KNOW YOUR CUSTOMER / CUSTOMER DUE DILIGENCE, ANTI-MONEY LAUNDERING, COUNTER FINANCING OF TERRORISM AND PROLIFERATION FINANCING POLICY AND PROCEDURES. 

INTRODUCTION AFRIONE.

AfriOne Bank Trading as a Subsidiary of PLATFORM CENTRE PTY LTD (hereinafter referred to collectively as “AfriOne”, “Company”, “Our”, AfriOne Bank/Wallet System", “Us” and “We”) AFRIONE BANK is an active company that serves as emerging market focused all in one marketplace, incorporated in the jurisdiction of South Africa and operated at No. 2 Baanbreker Avenue, Helderkruin, Roodepoort, Johannesburg, South Africa in accordance with the company act of south Africa with the registration number K2021920262 and We are registed with the Financial Intelligence Centre (FIC) - SHREG-230419-0000077. The company website address is www.afrionebank.africa .

The core activity of company is to trade (“buy”, “sell”, “spend”, “trade” & “Invest”) of crypto and has been serving customers through our various products and services i.e. digital wallet bank “Fiat”, Money Transfer/Remittance, Sales & Service, MasterCard, gift card, Debit card, API payment gateway, Crypto buy and sell of digital assets between P2P Parties and wallets address and remittance. AfriOne is a API facilitation company, making service reach the ordinary and every citizen where we find ourselves, except otherwise stated below and by operational jurisdiction.

The core activity of our company is unified next generation feature rich, secured, scalable, robust, and flexible crypto trading services platform enabling South Africans, Africans, Governments, business, individual and Aggregators to efficiently roll out and scale services through offering a wide range of use cases for the consumers through multiple transaction channels and creating a digital eco system by integrating the digital assets to various other digital service system. e.g. Operating custody accounts for third parties, offering payments services, executing payments transactions, operating an online crypto currency exchange platform, clearing and settling transactions between third parties, decentralized crypto trading platform and marketplace offering and various other services. Our Company is an all in one delivery extension to which will help to build delivery business and platforms for the entrepreneurs and the general public.

AUTHORITY & SCOPE OF THE AML/CTF POLICY

This Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Policy (the Policy) is issued under the authority of AFRIONE Directors (the “Board” or “BOD”). This Policy applies to all of the Company’s (“PLATFORM CENTRE” and It “SUBSIDIARIES”) employees, staff, officers and directors in accordance with the regulatory requirement of South African regulations and guidelines and subsequent amendments or additions, constitute and form part of the terms shall also be applicable on the conditions of their employment.

This Policy establishes the compliance framework by which all AFRIONE comply with all applicable laws and regulations in the south Africa entity have AML/CTF or suspicious activities obligations. This Policy is used by the Board as a guide to ensure that the stable business is conducted in a manner that is compliant with all applicable laws and regulations. The company has created and developed products and services with a compliance and security focus in mind in an effort to combat any attempted use of AFRIONE for illegal or illicit purposes. AFRIONE is committed to maintaining the highest possible compliance with all applicable laws and regulations relating to AML and the prevention of terrorism financing. All company’s personnel will be required to complete annual compliance training programs to support compliance focus. In all circumstances, company will maintain rigorous AML/CTF controls in accordance with applicable laws.

Adherence to this Policy is the responsibility of all employees directly or indirectly facing customers, executing or overseeing transactions, contractual documentation, systems and tools or other sources of information that may provide or reveal indications of possible money laundering or terrorism financing. All employees, including full-time, temporary or part-time employees, interns and contractors, if they have access to information or tools or are involved in the processes described in this document, are expected to be familiar with this policy as it relates to their responsibilities, and act in accordance with its provisions. The Board of Directors of company is ultimately responsible for approving this policy, ensuring compliance with this policy and creating the culture of compliance within the company.

Company has adopted a risk-based approach to mitigate the risk of being used for the purpose of money laundering or terrorism financing. This means assessing the ML/TF risks to which company is exposed to as a result of the nature and complexity of its business and the ML/TF risk to which is exposed to as a result of entering into a business relationship or carrying out a particular transaction. The rules, requirements and procedures set out in this Policy must be complied with at all times. The Company reserves the right to take disciplinary action (including dismissal) for non-compliant employees or contractors.

The AML/CTF function at company is an independent function executed and managed by the appointed Money Laundering Reporting Officers (MLRO) in each of its regulated entity worldwide, as applicable, who will regularly update local management and BOD on all material issues. The AML/CTF program encompasses but is not limited to the following activities: customer identification processes, defining the scope of eligible and non-eligible activities, sanctions screening, transactional monitoring, regular risk assessments, suspicious activities reporting, record keeping, training and other pertinent aspects, as required by applicable laws and regulations.

