AML/CFT Policy

Cashat is committed to preventing the use of its products and services for money laundering, terrorist financing, proliferation financing, sanctions evasion, bribery, corruption or any other financial crime. This Anti-Money-Laundering and Counter-Terrorism-Financing (AML/CFT) Policy is approved by the Cashat Board and reviewed at least annually.

The policy applies to every Cashat employee, contractor, agent, merchant, affiliate and operating entity, in every market in which we operate.

Our AML/CFT framework is designed to meet — and where reasonable, exceed — the requirements of:

• The Financial Action Task Force (FATF) 40 Recommendations.
• The Money Laundering (Prevention and Prohibition) Act, 2022 and the Terrorism (Prevention and Prohibition) Act, 2022 of Nigeria.
• The Proceeds of Crime and Anti-Money Laundering Act of Kenya.
• The Anti-Money Laundering Act, 2020 of Ghana.
• Equivalent legislation in the WAEMU, CEMAC, SADC and EAC member states where we operate.
• Sanctions regimes administered by the United Nations, the African Union, OFAC, the EU, the UK and other relevant authorities.

Cashat applies a risk-based approach (RBA) to identifying and managing money-laundering and terrorism-financing risk. Every customer, product, channel, country and counterparty is risk-rated, and the depth of our controls scales with the assessed risk. The methodology is documented in our Enterprise-Wide ML/TF Risk Assessment, which is refreshed annually and after any material change in the business.

Cashat applies tiered Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) for higher-risk relationships, and Simplified Due Diligence (SDD) where law permits. See our Compliance page for the wallet-tier ladder. Beneficial owners of corporate customers (≥25% ownership) are identified and verified, and control persons are screened for sanctions and PEP status.

All parties to a Cashat transaction — sender, receiver, intermediaries and ultimate beneficiaries — are screened in real time against the consolidated sanctions lists maintained by Cashat's screening vendor, which aggregates UN, AU, OFAC, EU, UK, HMT and other applicable lists. True matches are blocked, escalated to the Money Laundering Reporting Officer (MLRO), and reported as required.

Cashat operates 24/7 automated transaction monitoring that combines deterministic rules with machine-learning anomaly detection. Typologies covered include — but are not limited to — structuring, smurfing, rapid-movement schemes, agent-collusion, mule networks, sanctions-evasion patterns, and abuse of cross-border corridors. Alerts are triaged by the Financial Crime Operations team within target SLAs that vary by alert priority.

When the MLRO concludes that a transaction is suspicious, a Suspicious Transaction Report (STR) is filed with the relevant Financial Intelligence Unit within the statutory timeframe of the jurisdiction concerned. Cashat does not tip off the subject of an STR, in line with anti-tipping-off provisions.

All customer identification documents, transaction records and internal investigation files are retained for a minimum of seven years from the end of the customer relationship or the date of the transaction, whichever is later — and longer if required by local law or by an open investigation.

All Cashat employees and agents complete mandatory AML/CFT training at induction and at least annually thereafter. Training is role-specific: front-line staff focus on red-flag identification, while compliance, risk and engineering teams receive deeper modules. Completion is tracked and audited.

Cashat has appointed a Money Laundering Reporting Officer (MLRO) and a Deputy MLRO in each licensed jurisdiction. The MLRO reports directly to the Board Risk and Compliance Committee, which oversees the AML/CFT programme. The internal audit function independently tests the framework at least annually.

AML/CFT enquiries from regulators, banking partners and counterparties should be addressed to mlro@cashat.africa. Law-enforcement requests should be sent to leo@cashat.africa with appropriate legal process attached.