AML Policy

Anti Money Laundering

Introduction

Ugmart Limited was established in 2012. We are a mobile money changing company dealing in Buying & Selling of all major goods and services. We also offer Money Remittance Services globally through some of our products.

Our business is focused on money changing with products and services throughout the years. Ugmart Limited has provided services to many well-known and established corporations, NGOs, Banks and other institutions in Uganda and also to hundreds satisfied local individuals and foreign tourists as well.

Definition of Key Terms & Abbreviations Used in the AML Policies

AML: Anti-Money Laundering
CFT: Counter Financing of Terrorism
ML: Money Laundering
CTR: Currency Transaction Report
BOU Bank Of Uganda
FIA: Financial Intelligence Authority
UL: Ugmart Limited
CDD: Customer Due Diligence
KYC: Know Your Customer
MSB: Money Service Business
PEP: Politically Exposed Person

Ugmart Limited is committed to the highest standards of the Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT), and requires the management, and employees to follow the named standards. Ugmart Limited examines its AML strategies and objectives on an ongoing basis, and maintains an effective AML policy that reflects its best practices as a domestic financial services sales and purchase provider. Ugmart Limited AML program includes appropriate KYC and Customer Acceptance policies, including establishing the identity of the true beneficial owners, adherence to all legal and regulatory requirements imposed by the government and its regulators.

Money laundering – the process of converting funds, received from illegal activities (such as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or distort the real source of funds.

The process of money laundering can be divided into three sequential stages:

Placement:-

At this stage funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once; this form of placement is called smurfing.

Layering:-

Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered.

Integration:-

Funds get back into circulation as legitimate to purchase goods and services.

AML POLICY

Ugmart Limited providing services on the financial market adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing of illegally gained funds. AML policy means preventing the use of the company’s services by criminals, with the aim of money laundering, terrorist financing or other criminal activity.

For this purpose, a strict policy on the detection, prevention and warning of the corresponding bodies of any suspicious activities was introduced by the company. A complex electronic system for identifying every company’s client and conducting a detailed history of all operations was introduced as well.

To prevent money laundering, Ugmart Limited neither accepts nor pays cash under any circumstances. The company reserves the right to suspend any client’s operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.

COMPANY’S PROCEDURES

Ugmart Limited will make sure that it is dealing with a real person or legal entity. Ugmart Limited also performs all the required measures in accordance with applicable law and regulations, issued by monetary authorities.

The AML policy is being fulfilled within Ugmart Limited by means of the following:

Know your customer policy and due diligence
Monitoring of client activity
Record keeping

KNOW YOUR CUSTOMER AND CUSTOMER DUE DILIGENCE PROCESS

Because of the company’s commitment to the AML and KYC policies, each client of the company has to finish a verification procedure before Ugmart Limited starts any cooperation with the client, the company ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any customer or counterparty are taken. The company as well applies heightened scrutiny to clients, who are residents of other countries, identified by credible sources as countries, having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries.

Individual clients

During the process of registration, each client provides personal information, specifically: full name; date of birth; origin; complete address, including phone number and is verified by OTP as the phone owner and National identification number. A client sends the following information of the requirements of KYC and to confirm the indicated information:

Corporate clients

In case the applicant company is listed on a recognized or approved stock exchange or when there is independent evidence to show that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps to verify identity will normally be required. In case the company is unquoted and none of the principal directors or shareholders already has an account with Ugmart Limited, the official provides the following documents because of the requirements of KYC:

-A high-resolution copy of the certificate of incorporation/certificate
-A high-resolution copy of the Trading License.
-The names and addresses of directors.
-A high-resolution copy of Memorandum and Articles of Association or equivalent documents duly recorded with the competent registry;
-Description and nature of business (including the date of commencement of the business, products or services provided; and the location of principal business).
-Tax Identification Number of the Company.
-This procedure is performed to establish the identity of the client and to help Ugmart Limited know/understand the clients and their financial dealings to be able to provide the best services in the Industry.

VALIDATING PHOTO IDENTIFICATION

The photo ID must be issued by a legitimate issuing body. If the customer is not a resident of Uganda, he/she must present his passport. UL will not accept any form of identification that has expired/not valid.

Acceptable Customer ID’s are:-

Driving Permit (Uganda)
Passports
Refugee ID along with Family Attestation (issued in Uganda)
Financial Card (issued in Uganda)
National ID of Uganda

MONITORING CLIENT ACTIVITY

In addition to gathering information from the clients, Ugmart Limited continues to monitor the activity of every client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the client’s legitimate business or the usual client’s transaction history known from client activity monitoring. Ugmart Limited has implemented the system of monitoring the named transactions (both automatic and, if needed, manual) to prevent using the company’s services by criminals. UL compliance officers will always cross check the daily transaction report along with daily receipts of money remittance.

FOREX TRANSACTIONS.

Multiple Forex/Crypto cash purchases/sale made by one person in one business day must be aggregated, or added together, and treated this as a single purchase/sale, even if purchased or sold at different times during the day.

A customer purchase/sale of USD 10,000 and above or equivalent to any other foreign currencies on the same day, company must treat this as a ‘large cash transaction’ and to collect valid photo identification documents (as mentioned above) and source of the funds. All information must be obtained from the customer and documented before processing the transaction both Forex/Crypto & Money Remittance.

