Anti-Money Laundering (AML) & Financial Crime Prevention Policy

Effective Date: January 1, 2026

Mswahili Technologies is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes across all platforms, including Bantu Soko, Bantu Dereva, and Kadi (collectively, the “Services”).

This policy outlines the controls, procedures, and safeguards implemented to ensure compliance with applicable anti-money laundering (AML) laws, counter-terrorism financing (CTF) regulations, and financial crime prevention standards.

1. Purpose

The purpose of this policy is to define the framework used by Mswahili Technologies to detect, prevent, mitigate, and report suspicious financial activities in accordance with applicable laws and international compliance standards.

2. Customer Due Diligence (CDD) & Identity Verification

We apply Customer Due Diligence (CDD) procedures to verify the identity of users before and during their use of the Services.

Verification may include collection and validation of personal details such as phone numbers, national identification documents, business registration details, biometric verification (where applicable), and transactional behavior analysis.

Enhanced Due Diligence (EDD) may be applied to high-risk users, high-value transactions, or users operating in higher-risk jurisdictions or activity categories.

3. Transaction Monitoring & Risk Detection

We continuously monitor transactions and platform activity using automated and manual systems designed to identify unusual, suspicious, or potentially illegal behavior.

• Unusual transaction volumes or patterns inconsistent with user behavior
• Rapid movement of funds without clear economic purpose
• Structuring transactions to avoid detection thresholds
• Use of multiple accounts for coordinated activity
• Suspicious geographic or device-based anomalies

4. Risk-Based Approach

We apply a risk-based compliance framework to allocate resources and controls based on assessed risk levels.

Risk assessment may consider factors including user profile, transaction behavior, geographic exposure, industry type, and historical activity patterns.

Higher-risk users or activities may be subject to additional verification, transaction limits, or enhanced monitoring procedures.

5. Reporting Obligations

Where required by applicable law, we may report suspicious transactions, activities, or user behavior to relevant financial intelligence units, regulators, or law enforcement authorities.

Such reporting may occur without prior notice to the user and in accordance with legal confidentiality and reporting obligations.

6. Record Keeping & Data Retention

We maintain records of identity verification, transaction history, and compliance-related activity for periods required under applicable AML/CTF laws and regulatory frameworks.

These records are retained to support audits, investigations, regulatory compliance, and internal risk management processes.

7. Prohibited Activities

Users are strictly prohibited from using the Services for any unlawful or illicit financial activities.

• Money laundering or attempts to conceal the origin of funds
• Financing terrorism or other criminal organizations
• Fraudulent, deceptive, or manipulative financial activity
• Structuring transactions to evade monitoring or reporting requirements
• Any activity violating applicable financial crime prevention laws

8. Enforcement Measures

We reserve the right to take appropriate enforcement action where suspicious or prohibited activity is detected.

Enforcement actions may include temporary suspension, restriction of account functionality, transaction blocking, freezing of funds where legally required, or permanent termination of access.

Such actions may be taken without prior notice where necessary to comply with legal obligations or protect platform integrity.

9. Policy Updates

This AML Policy may be reviewed and updated periodically to reflect changes in legal requirements, regulatory guidance, and operational improvements. Updated versions will take effect upon publication.