AML & KYC Policy | Seevcash

Introduction

SeevCash is a mobile financial platform designed to serve the unbanked and underserved communities by reducing transaction fees and providing digital tools to manage finances more effectively. Our mission is to make digital transactions and financial management more affordable and accessible for individuals in Ghana, particularly those facing economic hardships. We aim to empower communities by providing inclusive financial solutions that reduce the burden of transaction costs and foster economic resilience. As financial services proliferate and carry more financial value, it is becoming necessary for organizations to understand the customers they serve. At SeevCash, we value the trust and opportunity to serve you, and therefore take the task of offering security along with proper legal compliance seriously. In this regard, we perform KYC/AML procedures in adherence with the law. It is important to note that by using SeevCash and all services offered under the brand, you grant us and the third parties we work with, the sole discretion to accept or reject to offer you our services upon running a KYC/AML check. All data collected during this process shall be stored securely and shall not be disclosed to any third parties for monetary or other reasons unless required through legal process.

Objectives of the Policy

The objectives of this policy include:

To enable SeevCash to know / understand the customers and their financial dealings better, thereby helping all concerns to manage KYC-AML related risks prudentially,
To prevent SeevCash from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities,
To put in place a proper control mechanism for detecting and reporting of suspicious transactions in accordance with the statutory and regulatory provisions
To ensure that the laws of the Republic of Ghana are duly complied with
To ensure compliance with guidelines issued by regulators in our country.

Data Collected

All new users who desire to use the services offered by SeevCash shall be subjected to a mandatory KYC/AML process as part of the on-boarding process. SeevCash shall require the user to furnish the following details (which shall be subject to change):

First Name
Last Name
National Identification OR Passport Number
Date of Birth
Email Address
Address

The collected information shall be run against existing databases using internal and other third-party APIs to ensure that the users who are onboarded are not listed adversely in any AML cases or have not been blacklisted by other financial service providers such as banks. Such data as we collect shall be stored securely and shall not be monetized by SeevCash.

Our KYC/AML Lines of Defense

SeevCash applies three (3) Lines of Defense while implementing KYC-AML guidelines. These shall be helpful in strengthening the procedures at operational level and shall provide tools for ensuring enough robustness to the entire mechanism of KYC-AML Compliance.

1. First Line (Employees)

During their day-to-day activities, first-line employees may observe unusual or potentially suspicious activity and/or behavior exhibited by customers. First-line employees are required, according to policies and procedures, to be vigilant in their identification, escalation, and reporting of potentially suspicious and or unusual activities. Management should ensure that all personnel, especially employees who directly interact with customers, adhere to the internal processes for identification and referral of potentially suspicious activity.

2. Second Line (Management)

As part of the second line of defense, the chief AML/CFT officer has the responsibility for ongoing fulfillment of all AML/CFT duties. The chief AML/CFT officer has the responsibility for reporting suspicious transactions to the board and to local authorities. The chief AML/CFT officer shall be provided with sufficient resources to execute all responsibilities effectively and play a central and proactive role in SeevCash's AML/CFT regimen.

3. Third Line (Auditing)

The Internal audit function is responsible for independently assessing the effectiveness of the design and operation of internal controls. Additionally, there shall be periodic external auditing reviews to supplement the Internal Audit Function.

Components of our KYC/AML Program

Our KYC/AML process includes the following interrelated components:

Governance
Risk identification, assessment, and mitigation
Policies and procedures
Customer identification and due diligence
Transaction monitoring
Reporting
Communication and training
Continuous improvement and testing
Internal and external audit

These components are broken down further below:

i) Governance

A sound governance structure is the foundation of an effective KYC/AML process. Our governance structure includes the board of directors, the senior management, a chief AML/CFT officer, and a properly resourced system with three lines of defense.

ii) Risk identification, assessment, and mitigation

SeevCash shall over time review the risks inherent in the technology space we occupy, along with internal reviews for inherent risks within our system. We shall modify our internal controls based on the risks determined during assessments.