This Policy is reviewed on every addendum/SROs/Circular of the regulations issued by South African government under regulations, to ensure that it incorporates recently enacted rules and regulations, provides guidance in relation to said products, systems or tools introduced by the company, and addresses most recent learning and best practices in the areas of AML and CTF.

AML/CTF POLICY OBJECTIVES

This AML/CTF Policy protect AFRIONE being used by money launderers, terrorists, and those financing terrorist activities. Specifically, this Policy:

·         Define specific roles and responsibilities for company AML/CTF compliance personnel;

·         Create an AML/CTF risk assessment process;

·         Outline company AML/CTF internal control processes;

·         Create a Know Your Customer (referred as “KYC”) framework that provides for risk-based customer identification, verification and due diligence;

·         Create a transaction monitoring and suspicious activity reporting program;

·         Establish controls to ensure compliance with sanctions requirements and the regular screening against official public financial sanctions lists;

·         Establish a process to ensure adherence to all AML/CTF requirements, including filing of suspicious activities reports to the authority as per law, performing AML/CFT risk assessments, responding to information requests and maintaining records;

·         Ensure that company documents its efforts to meet its legal and regulatory obligations, including any applicable recordkeeping requirements;

·         Provide a training program for all personnel of the Company;

·         Require periodic independent testing; and

·         Require regular reporting to the Board about company AML/CTF efforts.

KEY TERMS AND DEFINITIONS

The key terms and definitions of this Policy are: “Money laundering” shall mean:

“knowingly facilitating by any means the false justification of the nature, the origin, the emplacement, the position, the movement or the propriety of the goods, which are constituting the object or the direct or indirect proceeds, or constituting a patrimonial benefit of any nature whatsoever from one or several of the designated predicate offences;”

“knowingly assisting in a placement, dissimulation or conversion transaction of digital assets constituting the object or the direct or indirect proceeds, or constituting a patrimonial benefit of any nature whatsoever from one or several of the predicate offences;” and ―having acquired, held or used the digital assets i.e. crypto constituting the object or the direct or indirect proceeds, or a patrimonial benefit of any nature whatsoever from one or several of the predicate offences, knowing, at the time they received them, that they originated from one of the designated offences or from the participation in one or several of these offences.”

The above references both define the money laundering offence by listing the facts constituting this offence and also specify the categories of predicate offences which may give rise to this offence. Money laundering presupposes the existence of a predicate offence whose object or proceeds may give rise to a money laundering offence.

The predicate offences are classified within this policy according to the list of designated categories of offences set forth in the glossary of the FATF Recommendations. The predicate offences include, but are not limited to:

·         Involvement with an organized criminal gang, racket, or terrorism, including the financing thereof;

·         Human trafficking and illicit trafficking of immigrants;

·         Illicit trafficking in narcotic drugs and psychotropic substances;

·         Arms trafficking;

·         Illicit trafficking in stolen goods and other goods;

·         Corruption;

·         Fraud and swindle;

·         Forgery of money;

·         Forgery and product piracy;

·         Kidnapping;

·         Illegal detention and taking of hostages;

·         Theft;

·         Smuggling;

·         Extortion;

·         Forgery;

·         Aggravated tax fraud and tax evasion;

·         Piracy.

Money laundering consists of any act relating to the proceeds of or the object of any predicate offense (i.e. any act from which any economic benefit is drawn from the predicate offence).

The legal definition of money laundering is very broad and encompasses a whole set of devices which all serve the purpose to provide a false justification of the origin of the property forming the object or proceeds of the predicate offences. The money laundering offense requires that the actor knowingly launders the proceeds.

The FATF has identified a three-step process that is commonly used to launder money:

·         Placement: The disposal of cash obtained from illegal activity by depositing it with or sending it through a financial institution. Illegal activities usually generate large amounts of cash that need to be placed into the financial system, the retail economy or transferred out of the country (e.g., the sale of illegal drugs, where payment is commonly made in cash).

·         Layering: Moving illegally obtained funds through various layers of financial transactions in order to disguise the illicit source of funds confuse any audit trail and provide anonymity for the criminal.

·         Integration: The placement of laundered funds back into the financial system in a manner that makes such funds appears to be “clean” and legally earned.

A Politically Exposed Person (PEP) shall mean: An individual who is or has been entrusted with a prominent public function such as a Head of State or Government, a senior politician, senior government/judicial/military officer, senior executive of a state-owned corporation, important political party officials or family member and/or close relative of a PEP.

Know Your Customer (“KYC”) is the process of identifying and verifying the identity of its customers and ascertain relevant information required for doing business with them. KYC involves:

a.       Seeking evidence of identity and address from the customer and independently confirming that evidence at the start of a relationship with the Company and periodically updating the information as per customer risk classification; and

b.       Seeking information regarding the sources of income and nature of business etc. of the customer.

