AML Policy

1. Purpose

This Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy outlines Fyatu’s commitment to preventing the use of our Services for money laundering, terrorist financing, or other financial crimes. This policy applies to all Fyatu entities: FYATU FINANCIAL TECHNOLOGIES LIMITED TZ (Tanzania), FYATU SARL (DR Congo), and FYATU FINANCIAL TECHNOLOGIES (Ivory Coast).

2. Regulatory Framework

Fyatu complies with applicable AML/CTF laws and regulations in the jurisdictions where we operate, including:

• Anti-money laundering legislation of the United Republic of Tanzania, the Democratic Republic of Congo, and the Republic of Ivory Coast
• Guidelines and recommendations of the Financial Action Task Force (FATF)
• Applicable international sanctions regimes

3. Know Your Customer (KYC)

All users must complete identity verification before accessing our Services. Fyatu applies a single verification standard for all Customers:

Individual users must provide:

• Full name, date of birth, nationality
• Email address and phone number
• Government-issued identification document (ID card or passport)
• Selfie photo for biometric identity verification

Business users must additionally provide:

• Certificate of incorporation and business license
• Bank statements
• Details of directors and ultimate beneficial owners (UBOs)

Accounts that have not completed verification are subject to restrictions or suspension. The Administrator reserves the right to request additional documentation at any time if deemed necessary for compliance purposes.

4. Sanctions Screening

All Customers are screened against international and local sanctions lists during the verification process. Screening is performed by our third-party KYC verification provider and includes checks against UN, EU, OFAC, and other applicable sanctions databases.

Fyatu will not onboard or provide Services to any individual or entity that appears on a sanctions list. Existing Customers found to be sanctioned will have their Accounts immediately frozen and reported to the relevant authorities.

5. Transaction Monitoring

Fyatu employs automated and manual monitoring systems to detect suspicious activities, including:

• Unusual transaction patterns, volumes, or frequency
• Transactions involving high-risk jurisdictions as identified by FATF
• Structuring of transactions to avoid reporting thresholds
• Rapid movement of funds through accounts with no clear economic purpose
• Deposits via Stablecoins (USDT, USDC) or Mobile Money from unverified or suspicious sources
• Multiple Virtual Card top-ups followed by immediate spending patterns inconsistent with normal use

6. Suspicious Activity Reporting

When suspicious activity is identified, Fyatu will:

• Investigate the activity promptly through our compliance team
• File Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with relevant authorities as required by local law
• Freeze or lock the Customer’s Account pending investigation when necessary
• Cooperate fully with law enforcement and regulatory authorities
• Notify the Customer where legally permitted to do so

Fyatu employees are prohibited from disclosing to the Customer or any third party that a SAR/STR has been filed (tipping-off prohibition).

7. Account Lockdown

Fyatu reserves the right to freeze, suspend, or terminate any Account without prior notice if:

• Suspicious or potentially illegal activity is detected
• The Customer fails to provide requested documentation or information
• The Customer is found to be on a sanctions list
• A request is received from law enforcement or regulatory authorities
• The Customer violates the Terms of Service or this AML Policy

Frozen Funds will be held until the investigation is concluded or as directed by the relevant authorities.

8. Prohibited Activities

The following activities are strictly prohibited on the Fyatu platform:

• Money laundering or terrorist financing
• Sanctions evasion
• Fraud, identity theft, or impersonation
• Tax evasion or facilitating tax evasion
• Use of anonymizing services or tools to obscure transaction origins
• Operating unlicensed money service businesses through Fyatu
• Using the platform to process funds derived from criminal activity
• Any activity listed in the Prohibited Goods and Services appendix of our Terms of Service

9. Record Keeping

Fyatu maintains records of all customer identification data, verification documents, transaction history, and compliance activities for a minimum of 5 years after Account closure, as required by AML regulations in our operating jurisdictions. Records are stored securely and made available to regulators and law enforcement upon lawful request.

10. Employee Training

All Fyatu employees and contractors with access to customer data or involvement in transaction processing receive:

• AML/CTF training upon onboarding
• Regular refresher training on evolving regulations, typologies, and red flags
• Guidance on recognizing and escalating suspicious activities

11. Contact

To report suspicious activity or for compliance inquiries:

• Compliance team: [email protected]
• General support: [email protected]