AML Policy

Scope

Money Laundering is the process of any activity by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins. Criminal proceeds may take any form, including money or money’s worth, securities, tangible property and intangible property. Terrorism Financing is defined as providing, depositing, distributing or collection funds, directly or indirectly, intended to be used, or knowing that these funds are to be wholly or partially use, for the committing of terrorist acts. This Policy is aimed to prevent any company or individual from using Bani for money laundering or terrorist financing activities.

Our Policy

Customer Due Diligence

To prevent Money Laundering, Bani will implement processes and procedures in its Line of Businesses (LOBs) to conduct appropriate customer due diligence through the Bani, identifying the customer and verifying the customer’s identity on the basis of “Know Your Customer” principles.

Risk-Based Approach

Bani will classify its customers based on a risk level in its applicable line of business processes and procedures. Identifying the potential risk will help to effectively manage these risks, implementing controls to mitigate the identified risk, if any.

High Risk Customers

Bani will not do business with the following segments of customers:

Persons included in any official lists of sanctions;

Persons indicating possible involvement in criminal activities, based on available information about them;

Persons with businesses in which the legitimacy of activity or source of funds can’t be reasonably verified;

Persons refusing to provide the required information or documentation; or Entities whose shareholder/control structure cannot be determined.

Record Keeping

Customer documentation can either be submitted in physical or electronic form. An appropriate record of the received documentation, steps taken and copies of, or reference to, the documentation of the customer must be kept.

Records should be kept for as long as the relationship endures with the customer and for at least five (5) years after the relationship ends. In countries where this period exceeds the established period of time, the legally established time period will be considered to comply with local law.

Policy Review

Policy Review and Audits Regular reviews of the effectiveness of this Policy are carried out in addition to audits periodically undertaken by Bani.