AML KYC PRIVACY NOTICE

We will process your identifying data and profile data within operations such as identification (Know your Customer, also known as KYC) and profiling (Customer Due Diligence, also known as CDD) for the execution of our Anti Money Laundering (also known as AML) and Counter-Terrorism Financing (also known as CTF) customer identification and verification process obligations.

When AfriOne Bank asks for CDD, what this refers to is proof of address and proof of identification. This along with information gathered at the application stage paints a picture of any customer (KYC). Without KYC, AfriOne Bank may unknowingly become involved with illicit activities and therefore subject to reputational, operational, and legal risks, which can result in significant financial costs or the eventual winding up of the institution. KYC is most closely associated with the fight against money laundering.

Specific proof of address, proof of Identification, source of funds, and/or AML-CTF questionnaires that are aimed at fulfilling KYC and CDD obligations are compulsory to AfriOne Bank users and the failure to be replied might lead (in extreme cases) the blocking of their accounts or the refusal of services.

In response to the scale and effect of money laundering, the European Union has passed Directives designed to combat money laundering and terrorism. These Directives, together with national regulations as read below, form the cornerstone of our AML/CTF obligations, establish the legal basis for us to process this data, and outline the offenses and penalties for failing to comply.

Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market;

Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for money laundering or terrorist financing;

Council Decision of 17 October 2000 concerning arrangements for cooperation between financial intelligence units of the Member States in respect of exchanging information (2000/642/JHA);

Crime Proceeds of Crime Act 2015;

Terrorism Act 2018;

Drug Trafficking Offences Act 1995;

ANTI-MONEY LAUNDERING (AML) POLICIES

Our AML policy is designed to prevent money laundering by meeting the European standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. Our AML policy sets out the minimum standards which must be complied with and includes:

1.    Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules, and industry guidance;

2.    Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm. The requirement to provide CDD-related data throughout an RBA that will always take into account different factors such as the status of the client, the nature of the transactions, the financial product, or the financial flows involved;

3.    Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification, and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);

4.    Establishing and maintaining risk-based systems and procedures for the monitoring of ongoing customer activity;

5.    Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

6.    Maintaining appropriate records for the minimum prescribed periods;

7.    Providing training for and raising awareness among all relevant employees.

As a regulated financial institution, AfriOne Bank has specific requirements regarding AML systems and procedures. This reflects senior management’s desire to prevent money laundering.

ANTI MONEY LAUNDERING AND COMBATING TERRORIST FINANCING

Money laundering is defined as the process where the sources of funds are disguised so that it gives an impression of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicion.

SANCTIONS POLICY

AfriOne Bank is prohibited from transacting with individuals, companies, and countries that are on prescribed sanctions lists. AfriOne Bank will therefore screen against the United Nations, European Union, UK Treasury, and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

AUTOMATED DECISION MAKING

We use semi-automated processes which include but are not limited to, screening Know-Your-Customer (KYC) and Anti-Money Laundering (AML) data you provide to us to assess whether or not we are legally able to allow you to use our services.

All automated screening matches are manually reviewed by AfriOne Bank compliance analysts. The analyst will review the triage cases to determine if they should be cleared or escalated to the MLRO.

THIRD PARTIES AML-KYC

Where the processing of personal data is carried out on behalf of AfriOne Bank by a third-party provider, we conclude a separate contract with the processor concerning this processing. This contract ensures compliance with European data protection regulations and defines sufficient guarantees for the implementation of appropriate technical and organizational measures, which ensure the protection of your rights.

SECURITY MEASURES

We have put in place appropriate security measures to prevent your Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We have taken precautions to ensure the security of your data. The Personal Data you have entered on HTML pages (contact forms) and that is stored by us, shall be transmitted to AfriOne Bank in encrypted form (TLS - Transport Layer Security) via the public data network, and stored and processed at AfriOne Bank.

In addition, we limit access to your Data to those employees, agents, contractors, and other third parties strictly needed under the provisions made within a service agreement signed with them. They will only process your Data on our instructions and they are subject to a duty of confidentiality and a duty to comply with data protection procedures.

We have put in place procedures to deal with any suspected or actual Personal Data breach. We will notify you and any applicable authority of a Personal Data breach where we are legally required to do so.

INFORMATION ABOUT BACKGROUNDS

We envisage that we will process and store information about background investigations and certificates of good conduct issued by policing authorities and due diligence of all candidates. Once a decision has been made regarding interest in hiring an applicant any offer will be made contingent upon the satisfactory completion of reference checks and criminal background checks.

We will only process information about criminal records, convictions, and offenses where we have obtained your explicit consent, where necessary for performing or exercising our or your obligations or rights under applicable laws and regulations, and where it is necessary for the prevention and detection of an unlawful act or reasons of substantial public interest.

Where we are processing personal information based on your consent, you have the right to withdraw that consent at any time where there is no other legal basis for the processing, by contacting us at afrione@afrionebank.africa

CONTACT INFORMATION 

Any questions or suggestions about these Terms and conditions should be addressed via email to: “afrione@afrionebank.africa”. This notice is reviewed intermittently and may be updated at any time. We are regulated by the Information Commissioner’s Office You can contact them for advice and support.

Thank you

Privacy & Compliance Department.

2 Baanbreker Avenue, Helderkruin, Roodepoort South Africa

AFRIONE BANK – EVERYONE IS BANKABLE