Total Amounts 10M Shilling & Above

If the transaction amount for a single customer on a same day is 10M (Ten Million Shilling) and above or equivalent to any other foreign currencies should also require transaction report to be submitted to FIA on a weekly basis through their website. This will also require Ugmart Limited to collect the valid photo identification documents (as mentioned above) and source of the funds before processing the transaction. This process is to protect the Counter Terrorism Financing (CTF) and Money Laundering.

MONEY REMITTANCE TRANSACTIONS

Before process any send/receive transaction, our system ensures:

-The customer fills correctly Money transfer Send/Receive Form.
-Confirm the customer logged on the Money transfer Send/Receive Form.
-Cross check the accuracy of the customer information into the Money transfer system.
-Ensure to collect the source of Fund & purpose of transaction.
-Confirm that the customer log in credentials used on form match the those on the consumer identity in the database.

MAINTENANCE OF RECORDS

Record Keeping

All customer ID’s, supporting documents which include Trading License copy, Invoice details etc. to be filed and kept it in safe place. All record keeping and reporting documentation required by the Bank of Uganda and financial regulatory authority will be maintained for a minimum of ten (10) years and they will be made readily available upon legitimate request.

Consumer Privacy

In accordance with the Privacy Act, the company must protect consumers’ personal and private information. All documents that contain consumer’s private and personal information will be stored in a secure location.

COMPLIANCE OFFICER/SYSTEM ADMIN JOB RESPONSIBILITIES:-

Develops initiates, maintains, and revises policies and procedures for the general operation of the Compliance Program and its related activities to prevent illegal, unethical, or improper conduct.
Manages day-to-day operation of the Platfrom.
Develops and periodically reviews and updates Standards of Conduct to ensure continuing currency and relevance in providing guidance to management and employees.
Collaborates with other departments (Risk Management, Internal Audit, Employee Services, etc.) to direct compliance issues to appropriate existing channels for investigation and resolution.
Consults with the General Manager as needed to resolve difficult legal compliance issues.
Responds to alleged violations of rules, regulations, policies, procedures, and Standards of Conduct by evaluating or recommending the initiation of investigative procedures.

Acts as an independent review and evaluation body to ensure that compliance Issues/concerns within the organization are being appropriately evaluated, investigated and resolved.

Identifies potential areas of compliance vulnerability and risk; develops/implements corrective action plans for resolution of problematic issues, and provides general guidance on how to avoid or deal with similar situations in the future.
Provides reports on a regular basis, and as directed or requested, to keep the senior management informed of the operation and progress of compliance efforts.
Ensures proper reporting of violations or potential violations to duly authorized enforcement agencies (BOU & FIA) as appropriate and/or required.

Monitors the performance of the Compliance Program and relates activities on a continuing basis, taking appropriate steps to improve its effectiveness.

Developing an AML/CFT Compliance Programme.

Receiving and vetting suspicious transaction reports from staff.

Filing suspicious transaction reports with the FIA.

Ensuring that the financial institution’s compliance Programme is implemented.

Co-coordinating the training of staff in AML/CFT awareness, detection methods and reporting requirements

EMPLOYEE TRAINING REQUIREMENTS

Ugmart Limited follows a rigid recruitment process, part of it being the mechanism of understanding any relationship of potential employees with any kind of crime/criminal activities.

Within our induction program, which consists of a number of intensive and hands-on training sessions, Ugmart Limited trains the new recruits in the principles, methodologies, policies and procedures of AML/KYC.

Training is to be provided to all employees (new and existing) on a periodical basis must include:-

Review of all requirements in this AML Compliance Program.

Verification of customer identification.

All relevant transaction processing requirements

Identifying suspicious activity and structured transactions. Reporting requirements related to all transactions.

Record keeping requirements.

Additional training will be provided regularly to all employees based on, but not limited to, changes in government regulations.

Periodically monitor the staff performance in compliance.

Prepare compliance related check list and to be filled by all employees in operations.

All training will be documented and retained in employee personnel files, other related AML files, or with the training Log in the TRAINING RECORDS section of the Compliance Training Resource.

STATEMENT OF POLICY

  1. The company supports the fight against money laundering and terrorism by adopting this AML Compliance Policy to prevent the Agent’s financial services from being used to promote such criminal activity.
  2. Cooperate with all the authorities, to the extent that is permitted by applicable Laws, so as to help them in their efforts to prevent or fight money laundering, and the financing of terrorism proliferation.
  3. The company will fully comply with both the intent and letter of all laws and regulations relating to AML, the prevention of terrorist financing and economic sanctions
  4. The Agent will train its employees to comply with these laws and regulations.
  5. Every employee of the company who conducts or is involved in a Money Service Business (MSB) operation is required to understand and comply with the contents of this document.
  6. A copy of this AML Compliance Policy will be declared in each company product and user interface conducting money services, in a place that is accessible to all employees conducting MSB and Forex/Crypto transactions.
  7. Maintain all customer/transactions related records for at least 10 years or for longer period if the Law in the country requires so.

MONEY LAUNDERING – CONCLUSION

Compliance is the responsibility of each and every employee.

Strict compliance is very much necessary with all laws and regulations.

Noncompliance with the law is not worth the risk.

Ignorance of the law is not self-defensive hence no excuse before the law.

In case of doubt in conducting a transaction, please always refer to our AML Policy & Procedures or contact the Compliance Officer/management team.
TOGETHER WE WILL FIGHT AGAINST ANTI-MONEY LAUNDERING.