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Anti money laundering and counter financing of terrorism and proliferation policy

[Company legal name] ("Zero Entry", "we", "us") Effective date: [effective date] Version: 1.0 (draft for legal review)

1. Purpose and commitment

Zero Entry is committed to preventing its platform and its business from being used to launder money or to finance terrorism or the proliferation of weapons. This policy sets out the controls we apply to meet our obligations under the Financial Intelligence Act, 2019 of Botswana, its regulations, and the guidance of the Financial Intelligence Agency, to the extent they apply to our activities.

2. Scope

This policy applies to all directors, employees and contractors of Zero Entry. It governs how we identify our customers, monitor for suspicious activity, keep records and report where required.

3. Our position in the chain

Zero Entry provides accounting software. We are not a bank, a money transfer service or an accountable institution that holds client funds. We do not move customer money. Even so, we apply proportionate controls because our platform processes financial records, and we support our users, some of whom are accountable institutions, in meeting their own obligations.

4. Risk based approach

We assess and manage money laundering and financing risk in proportion to the nature of each relationship. Factors we consider include the type of customer, the sector they operate in, the products they use, and any unusual patterns of use. We apply enhanced measures where the risk is higher.

5. Customer due diligence

Before and during a business relationship we take reasonable steps to:

  • identify the customer and, where the customer is a company, its beneficial owners and controllers;
  • verify that identity using reliable, independent information;
  • understand the purpose and intended nature of the relationship; and
  • keep the information current for the life of the relationship.

We may decline to open, or may suspend or close, an account where we cannot complete satisfactory due diligence.

6. Sanctions and screening

We do not knowingly provide services to individuals or entities subject to applicable sanctions or listed under measures against terrorism or proliferation financing. We screen against relevant lists where required and take action on any match.

7. Ongoing monitoring

We monitor the use of our platform for activity that is inconsistent with what we know of a customer, or that has no apparent lawful purpose. Unusual activity is escalated internally for review.

8. Suspicious transaction reporting

Where an employee has knowledge or a reasonable suspicion of money laundering, terrorist financing or proliferation financing, they must report it internally to the Compliance Officer without delay and must not alert the customer. The Compliance Officer assesses each internal report and, where the legal threshold is met, files a suspicious transaction report with the Financial Intelligence Agency within the time the law requires. Tipping off a customer that a report has been or may be made is prohibited.

9. Record keeping

We keep records of customer identification, due diligence and any internal or external reports for the period required by law, which is at least five years from the end of the relationship or the date of the transaction, and we make them available to competent authorities on lawful request.

10. Compliance Officer

The board appoints a Compliance Officer responsible for this policy, for receiving internal reports, for liaising with the Financial Intelligence Agency, and for training. The current Compliance Officer is [name], [email], [phone].

11. Training

All relevant staff receive training on recognising and reporting suspicious activity, on their obligations under this policy, and on the prohibition against tipping off, on joining and at regular intervals thereafter.

12. Consequences

Failure to follow this policy may result in disciplinary action and, where the law is broken, personal criminal liability. Nothing in this policy prevents an employee from meeting a legal obligation to report.

13. Review

This policy is reviewed at least annually and when the law or our risk profile changes.

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