ANTI-MONEY LAUNDERING POLICY
Document History
Version Year Description Approval DATE
1.0 2024 Anti- Money
Laundering Policy
1. Introduction
Atlantic Micro Credit, (herein referred to as “the company”) is committed to the compliance of
recognized global standards on combating money laundering and terrorism financing.
Purpose: This Anti-Money Laundering (AML) Policy is designed to ensure the
company’s compliance with applicable AML regulations and to prevent the company
from being used to facilitate money laundering or terrorist financing.
Scope: This policy applies to all employees, directors, contractors, and any individuals
working on behalf of the company.
Legal and Regulatory Framework: The policy aligns with both local and international
AML regulations, such as the Financial Action Task Force (FATF) recommendations,
Anti-Money Laundering Act,2006 (Tanzania) and subsequent amendments and
Prevention of Terrorism (General) Regulations, 2014 and subsequent amendment.
2. Definitions
Customers:
For the purpose of this policy, a customer is defined as;
a) A person or an entity that has a business relationship with the company.
b) Any person or entity connected with a financial transaction which can pose significant
reputation
Money Laundering:
Money Laundering means the act of a person who;
a) Engages, directly or indirectly in a transaction that involves proceeds of any unlawful
activity.
b) acquires, possesses, uses or administers property, while he knows or ought to know or
ought to have known at the time of receipt that such property is the proceeds of a
predicate offence.
c) conceals, disguises or impedes the establishment of the true nature, source, location,
disposition, movement or ownership of or rights with respect to property, while he knows
or ought to know or ought to have known that such property is the proceeds of a predicate
offence
Terrorist Financing:
conducting a financial transaction or facilitating a financial transaction directly or
indirectly, in order to deal with property that is owned or controlled by a terrorist,
terrorist group or terrorist entity.
Beneficial Owner:
Any natural person who ultimately owns or controls the customer, the natural person on
whose behalf a transaction or activity is being conducted
Suspicious Activity Reporting (SAR): A report submitted to authorities when
suspicious or potentially illegal financial activity is identified.
3. Roles and Responsibilities
Board of Directors: Ultimate responsibility for ensuring the company adheres to AML
policies and procedures.
AML Compliance Officer: Designated to oversee the implementation of the AML
policy, report suspicious activities, and ensure the company complies with relevant laws.
Employees: All employees are required to understand and comply with the AML policy
and report any suspicious activities to the AML Compliance Officer.
4. Know Your Customer (KYC) Procedures
Customer Identification: All new clients must be identified using valid government-
issued identification (e.g., passport, ID card). KYC documentation should include the
customer's full name, address, date of birth, and the source of funds.
Risk Assessment: Clients should be categorized based on their risk profile (e.g., low,
medium, or high) depending on factors such as geographic location, transaction volume,
and nature of the business.
Enhanced Due Diligence (EDD): For high-risk customers, additional measures must be
taken, such as obtaining more detailed information or closer monitoring of transactions.
5. Monitoring and Reporting Suspicious Activity
Transaction Monitoring: Regular monitoring of customer transactions to identify
unusual patterns or activities inconsistent with their profile.
Suspicious Activity Reporting (SAR): Employees must immediately report any unusual
or suspicious transactions to the AML Compliance Officer. The Compliance Officer will
assess the situation and file an SAR with Financial Intelligence Unit (FIU).
Confidentiality: Employees must not disclose to the customer that a SAR has been filed
(i.e., no "tipping off").
6. Record-Keeping
Retention Period: All customer records, including KYC documents and transaction
records, must be retained for a minimum of ten years, as per regulatory requirements.
Documentation: Records should include customer identification details, account activity,
correspondence, and SAR filings.
7. Employee Training
AML Training Programs: All employees must undergo regular training on AML
regulations, detecting suspicious activities, and the company's reporting protocols.
Training Frequency: Training sessions will be conducted annually and as needed, based
on changes to AML laws or internal procedures.
Effectiveness Review: The AML Compliance Officer will periodically evaluate the
effectiveness of the training programs and make improvements as necessary.
8. Internal Controls and Audits
Internal Audits: Regular internal audits will be conducted to ensure the company’s
AML controls are effective and being followed.
Independent Review: An independent external review may also be conducted to verify
the company’s compliance with AML regulations.
Risk-Based Approach: The company will apply a risk-based approach in monitoring
and reviewing accounts, transactions, and AML procedures.
9. Sanctions and Penalties
Non-Compliance Consequences: Any employee who fails to comply with the AML
policy will face disciplinary action, including possible termination.
Legal Penalties: The company and its employees could face legal penalties, including
fines and imprisonment, for failing to adhere to AML regulations.
10. Policy Review and Updates
Annual Review: This policy will be reviewed annually by the AML Compliance Officer
to ensure it remains up-to-date with current laws and regulations and shall be up for
review to the Board of Directors once every two years whichever comes earlier.
Policy Amendments: Any changes or amendments to the policy will be communicated
to all employees and reflected in subsequent training sessions.
Signatures
Director:
Name: _________________________
Signature: ______________________
Date: __________________________
Director:
Name: _________________________
Signature: ______________________
Date: __________________________
