Anti-Money Laundering and Countering the Financing of Terrorism
Last Updated: 30th January 2025
I. Introduction
YOUNGESTGEXCHANGE Ltd. (YOUNGESTGEXCHANGE or YGE), hereafter referred to as “the Company,” is a cross-border payment service provider operating within and beyond the borders of Cameroon. This Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) policy is designed to comply with both national regulations and international standards. Our goal is to prevent the misuse of our services for illicit purposes and to foster a culture of compliance within our organization.
II. Regulatory Framework
This policy is grounded in existing laws and regulations including:
- The Cameroonian Law No. 2016/012 of July 2016 on Anti-Money Laundering and Combating the Financing of Terrorism.
- The Central Bank of Central African States (BEAC) regulations on AML/CFT.
- The Financial Action Task Force (FATF) Recommendations.
- The United Nations Security Council Resolutions.
YOUNGESTGEXCHANGE Ltd. is subject to regulatory oversight by the National Financial
Intelligence Unit (ANIF), ensuring compliance with all applicable AML/CFT regulations.
III. Objectives of the Policy
- To prevent and detect money laundering and terrorist financing activities.
- To establish a risk-based approach to AML/CFT measures.
- To facilitate cooperation and information-sharing with competent authorities.
- To promote awareness and training within the organization on AML/CFT issues.
IV. Governance Structure
The implementation of the AML/CFT policy is overseen by:
- Board of Directors: Responsible for the overall direction, approval, and oversight of the AML/CFT policy.
- Compliance Officer: Appointed to ensure compliance with AML/CFT regulations and acts as the main point of contact with regulatory authorities.
- AML/CFT Committee: Comprised of senior management responsible for the execution and review of AML/CFT policies and procedures.
V. Risk Assessment
- Risk-Based Approach: The Company aligns its risk-based approach (RBA) with its risk appetite, using clearly defined risk categories. Periodic reviews will ensure the framework remains effective and in line with regulatory expectations.
- Customer Risk Rating: Customers will be classified into risk categories (high, medium, low) based on factors including their profile, transaction history, and geographical location. This classification informs the level of due diligence applied to each relationship.
VI. Customer Due Diligence (CDD)
- Know Your Customer (KYC):
- Internal KYC procedures require customers to submit valid government-issued ID and proof of address.
- Internal KYC procedures require customers to submit valid government-issued ID and proof of address.
- Enhanced Due Diligence (EDD) is applied to high-risk clients or when concerns arise.
- Source of Wealth and Funds Verification:
- Customers must provide documentation to verify their financial status and the source of their funds.
- For high-risk clients, additional documentation such as salary slips, bank statements, tax returns, or business ownership records is requested.
- Background checks are conducted to verify the legitimacy of the provided information
- Ongoing Monitoring: Continuous monitoring of customer transactions will be employed to identify any unusual or suspicious activities. This includes the use of transaction limits and triggers for alerts.
VII. PEPs and Enhanced Due Diligence Checks
- Definition of Politically Exposed Persons (PEPs):
- PEPs refer to natural persons who are, or have been, entrusted with prominent public functions either within or outside Cameroon, as well as their immediate family members and close associates.
- Risk Considerations:
- PEPs pose a higher risk of money laundering and corruption due to their access to resources and influence. This elevated risk extends to their immediate family members and known close associates.
- Individuals are not considered PEPs if they have left office for over one year.
- Enhanced Due Diligence (EDD) for PEPs:
The Company will apply enhanced due diligence measures for PEPs, including:- Detailed background checks and active tracking of PEPs using global databases and conducts enhanced due diligence on such individuals.
- Continuous transaction monitoring for unusual or suspicious activity.
- Obtaining senior management approval for establishing or continuing a relationship with a PEP.
VIII. Reporting Obligations
- Suspicious Activity Reports (SARs):
- All transactions are monitored for suspicious behaviour, with clear red flags defined (e.g., large cash deposits, rapid movement of funds).
- SARs are filed with the National Financial Intelligence Unit (ANIF) in accordance with company guidelines.
- The Compliance Officer ensures that SARs are investigated, documented, and reported promptly to relevant authorities.
- Internal Reporting:
- Employees are encouraged to report any suspicious activities directly to the Compliance Officer.
- A SAR/STR filing log is maintained for regulatory audits, and internal meetings are held regularly to discuss trends and best practices in reporting.
IX. External Audits and Regulatory Reviews
- Independent Audits:
- YOUNGESTGEXCHANGE Ltd. Is to undergo regular external audits to assess its compliance with AML/CFT regulations. These audits are conducted by independent bodies and include both random and scheduled audits.
- Findings from audits are to be reviewed by Senior Management, and corrective actions are implemented as necessary.
- Audit recommendations are to be tracked to ensure they are addressed promptly.
- Regulatory Reviews:
- Periodic reviews are conducted to ensure compliance with all regulatory requirements. This includes sanctions screening against local and international lists and the periodic review of client relationships to identify high-risk individuals.
X. Training and Awareness
- Employee Training:
- All employees are required to undergo AML/CFT training upon hiring and annually thereafter.
- Training includes scenario-based exercises, case studies, and real-world examples to reinforce understanding of AML/CFT laws and the importance of compliance.
- Training logs are maintained for auditing purposes, ensuring that employees are regularly updated on AML/CFT requirements.
XI. Record Keeping
The Company will maintain comprehensive records of:
- CDD records.
- Transaction logs.
- Reports made to regulatory authorities.
- Training logs for audit purposes.
All records will be retained for a minimum of five years after the completion of the transaction or following the termination of the business relationship.
XII. Audit and Review
- Internal Audit: Regular audits will take place to assess the effectiveness of the AML/CFT program and compliance with this policy.
- Policy Review: This policy will be reviewed annually, and updates will be made as necessary to respond to changes in regulations, market conditions, and best practices.
XIII. Conclusion
YOUNGESTGEXCHANGE Ltd. is firmly committed to conducting business in a manner that upholds the integrity of the financial system. The Company will take all necessary steps to prevent money laundering and the financing of terrorism by effectively implementing this AML/CFT policy.
Approval and Implementation: This policy is approved by the Board of Directors and shall be implemented by all employees of YOUNGESTGEXCHANGE Ltd.
Date of Approval: January 30, 2025.