Customer Due Diligence (“CDD”) information comprises the facts about a customer that should enable an organization to assess the extent to which the customer exposes it to a range of risks. These risks include money laundering, terrorist financing and having business relationship with sanctioned individuals/entities or designated terrorists under South Africa Anti-Terrorism law.

(i)     Money Laundering (“ML”) is the involvement of any transaction or series of transactions seeking to conceal or disguise the nature or source of proceeds derived from illegal activities, including narcotics trade, human trafficking, terrorism, ransom, extortion money, organized crime, fraud, and other crimes.

(ii)   Financing Terrorism (“TF”) refers to activities that provide financing or financial support to individual terrorists or non-state actors.

(iii) Customer means any natural person, legal person or legal arrangement to whom financial services have been extended by a regulated person.

(iv)  Beneficial Owner A natural person who is the owner of the Customer (a legal entity or a foreign undertaking) or controls the Customer and/or the natural person on whose behalf a transaction or activity is being conducted.

(v)    Legal Persons mean entities other than natural persons whether incorporated or not or a legal arrangement that can establish a permanent customer relationship with a regulated person or otherwise own property and include companies, bodies corporate, foundations, Limited Liability partnership (LLP), partnerships, or associations and other relevantly similar entities.

AML/CTF RISK ASSESSMENT AND ASSOCIATED CONTROLS AND MEASURES

AFRIONE will identify and assess the money laundering risks and the terrorism financing risks that may be associated with its unique business, services, and customers. More specifically, company will:

·         Carry out a business-wide ML/TF risk assessment on semiannually basis, assessing the risks to which company is exposed as a result of the nature and complexity of its business;

·         Assess the risks to which company is exposed as a result of entering a business relationship or carrying out transactions to buy remittances.

Each of the above risks assessments will consist of two separate, but related steps: The identification of the ML/TF risk factors, and the assessment of any such factors. The Company shall take reasonable steps to manage them and shall focus resources on the areas of its business that management believes pose the greatest risks.

Having identified its AML/CTF risks, the Company has following strengths:

·         Developed and implemented policies, procedures and controls, which are approved by the Board of Directors to enable it to manage and mitigate the risks;

·         Monitor the implementation of those policies, procedures and controls, and enhance them if necessary;

·         Perform enhanced/reinforced measures where higher risks are identified, to effectively manage and mitigate those higher risks; and

·         Ensure the performance of measures or enhanced measures to effectively manage and mitigate the identified risks to address the risk assessment and guidance from the relevant authorities.

Company will perform its semiannual risk assessment, where AML/CTF risks must be fully addressed. Based on the outcome of such risk assessment, an appropriate compliance plan must be developed and executed. The outcome of the AML/CTF risk assessment must be presented to and reviewed by the Board of Directors.

The risk assessment is based on total customer risk assessment scoring system. Score in the client’s overall risk profile is 100 points.

The above number of points in the customer risk assessment scoring system upon the assessment of the nature of company socioeconomic activity and the client ‘s MLTF risk is broken down by risk assessment as follows:

·         customer risk—33 Points

·         national and geographic risk— 2O points

·         risk related to services and products used by the client — 27points

·         service and product delivery channel risk—20 Points

For each risk segment considered within the assessment, the risk score can never be zero. Whilst the risk within a factor can be extremely low, there is always an inherent money laundering and terrorist financing risk which needs to be acknowledged by the South African Financial Intelligence Centre [FIC].

The monitoring employees ensure updates of the customer’s risk profile by applying the customer risk assessment scoring system each time when it is required to carry out due diligence of the customer. The customer risk assessment scoring system is utilized to apply risk mitigation measures pursuant to this AML and TF Policy or when FIC has obtained (through reports, customer service or due diligence, mass media Etc) Information concerning the customer, its beneficial owner, personal or economic activity as well.

The monitoring employee, based on the risk assessment and the risk Profile of the customer awarded score, determines the necessary due diligence measures and their regularity. The client’s due diligence measures and their regularity is determined based on the existing level of risk.

In order to perform regular update of the numerical score assigned to the risk factor, the customer compliance and monitoring department head selects at least 10 (ten) clients (focus group) and the relevance of the numerical score assigned to each risk factor, as well as the necessary changes in the numerical score assigned to each risk factor is based on the monitoring of the activity of the focus group.

