reporting requirements.
• Updates to laws and internal policies.

Training records are maintained by the Compliance Department.

17. Confidentiality

Customer information collected for KYC purposes is confidential and will only be used for legitimate business purposes or disclosed where required by law or with the customer's consent.

Employees must maintain strict confidentiality regarding all customer information.

18. Policy Review

This KYC Policy shall be reviewed at least annually, or earlier if required due to changes in:

• Laws and regulations.
• Business operations.
• Products and services.
• Risk assessments.
• Regulatory guidance.

Any amendments must be approved by Senior Management and, where applicable, the Board of Directors.

19. Contact Information

Questions regarding this KYC Policy should be directed to the Compliance Department or the Money Laundering Reporting Officer (MLRO).

Muhas Money Link is committed to maintaining the highest standards of customer identification, regulatory compliance, and financial integrity to protect our customers, employees, and the financial system.

 

6. Sanctions Compliance

1. Purpose

Muhas Money Link ("the Company") is committed to complying with all applicable international sanctions laws, regulations, and regulatory directives to prevent its services from being used for illegal activities, including money laundering, terrorist financing, proliferation financing, and the circumvention of financial sanctions.

This Sanctions Compliance Policy establishes the framework for identifying, assessing, managing, and mitigating sanctions-related risks in all aspects of Muhas Money Link's operations.

The objectives of this policy are to:

• Ensure compliance with applicable sanctions requirements.
• Prevent transactions involving sanctioned persons, entities, vessels, aircraft, or jurisdictions where prohibited.
• Protect Muhas Money Link from legal, financial, operational, and reputational risks.
• Support the Company's Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) framework.

2. Scope

This policy applies to:

• All Muhas Money Link employees.
• Directors and Senior Management.
• The Money Laundering Reporting Officer (MLRO).
• Compliance Department personnel.
• Branches and representative offices.
• Agents and authorized representatives.
• Third-party service providers, where applicable.
• All customers using Muhas Money Link services.

Every employee is responsible for complying with this policy.

3. Regulatory Framework

Muhas Money Link shall comply with all sanctions obligations applicable to its operations, including those arising from:

• Applicable laws of The Republic of The Gambia.
• Directions and requirements issued by the Central Bank of The Gambia.
• Financial Intelligence Unit (FIU) directives, where applicable.
• United Nations Security Council (UNSC) sanctions.
• Any other sanctions regimes that the Company is legally required or contractually obligated to observe.

Where different sanctions regimes apply, Muhas Money Link will adopt the highest applicable standard required for its business operations.

4. Definitions

Sanctions

Restrictions imposed by governments or international organizations that prohibit or restrict dealings with specified persons, entities, countries, organizations, vessels, aircraft, or activities.

Designated Person

A person or entity that has been officially listed under an applicable sanctions regime.

Asset Freeze

A legal requirement to prevent the transfer, movement, alteration, or use of funds or economic resources belonging to a designated person or entity.

Sanctions Screening

The process of comparing customer and transaction information against applicable sanctions lists.

5. Governance and Responsibilities

Board of Directors

The Board is responsible for:

• Approving the Sanctions Compliance Policy.
• Promoting a strong compliance culture.
• Ensuring adequate resources are available for sanctions compliance.
• Overseeing sanctions risk management.

Senior Management

Senior Management shall:

• Implement this policy.
• Ensure appropriate controls are maintained.
• Support the Compliance Department.
• Address sanctions compliance risks promptly.

Money Laundering Reporting Officer (MLRO)

The MLRO shall:

• Oversee sanctions compliance activities.
• Review sanctions alerts.
• Escalate confirmed matches where required.
• Liaise with regulatory authorities.
• Maintain sanctions-related records.
• Recommend improvements to sanctions controls.

Employees

All employees must:

• Complete sanctions compliance training.
• Follow sanctions screening procedures.
• Report potential sanctions concerns immediately.
• Cooperate with investigations.
• Protect confidential information.

6. Sanctions Risk Assessment

Muhas Money Link applies a risk-based approach to sanctions compliance.

Risk assessments consider:

• Customer profile.
• Country of residence.
• Nationality.
• Destination country.
• Transaction value.
• Frequency of transactions.
• Delivery channel.
• Products and services used.
• Nature of business.
• Ownership structure.

Higher-risk customers may be subject to enhanced due diligence.

7. Customer Screening

Muhas Money Link screens customers:

• Before onboarding.
• Before processing transactions, where applicable.
• During ongoing customer relationships.
• Whenever customer information changes.
• During periodic reviews.

Screening includes:

• Customer names.
• Beneficiaries.
• Senders.
• Corporate entities.
• Directors.
• Beneficial owners.
• Authorized representatives.

8. Transaction Screening

Every transaction may be screened for sanctions risks before processing.

The Company may review:

• Sender.
• Recipient.
• Intermediary institutions.
• Destination country.
• Payment purpose.
• Transaction references.
• Payment routes.

Transactions identified as presenting sanctions risks may be delayed, suspended, rejected, or escalated for further review.

