AML / KYC Disclosure Statement

1. Purpose and scope#

This statement explains, at a high level, the controls Sankofa Trade uses to prevent the Platform being used for money laundering, terrorist financing, proliferation financing or sanctions evasion. It applies to every trader, institutional partner, beneficial owner and counterparty that interacts with our services. It is a disclosure, not our full internal AML policy, which is confidential.

2. Governance and responsibility#

• A designated Anti-Money-Laundering Reporting Officer (AMLRO) / Money Laundering Reporting Officer owns the programme and reports to the board.
• Roles are segregated: front-line onboarding, a compliance review function, and senior sign-off for higher-risk cases.
• Staff receive AML/CFT and sanctions training at onboarding and periodically thereafter.
• The programme is independently reviewed and updated as risks, laws and typologies change.

3. Customer due diligence (KYC / KYB)#

Before any facility is made available we verify identity and assess risk. We apply a risk-based approach: standard due diligence for typical cases, simplified measures for demonstrably low risk, and enhanced due diligence where risk is higher.

Identity (KYC)

Government identity verification (e.g. Ghana Card), liveness/biometric checks where used, proof of address and validation against authoritative sources.

Business (KYB)

Company registration, ownership structure, and identification and verification of beneficial owners (typically those holding 25% or more) and controllers.

Purpose & source

Understanding the nature of the business, the expected trade activity, and, where relevant, source of funds and source of wealth.

4. Sanctions screening#

We screen customers, beneficial owners, counterparties and, where relevant, transactions against applicable sanctions and watchlists at onboarding and on an ongoing basis, including on list updates.

• Lists screened include United Nations Security Council sanctions and other lists applicable to our operations and settlement partners;
• A confirmed true match will result in blocking, freezing where required, and reporting to the competent authority;
• Potential matches are reviewed by compliance before any account or transaction proceeds; and
• We will not process trade or settlement that would breach applicable sanctions. [legal review — confirm applicable regimes per corridor]

5. Transaction monitoring#

Activity on the Platform is monitored on a risk basis for indicators of financial crime — for example, structuring, activity inconsistent with a customer’s profile, rapid movement of funds, or trade documentation that does not match the underlying goods or corridor. Alerts are triaged by compliance, and unresolved concerns are escalated.

6. The compliance escalation we implement#

Our platform operationalises a defined escalation path rather than a generic “we take this seriously” statement. In practice:

1. Automated screening and monitoring generate cases with a risk rating and the reasons that triggered them;
2. A compliance officer reviews each case, requests further information where needed, and records a decision with an audit trail;
3. Higher-risk cases and potential true matches are escalated to a senior credit/compliance officer and, where required, the AMLRO;
4. The AMLRO decides whether to file a suspicious-transaction report and whether to restrict, suspend or exit the relationship; and
5. Actions, decisions and supporting evidence are logged immutably for regulatory audit.

7. Reporting obligations#

Where we form a suspicion of money laundering, terrorist financing or a related offence, we file the required reports with Ghana’s Financial Intelligence Centre (FIC) and cooperate with competent authorities. We also make threshold and other regulatory reports as required.

8. Record keeping#

We retain due-diligence records, transaction records and the evidence behind compliance decisions for at least the statutory minimum period (generally six years after the relationship or transaction ends), and longer where an investigation requires it. See the Privacy Policy for how these records are protected.

9. What we ask of you#

• Provide accurate, current identity, business and beneficial-ownership information, and update it when it changes;
• Only submit genuine trade documents relating to real underlying trade;
• Respond promptly to requests for information — we may pause a facility or settlement until a request is satisfied; and
• Never use the Platform to disguise the origin of funds, evade sanctions or facilitate any offence.

10. Contact#