Before the implementation of a new customer risk assessment scoring system or significant changes to the existing client risk assessment scoring system, the company shall inform the commission in a written form. The customer risk assessment scoring system shall include the following client identification information:

·         name of the customer

·         country of registration of the customer

·         registration number of the customer

·         representatives of the customer

·         beneficial owners of the customer

Company will put these following measures in place to ensure its business-wide and individual risk assessments remain up to date:

·         Set a date for every six months of each calendar year, on which the next business-wide risk assessment update will take place

·         Set a risk-sensitive date for individual risk assessments to ensure that new or emerging risks are included

·         Reflect the emergence of new, or an increase in existing ML/TF risks in business-wide and individual risk assessments as soon as possible, and

·         For each risk assessment period, record issues that could have a bearing on risk assessments, such as suspicious transaction or activity reports, compliance failures and intelligence from front office staff.

OBLIGATION TO ASSESS NEW PRODUCTS, PRACTICES AND TECHNOLOGIES PROCESS

The Company must identify and assess the money laundering and terrorism financing risks that may arise in relation to:

·         New products and new business practices, including new delivery mechanisms

·         Impact of new AML regulations on existing products and services

This must be done prior to the launch or use of such products and practices, where applicable, paying particular attention to products or practices that favor anonymity.

OBLIGATION TO CONDUCT CUSTOMER DUE DILIGENCE (“CDD”) & KNOW YOUR CUSTOMER (“KYC”)

Company must exercise due diligence when dealing with new and existing clients. It will, under applicable laws, assist and cooperate with regulators and relevant law enforcement authorities in detecting and preventing money laundering and terrorism financing.

AFRIONE will periodically, and at least after six months of year, review the adequacy of the existing CDD information and procedures, in accordance with the business-wide risk assessment and ensure these remain relevant and kept up-to-date.

Under CDD, company shall apply risk-sensitive measures to identify the customer and, where applicable, the customer’s beneficial owner, and verify that identity on the basis of reliable and independent sources in a satisfactory manner, including the identity of beneficial owners. Finally, company shall establish the purpose and the intended nature of the business relationship.

OBLIGATION TO IDENTIFY AND REPORT SUSPICIOUS ACTIVITIES, CONDUCT CLIENT DUE DILIGENCE (“CDD”) & KNOW YOUR CUSTOMER (“KYC”)

Company AML team will file Suspicious Activity Reports or Suspicious Transaction Reports (hereinafter “SARs” or “STRs”) with the relevant FIC (and other authorities, where applicable) when we know, suspect or have reasonable grounds to suspect that money laundering or terrorism financing is being committed or has been committed or attempted, in particular in consideration of the person concerned, its development, the origin of the funds, the purpose, nature and procedure of the operation.

CUSTOMER IDENTIFICATION:

(i)     No account shall be opened in the name of person who fails to disclose his/her true identity or fails to provide valid identity document. To authenticate identity of new customer:

a.       The photocopies of identity documents shall be validated through regulatory authority, identifying presence of any adverse remarks in the comments.

b.       In case of an individual with shaky/immature signatures, in addition to Passport, a passport size photograph of the new account holder will be obtained.

(ii)   Source of income shall be essentially disclosed by the customer.

a.       In case source of customer’s income is business / employment, name of the business / employer shall also be disclosed.

b.       In case of a salaried person copy of his service card or salary slip or certificate or letter on letter head of the employer will be obtained.

(iii) All prospective customers must be seen either face to face by the Company’s customer service representative or trader or on video call through communication tool like Skype, WhatsApp etc. and details verified over a recorded call on registered phone number.

(iv)  For any new account opening form, the Compliance Department shall match the particulars of the customer from the followings:

UNSC Sanctions list obtained daily from UNSC website under consolidated sanction list (https://www.un.org/sc/suborg/en/sanctions/un-sc-consolidated-list); If any matching name is found the account is being declined and reported to FIC simultaneously in the form of STR.

PROGRAM AND SYSTEMS TO PREVENT ML AND TF:

(i)     The Company will establish and maintain programs and systems to prevent, detect and report ML/TF. The systems will be appropriate to the size of the Company and the ML/TF risks to which it is exposed and will include:

a.       Adequate systems to identify and assess ML/TF risks relating to persons, countries and activities which should include checks against all applicable sanctions lists;

b.       Policies and procedures to undertake a Risk Based Approach (RBA);

c.       Internal policies, procedures and controls to combat ML/TF, including appropriate risk management arrangements;

d.       Customer Due Diligence measures;

e.       Record keeping procedures;

f.        Group-wide AML/CFT programs;

g.       An audit function to test the AML/CFT system;

h.       Screening procedures to ensure high standards when hiring employees; and

i.        An appropriate employee-training program.

(ii)   It will be the responsibility of the Senior Management to ensure that appropriate systems are in place to prevent, detect and report ML/TF and the Company is in compliance with the applicable legislative and regulatory obligations.