9. Handling Potential Matches

Where a potential sanctions match is identified, Muhas Money Link shall:

1. Suspend processing where appropriate.
2. Conduct additional verification.
3. Review supporting documentation.
4. Determine whether the alert is a false positive or a confirmed match.
5. Escalate confirmed matches to the MLRO.
6. Take any actions required by applicable law or regulatory direction.

Employees must not inform customers that a sanctions review or regulatory report is being undertaken where doing so is prohibited by law.

10. Prohibited Activities

Muhas Money Link will not knowingly:

• Process transactions involving sanctioned persons or entities where prohibited.
• Facilitate transactions intended to evade sanctions.
• Assist in concealing beneficial ownership.
• Process transactions involving prohibited jurisdictions where applicable.
• Participate in activities designed to circumvent sanctions requirements.

11. Record Keeping

The Company shall maintain records relating to sanctions compliance, including:

• Screening results.
• Investigation records.
• Supporting documentation.
• Compliance decisions.
• Regulatory communications.
• Employee training records.

Records shall be retained for the period required by applicable laws and regulatory requirements.

12. Employee Training

Muhas Money Link provides regular sanctions compliance training to employees covering:

• Applicable sanctions obligations.
• Screening procedures.
• Escalation requirements.
• Identification of sanctions risks.
• Reporting responsibilities.
• Updates to relevant laws and internal procedures.

Attendance and completion of training shall be documented.

13. Monitoring and Internal Controls

The Compliance Department shall regularly monitor the effectiveness of sanctions controls by:

• Reviewing screening processes.
• Testing compliance procedures.
• Monitoring sanctions alerts.
• Assessing operational risks.
• Recommending corrective actions where weaknesses are identified.

Independent reviews or internal audits may be conducted periodically.

14. Confidentiality

Information obtained during sanctions screening and investigations shall be treated as confidential and accessed only by authorized personnel.

Disclosure shall be made only where required by law, regulation, or competent authority.

15. Non-Compliance

Failure by employees, agents, or representatives to comply with this policy may result in:

• Disciplinary action.
• Suspension of duties.
• Termination of employment or contractual relationship.
• Reporting to regulatory or law enforcement authorities where required.

Muhas Money Link maintains a zero-tolerance approach to deliberate breaches of sanctions requirements.

16. Policy Review

This policy shall be reviewed at least annually, or earlier where necessary due to:

• Changes in applicable laws or regulations.
• Updates to sanctions regimes.
• Changes to Muhas Money Link's products or services.
• Internal audit findings.
• Regulatory recommendations.

Any amendments shall be approved by Senior Management and, where appropriate, the Board of Directors.

7. Fraud Prevention

1. Purpose

Muhas Money Link ("the Company") is committed to maintaining the highest standards of integrity, transparency, and security in all its operations. Fraud poses significant financial, operational, legal, and reputational risks to the Company, its customers, business partners, and the financial system.

This Fraud Prevention Policy establishes the principles, responsibilities, and procedures for preventing, detecting, reporting, investigating, and responding to actual or suspected fraudulent activities involving Muhas Money Link's products, services, employees, agents, customers, and third parties.

The objectives of this policy are to:

• Protect customers, employees, and the Company from fraud.
• Minimize financial losses arising from fraudulent activities.
• Promote a culture of honesty, accountability, and ethical conduct.
• Ensure compliance with applicable laws, regulations, and industry standards.
• Strengthen public confidence in Muhas Money Link's services.

2. Scope

This policy applies to:

• All Muhas Money Link employees.
• Directors and Senior Management.
• Temporary and contract staff.
• Agents and sub-agents.
• Consultants and service providers.
• Customers using Muhas Money Link services.
• Third parties engaged by the Company where relevant.

Every individual associated with Muhas Money Link has a responsibility to support fraud prevention efforts.

3. Definition of Fraud

Fraud refers to any intentional act, omission, deception, misrepresentation, concealment, or abuse of position carried out to obtain an unlawful or unfair financial or personal benefit or to cause loss to another party.

Examples include:

• Identity theft.
• Forged or altered identification documents.
• False customer information.
• Unauthorized money transfers.
• Account takeover.
• Employee theft or embezzlement.
• Internal collusion.
• Cyber fraud.
• Social engineering.
• Phishing and email scams.
• Mobile money fraud.
• Agent fraud.
• Payment fraud.
• Document falsification.
• Misappropriation of company assets.

4. Fraud Risk Management

Muhas Money Link adopts a proactive and risk-based approach to fraud management by:

• Identifying fraud risks.
• Assessing the likelihood and impact of fraud.
• Implementing preventive controls.
• Monitoring transactions.
• Reviewing emerging fraud trends.
• Continuously improving fraud controls.

Fraud risk assessments shall be conducted periodically and whenever significant operational changes occur.

5. Roles and Responsibilities

Board of Directors

The Board shall:

• Approve the Fraud Prevention Policy.
• Promote ethical governance.
• Oversee fraud risk management.
• Ensure sufficient resources are allocated to fraud prevention activities.