iii) Policies and procedures

Internal procedures around KYC/AML shall be directed by a risk-based approach that may be illustrated as follows:

Our policies shall be reviewed by the Board of Directors and shall be ratified by the Board at each alteration. The policies shall be subjected to annual reviews and changes to suit the changing needs of the market.

iv) Customer Identification and Due Diligence

While we perform KYC upon onboarding, it is important to note that we shall continuously perform due diligence on customers through transaction monitoring and periodic audits, among others. This shall be done to ensure that the transactions being conducted are consistent with our knowledge of the customer and the customer's business and risk profile, including where necessary, the source of funds.

As part of enhanced due diligence, some of our actions may include:

Obtaining additional information on the customer (for example, occupation, volume of assets) and updating more regularly the identification data of customer and beneficial owner.
Obtaining additional information on the intended use of funds transacted.
Obtaining information on the source of funds or source of wealth of the customer.
Conducting enhanced monitoring of the business relationship by increasing the number and timing of controls applied and selecting patterns of transactions that need further examination.

v) Transaction Monitoring

Our transaction monitoring may involve manual or electronic scanning of transactions based on certain parameters (for example, customer phone number, customer names, value and frequency of transactions, country of origin or destination of transactions) to determine if they are consistent with SeevCash's knowledge of the customer. Transaction monitoring is intended to alert us of unusual user activity, enabling us to meet statutory obligations with respect to reporting potentially suspicious transactions.

vi) Reporting

One of our KYC/AML obligations is to provide authorities with reports on important financial transactions. Regulatory requirements require that we make suspicious-transactions reports and large currency transaction reports. Therefore, when necessary, we shall share such information as is relevant with authorities. However, we shall ensure that we keep confidentiality and respect user data to the extent that the law shall allow.

vii) Communication and Training

SeevCash shall hold frequent strategic and operational meetings to discuss and communicate KYC/AML policies and to ensure that employees and management are on the same page regarding such policy and action. Channels of communication shall be kept open through training to ensure that employees can easily and efficiently raise concerns to management regarding suspicious activity around KYC/AML both internally and externally. Training sessions shall be planned for annually alongside other calendar events to ensure that this aspect is not sidelined. At convenient times, SeevCash shall fund the training of employees for AML/CFT training courses offered by various professional organizations, such as the Association of Certified Anti-Money Laundering Specialists (ACAMS), Association of Certified Fraud Examiners (ACFE) and American Bankers Association (ABA).

viii) Continuous Improvement and testing

There shall be continuous monitoring to ensure that SeevCash's KYC/AML system stays robust. This shall be done through assessment of compliance, review of exception reports, and reporting of main compliance failures to the board and/or senior management. Improvement shall be affected through alteration of weak points identified and the establishment of new policy where such is found wanting.

ix) Internal and External Audit

Internal audit, as described, is our third line of defense. It shall independently evaluate the KYC/AML program and processes carried out by the first and second lines of defense. The expertise and independence of the party testing the KYC/AML program shall be ensured through robust selection and retraining. Senior management is to ensure that internal and external auditors are qualified, independent, and do not have conflicting business interests/responsibilities that may influence the outcome of the audit. To further promote the independence of the audit-testing function, the board and senior management shall ensure that all audit reports (whether internal or external) are directly provided to the board.

Conclusion

SeevCash is committed to offering frictionless service. It is with this in mind that we aim to perform proper and complete checks on the customers we serve through our KYC/AML process. We shall strive to comply with regulations, both local and international. Over time, our policy will change to reflect changing global standards. We shall especially refer to the Financial Action Task Force (FATF) publications from time to time to adopt standards that are applied world over. We value your trust, and we shall ensure your safety and stability by ensuring that our services are not misused or abused by malicious parties to the detriment of genuine users. This KYC/AML policy enables us and our customers to execute our responsibilities in a more efficient, compliant, and cost-effective manner.

SeevCash LTD KYC/AML POLICY

Abbreviations