Last Update: 01 July 2025
Introduction
At Samex Ltd, we are fully committed to preventing money laundering and the financing of terrorism. We operate in compliance with international Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) standards.
Our company is a licensed under the jurisdiction of Mwali Comors, and we fully adhere to the regulatory framework set by our licensing authority, CL20250603. In addition to local compliance obligations, we follow the recommendations of the Financial Action Task Force (FATF)and enforce controls aligned with relevant international sanctions regimes, including those issued by the United Nations, European Union, Office of Foreign Assets Control (OFAC), and other competent authorities.
This AML Policy outlines the procedures and internal controls we implement to detect, prevent, and report suspicious activities in accordance with both national and global standards.
1. Regulatory Compliance
We comply with all AML/CFT (Combating the Financing of Terrorism) obligations as required by:
* The Financial Action Task Force (FATF)
* Our licensing authority: Mwali Comoros
Our policies are regularly reviewed and updated to reflect changes in legal and regulatory requirements.
2. Customer Due Diligence (CDD)
We apply a risk-based approach to Customer Due Diligence, which includes:
* Identity Verification: Customers must complete KYC (Know Your Customer) verification before accessing full services.
* Proof of Address: Valid proof of address is required for account verification.
* Ongoing Monitoring: Transactions are monitored for unusual or suspicious activity.
Enhanced Due Diligence (EDD) measures are applied to high-risk customers or jurisdictions.
3. Know Your Customer (KYC)
Our KYC process ensures we understand who our customers are. This includes:
* Government-issued photo ID (e.g., passport, driver’s license)
* Selfie verification (for biometric confirmation)
* Proof of address document (utility bill, bank statement)
We may request additional documents as needed for risk mitigation.
4. Transaction Monitoring
We monitor all transactions using automated systems that flag suspicious behavior such as:
* Rapid movement of large sums
* Structuring transactions to avoid reporting thresholds
* Transactions to or from high-risk jurisdictions
Suspicious activity may be reported to the relevant financial intelligence unit (FIU).
5. Reporting Suspicious Activity
We are legally required to file Suspicious Activity Reports (SARs) in the event of suspected money laundering or terrorist financing. All reports are filed confidentially with the appropriate authorities.
6. Record Keeping
In accordance with regulatory obligations, we retain all customer identification and transaction records for at least 7 years after the end of the customer relationship.
7. Training and Awareness
All staff members undergo regular AML training to ensure awareness and understanding of:
* The risks associated with money laundering
* How to identify and report suspicious activities
* Regulatory changes and industry best practices
Employees’ Obligations, Education and Training Employees’ Obligation, Staff should be made aware of:
1. The company’s and their own personal statutory obligations and the possible consequences for failure to comply with CDD and record-keeping requirements under the AML act and Prevention of terrorism act.
2. Any other statutory and regulatory obligations that concern their AIs and themselves under the AML act, Prevention of terrorism act and other related acts and regulations, and the possible consequences of breaches of these obligations;
3. The company’s policies and procedures relating to AML/CFT, including suspicious transaction identification and reporting
4. Any new and emerging techniques, methods and trends in ML/TF to the extent that such information is needed by the staff to carry out their particular roles in the company with respect to AML/CFT.
Disclaimer: This AML Policy is subject to change without notice to comply with updates in applicable law and regulation.