Senior Management

Senior Management shall:

• Implement fraud prevention strategies.
• Promote ethical business practices.
• Support investigations.
• Ensure corrective actions are implemented.
• Monitor fraud risk indicators.

Compliance Department

The Compliance Department shall:

• Monitor fraud-related risks.
• Review suspicious activities.
• Coordinate fraud investigations where appropriate.
• Recommend improvements to internal controls.
• Liaise with regulatory authorities where required.

Employees

Employees shall:

• Follow company procedures.
• Verify customer identities.
• Protect confidential information.
• Report suspected fraud immediately.
• Complete mandatory fraud awareness training.
• Cooperate with investigations.

Failure to comply with this policy may result in disciplinary action.

6. Customer Due Diligence

Fraud prevention begins with effective customer identification.

Muhas Money Link shall:

• Verify customer identity using reliable documentation.
• Conduct Know Your Customer (KYC) procedures.
• Apply Enhanced Due Diligence where necessary.
• Screen customers against sanctions lists where applicable.
• Maintain accurate customer records.
• Update customer information periodically.

7. Fraud Prevention Controls

To reduce fraud risk, Muhas Money Link maintains a range of preventive controls, including:

Operational Controls

• Segregation of duties.
• Dual authorization for sensitive activities.
• Access controls.
• Transaction approval limits.
• Employee background checks.
• Secure document handling.

Technology Controls

• User authentication.
• Strong password requirements.
• Multi-factor authentication where available.
• Secure network infrastructure.
• Firewalls.
• Anti-malware protection.
• Encryption of sensitive information.
• System activity logging.

Transaction Controls

• Transaction monitoring.
• Velocity checks.
• Exception reporting.
• Geographic risk analysis.
• Verification of beneficiary information.
• Limits on transaction values where appropriate.

8. Fraud Detection

Muhas Money Link actively monitors for indicators of fraud, including:

• Unusual transaction patterns.
• Multiple transactions designed to avoid reporting thresholds.
• Repeated failed login attempts.
• Frequent changes to customer information.
• Transactions inconsistent with customer profiles.
• Suspicious documentation.
• Unusual agent activity.
• High-risk destination countries.
• Duplicate transactions.

Employees should remain alert to unusual customer behaviour and escalate concerns promptly.

9. Reporting Suspected Fraud

Any employee, agent, or contractor who suspects fraud must report it immediately to:

• The Compliance Department.
• The Money Laundering Reporting Officer (MLRO), where appropriate.
• Senior Management, depending on the nature of the incident.

Reports should include:

• Date and time of the incident.
• Description of the suspected fraud.
• Persons involved, if known.
• Supporting documentation or evidence.
• Actions already taken.

Employees must not attempt to investigate suspected fraud independently unless authorized to do so.

10. Fraud Investigation

Where fraud is suspected, Muhas Money Link may:

• Secure relevant records.
• Review transaction history.
• Interview relevant individuals.
• Analyse supporting documentation.
• Preserve electronic evidence.
• Suspend affected accounts or transactions where necessary.
• Cooperate with law enforcement and regulatory authorities as required.

Investigations shall be conducted fairly, confidentially, and in accordance with applicable laws.

11. Customer Awareness

Muhas Money Link encourages customers to protect themselves from fraud by:

• Keeping passwords, PINs, and One-Time Passwords (OTPs) confidential.
• Never sharing verification codes with anyone.
• Verifying recipient details before sending money.
• Reporting suspicious emails, calls, or messages claiming to be from Muhas Money Link.
• Monitoring transaction confirmations and receipts.
• Contacting customer support immediately if unauthorized activity is suspected.

The Company will never request passwords, PINs, or OTPs through email, SMS, or telephone.

12. Fraud Awareness and Training

Muhas Money Link provides regular training to employees covering:

• Fraud risks affecting money transfer services.
• Customer identification procedures.
• Document verification.
• Cybersecurity awareness.
• Social engineering risks.
• Internal reporting procedures.
• Emerging fraud trends.
• Responsibilities under this policy.

Training shall be provided during employee induction and refreshed periodically.

13. Confidentiality

All reports of suspected fraud and related investigations shall be treated as confidential.

Information shall be disclosed only to authorized personnel or competent authorities where required by law.

Employees must avoid discussing investigations with unauthorized persons.

14. Consequences of Fraud

Individuals found to have committed fraud may be subject to:

• Disciplinary action.
• Termination of employment or contractual relationship.
• Recovery of financial losses where legally permitted.
• Civil proceedings.
• Criminal prosecution.
• Reporting to regulatory or law enforcement authorities.

Muhas Money Link maintains a zero-tolerance approach to fraud.

15. Policy Review

This policy shall be reviewed at least annually or earlier if required due to:

• Changes in fraud risks.
• Regulatory developments.
• New products or services.
• Internal audit findings.
• Significant fraud incidents.

Updates shall be approved by Senior Management and, where applicable, the Board of Directors.