1. INTRODUCTION AND SCOPE

1.1 Introduction
This document explains Sendhome’s Policy for Anti-moneylaundering and the Combating of the Financing of Terrorist
and Related Activities and Sanctions. Sendhome management has committed to these security policies to identify any
business relationship, transaction or prospective business relationship or transaction involving individuals, entities,
countries, goods or activities targeted in applicable financial sanctions legislation as much as possible and apply measures
to combat the proliferation of weapons of mass destruction and other sanctioned activities. Sendhome will take all
reasonable steps to ensure that any financial services it provides is not used to benefit sanctioned individuals or entities
or to carry out sanctioned activity or any activity involving sanctioned goods or the proliferation of weapons of mass
destruction.

1.2 Scope of Compliance
This policy applies to the whole company, employees, contractors, temporary employees, consultants, clients,
shareholders, vendors and outside agencies. It must be read together with applicable sections of the Financial Intelligence Centre Act (FICA) and in particular Section 26A, 26B,28A and SARB Guidance Note 7 and other country-specific regulatory and supervisory rules, guidance notes, public compliance communications, directives and circulars, etc. and – the Sendhome RMCP.

 

2 POLICY ROLES AND RESPONSIBILITIES

 

2.1 Policy Applicability

All employees, contractors, vendors and third-parties that use, maintain or handle Sendhome information assets must follow this policy. No exemptions will be permitted.

 

2.2 AML Compliance Officer

The Compliance Officer is responsible for coordinating and overseeing Sendhome’s compliance with policies and procedures regarding Anti-money laundering and the Combating of the Financing of Terrorist and Related Activities.

 

2.3 AML/CFT Compliance Department

Successfully implementing this policy requires that the various departments and groups consistently adhere to a shared vision for Anti-money laundering and the Combating of the Financing of Terrorist and Related Activities and Sanctions.

The Compliance Department works with departmental system managers, administrators and users to ensure compliance. Specific responsibilities of the Information Security Department include:

• Create and update new complaince policies and procedures when needs arise. Maintain and update existing AML / CFT policies and procedures. Review the policy on an annual basis and assist management with the approval process.
• Act as a central coordinating department for implementation of the AML/CFT Policies.
• Monitor and analyze money laundering alerts and distribute information to appropriate information security, technical and business unit management personnel.
• Review logs daily. Follow up on any exceptions and matches identified.

2.4 Know Your Client (KYC)

Sendhome must establish and verify the identity of all clients in line with agreed standards. Sendhome shall not establish business relationships or conclude a single transactions with clients who would expose the company to reputational, operational or legal risks because of the company not complying with its RMCP or any regulation associated with its RMCP. 

The company will not establish a business relationship with clients who insist on anonymity or who give fictitious names.

2.5 Screening of domestic prominent influential persons and foreign prominent public officials.

Sendhome will screen the records and cross-border transactions of prospective and existing clients by comparing these records and transactions against the following sanctions lists: OFAC, UN Sanctions Lists and EU Sanctions List.

In addition, Sendhome will review negative media databases to supplement the lists.

When a prospective-client, existing-client or cross-border transaction match is identified during the screening process, the party information or cross-border transaction must be reviewed and investigated to determine whether or not it is a false positive or a true positive. No transactions will be allowed if the match is confirmed to be positive.

In particular, Sendhome must, where required, refuse to establish a new business relationship, continue with an existing business relationship or conclude a single transaction or a transaction in the course of a business relationship where a
true positive match is identified in respect of:

• a specified entity identified in a notice issued by the President of the Republic of South Africa under section 25 of
  the Protection of Constitutional Democracy Against Terrorist and Related Activities Act, 33 of 2004 (Pocdatara);
  and/or
• a person or an entity identified pursuant to a resolution of the Security Council of the United Nations contemplated
  in a notice referred to in section 26A(1) of the Financial Intelligence Centre Ac, 38 of 2001, as amended (Fica),
  unless that business relationship or transaction is a permitted financial service or permitted dealing of property.
• Sendhome must, where required, refuse to facilitate a transaction where a true positive match is identified in respect
  of an individual or entity on a ratified sanctions list if that facilitation would be in breach of the applicable sanctions
  regime.
• Sendhome must, within 10 business days of becoming aware of the reportable transaction, report to the FIC the
  prescribed details concerning knowledge or suspicion with regard to:
  – a transaction or series of transactions; and
  – activity where no transaction is concluded, in relation to the proceeds of unlawful activity, money laundering,
  terrorist financing, proliferation finance or financial sanctions.

• Facilitate Money Laundering, Terrorism Financing, Proliferation Financing and sanctioned activities.
• Establish or continue business relationships or conclude a single transaction with high-risk clients if Sendhome has not conducted Enhanced Due Diligence on them.
• Establish or continue business relationships or conclude a single transaction with clients that would expose Sendhome to reputational, operational or legal risks because of not complying with policies or any regulation associated with the policies
• Have clients who insist on anonymity or give fictitious names.
• Sendhome understands that a breach of Anti Money Laundering, Combating of the Financing of Terrorism and related activities and sanctions rules and risk appetite expressions could happen despite its best efforts. Sendhome will always have risk mitigation and remediation plans in place to limit the chances of breaches inadvertently
  happening.