1. Policy Statement
AfriVest LLC ("AfriVest") is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. This policy establishes the framework through which AfriVest prevents, detects, and reports money laundering, terrorist financing, proliferation financing, and other financial crimes. AfriVest maintains zero tolerance for the use of its platform to facilitate illicit financial activity.
This policy is designed to comply with the Financial Action Task Force (FATF) Recommendations, applicable national AML/CTF legislation in all operating jurisdictions, and international best practices for virtual asset service providers (VASPs).
2. Regulatory Framework
AfriVest's AML/KYC program is aligned with the following regulatory frameworks:
- FATF Recommendations 10 to 21: Preventive measures for financial institutions and VASPs
- FATF Recommendation 15: New technologies (virtual assets and VASPs)
- FATF Recommendation 16: Wire transfers (Travel Rule for virtual assets)
- South Africa: Financial Intelligence Centre Act (FICA), FSCA CASP regulations
- Zimbabwe: Money Laundering and Proceeds of Crime Act, RBZ AML/CFT Guidelines
- Kenya: Proceeds of Crime and Anti-Money Laundering Act, VASP Bill 2025
- Nigeria: Money Laundering (Prevention and Prohibition) Act, SEC Digital Asset Rules
3. Customer Due Diligence (CDD)
3.1 Standard Due Diligence, Natural Persons
All individual users must complete identity verification before accessing Platform services. Standard CDD for natural persons includes:
- Full legal name verification against government-issued identity document
- Date of birth confirmation
- Nationality and citizenship status
- Residential address verification (utility bill, bank statement, or institutional attestation)
- Biometric liveness detection and facial matching
- Source of funds declaration for transactions above defined thresholds
- Screening against global sanctions lists and PEP databases
3.2 Standard Due Diligence, Legal Entities
Corporate and institutional users must provide:
- Certificate of incorporation or equivalent registration document
- Memorandum and articles of association
- Proof of registered address
- Board resolution authorizing Platform use
- Identification and verification of all directors and authorized signatories
- Ultimate Beneficial Ownership (UBO) structure to the 25% threshold
- Identification and verification of all UBOs
- Source of funds and source of wealth documentation
3.3 Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied when heightened risk factors are identified, including:
- Politically Exposed Persons (PEPs) and their family members/close associates
- Users from high-risk jurisdictions (as identified by FATF or national risk assessments)
- Complex ownership structures or nominee arrangements
- Transactions exceeding jurisdiction-specific thresholds
- Adverse media findings
- Unusual transaction patterns flagged by monitoring systems
- Users with risk scores exceeding 60/100 on AfriVest's dynamic risk model
EDD measures include: detailed source of wealth investigation, enhanced ongoing monitoring, senior management approval for relationship continuation, more frequent periodic reviews, and additional documentation requirements.
4. Ongoing Monitoring
AfriVest conducts continuous monitoring of all customer relationships and transactions through:
- Real-time transaction screening: Every transaction is screened against OFAC, EU, UN, and UK HMT sanctions lists before settlement
- Pattern analysis: Machine learning models identify structuring, layering, and other suspicious patterns
- Velocity monitoring: Configurable thresholds detect unusual transaction frequency or volume
- Network analysis: Mapping wallet relationships to identify connections to flagged entities
- Periodic reviews: Customer risk profiles are reviewed annually (standard risk), semi-annually (high risk), or quarterly (critical risk)
5. Suspicious Transaction Reporting
When monitoring systems or staff identify transactions or activity that may constitute money laundering, terrorist financing, or other financial crime, AfriVest files Suspicious Transaction Reports (STRs) with the relevant Financial Intelligence Unit (FIU) within mandated timeframes. STR filing decisions are made by the designated Money Laundering Reporting Officer (MLRO) and are never disclosed to the subject of the report (tipping-off prohibition).
6. Travel Rule Compliance
In accordance with FATF Recommendation 16, AfriVest transmits originator and beneficiary information for all virtual asset transfers above applicable thresholds. The following data elements are transmitted to counterparty VASPs:
- Originator: name, wallet address, geographic address or national ID number or date/place of birth
- Beneficiary: name, wallet address
AfriVest verifies that counterparty VASPs are registered/licensed and maintain adequate AML/CTF controls before transmitting funds. Transfers to unregistered or non-compliant VASPs are blocked.
7. Sanctions Compliance
AfriVest maintains comprehensive sanctions compliance including:
- Real-time screening against all major sanctions lists (OFAC SDN, EU Consolidated, UN Security Council, UK HMT)
- Screening at onboarding, at every transaction, and upon list updates
- Blocking and freezing of assets belonging to designated persons or entities
- Immediate reporting to relevant authorities upon sanctions matches
- Prohibition of transactions involving sanctioned jurisdictions (comprehensive sanctions)
8. Record Keeping
AfriVest retains all CDD records, transaction records, and compliance documentation for a minimum of five (5) years following the termination of the business relationship, or longer where required by local law. Records are maintained in a format that allows timely retrieval for regulatory examination or law enforcement requests.
9. Staff Training
All AfriVest personnel receive AML/CTF training appropriate to their role. Training covers: identification of suspicious activity, reporting obligations, sanctions compliance, data protection in the compliance context, and emerging typologies. Training is conducted at onboarding and refreshed annually, with additional sessions when significant regulatory changes occur.
10. Governance & Oversight
AfriVest's AML/CTF program is overseen by:
- Board of Directors: Ultimate responsibility for compliance culture and resource allocation
- Chief Compliance Officer (CCO): Day-to-day management of the compliance program
- Money Laundering Reporting Officer (MLRO): STR filing decisions and FIU liaison
- Compliance Committee: Periodic review of policies, procedures, and program effectiveness
- Internal Audit: Independent assessment of compliance program adequacy
11. Cooperation with Authorities
AfriVest cooperates fully with law enforcement agencies, financial intelligence units, and regulatory authorities in all operating jurisdictions. This includes responding to information requests, providing evidence for investigations, and participating in regulatory examinations. AfriVest will never tip off a customer about an ongoing investigation or STR filing.
12. Policy Review
This policy is reviewed at least annually, or more frequently when triggered by: regulatory changes, new product launches, expansion to new jurisdictions, identified deficiencies, or significant changes in risk profile. All policy updates are approved by the Board of Directors.
13. Contact
For compliance-related inquiries:
- Compliance Team: compliance@afrivest.org
- MLRO: mlro@afrivest.org