1. Introduction
Sevenlocks Bureau de Change acknowledges its legal and moral responsibility to fight financial crime and the misuse of the economic system. This AML/CFT policy is designed to establish a clear framework for identifying, preventing, and reporting suspicious activities that may involve money laundering or the financing of terrorism. It reflects our commitment to transparency, integrity, and local and international law compliance.

2. Objectives of the Policy
This policy’s primary goal is to protect the company from being exploited for money laundering or terrorist financing. Specific objectives include preventing financial crimes, ensuring full compliance with regulatory expectations, safeguarding our reputation, protecting our customers, and promoting a culture of accountability and vigilance among employees.

3. Definitions
Money Laundering (ML): Disguising the origins of illegally obtained money.
Terrorist Financing (TF): Providing funds to support terrorist activities.
Suspicious Transaction: A transaction that appears unusual, lacks a clear economic purpose, or does not fit a customer’s profile.

4. Governance and Oversight
The Managing Director is ultimately accountable for the company’s AML/CFT compliance, while the Compliance Officer handles day-to-day implementation. The Compliance Officer oversees monitoring, investigations, and reporting duties. All staff must comply with this policy and report suspicious activities without delay. A zero-tolerance approach is enforced.

5. Know Your Customer (KYC) and Customer Due Diligence (CDD)
Our KYC process involves gathering comprehensive identification information before entering a business relationship or conducting transactions. Customer Due Diligence requires assessing the risk associated with the customer and applying additional scrutiny to high-risk accounts. Ongoing due diligence ensures continued monitoring and detection of behaviour or risk level changes.

6. Monitoring and Reporting
All transactions are continuously monitored for red flags using automated systems, which generate alerts for review. Suspicious Transaction Reports (STRs) are submitted to the NFIU when an activity lacks apparent economic legitimacy or involves large, irregular amounts. Currency Transaction Reports (CTRs) are submitted for high-value cash transactions above prescribed thresholds. All reporting is done promptly and confidentially

7. Record-keeping and Retention
Transaction records, customer profiles, and KYC documentation are stored securely for at least five years, even after the end of a business relationship. These records must be readily available for regulatory inspection. Data security protocols, including encryption and regular backups, are strictly enforced.

8. Staff Training and Awareness
Training is an essential part of the AML/CFT program. All employees undergo initial and periodic training on AML/CFT responsibilities. Training includes money laundering typologies, recognising suspicious activity, customer onboarding protocols, and regulatory requirements. Participation is mandatory and tracked by the Compliance Officer.

9. Internal Controls and Independent Audit
Internal controls such as dual authorisation, segregation of duties, and reconciliation checks help prevent financial crimes. Periodic independent audits assess the effectiveness of AML procedures and detect any control weaknesses. Management is responsible for implementing audit recommendations.

10. Sanctions Screening
All clients and transactions are screened against local and international sanctions lists. This includes OFAC, UN, and EU lists. Transactions linked to sanctioned individuals, entities, or countries are automatically flagged and escalated for further review or blocked entirely.

11. Policy Review
This AML/CFT policy is reviewed at least once a year or whenever there is a significant change in regulations or operations. Revisions are approved by the Managing Director and disseminated to all staff to ensure complete understanding and compliance.

12. Non-Compliance Consequences
Employees violating this policy may face disciplinary action, including termination and possible legal proceedings. Non-compliance may also result in regulatory sanctions, fines, or license revocation for the company. All staff are urged to remain vigilant and report any
concerns immediately.