Orbiko Africa Pty Ltd (referred to as “Orbiko” in this document)
Anti-Money Laundering and Know Your Customer Policy
Last updated: 4 May 2025

Overview

The AML/KYC Policy is designed to prevent and mitigate risks of Orbiko Africa being involved in illegal activities, including but not limited to:

• Money laundering.
• Terrorist financing.
• Corruption and bribery.
• Drug and human trafficking.
• Proliferation of weapons of mass destruction.

Orbiko Africa complies with the Financial Intelligence Centre Act (FICA), POPIA, and related South African regulations to ensure effective internal mechanisms are in place. The policy also aligns with international standards and requires all users, partners, and stakeholders to adhere to the same compliance measures.

For law enforcement requests, please direct official documentation to our compliance team via [email protected].

AML/KYC Policy Covers the Following:

1. Verification Procedures.
2. Compliance Officer.
3. Monitoring Transactions.
4. Risk Assessment.

1. Verification Procedures

Orbiko Africa follows Customer Due Diligence (CDD)principles, including Enhanced Due Diligence (EDD)for higher-risk customers, such as Politically Exposed Persons (PEPs).

Key Verification Steps:

• Identity Verification: Users must provide reliable, independent source documents (e.g., South African ID, passport, utility bill, or bank statement). Orbiko Africa reserves the right to collect and verify this information.
• Proof of Address: Users must submit proof of residential address, such as a utility bill not older than three months.
• Bank Account Verification: Users must provide the name of their bank account along with a supporting bank statement to verify ownership.
• Ongoing Monitoring: Orbiko Africa may periodically request updated documents, particularly if the user’s information changes or suspicious activity is detected.

Screening Against Sanctions:

Orbiko Africa screens all users and transactions against local and international sanctions lists, including those issued by:

• United Nations.
• South African Reserve Bank (SARB).
• Financial Intelligence Centre (FIC).
• US Office of Foreign Assets Control (OFAC).

Users or entities appearing on these lists will be denied access to Orbiko’s services.

Data Protection:

All personal information is collected, stored, and processed in compliance with POPIA. Users’ data will only be shared with law enforcement or regulators as required by law.

2. Compliance Officer

The Compliance Officer is responsible for ensuring adherence to the AML/KYC Policy. Their duties include:

• Collecting and verifying user information.
• Establishing and updating internal policies and procedures.
• Monitoring transactions and investigating suspicious activity.
• Maintaining records management systems for secure storage and retrieval of compliance documentation.
• Liaising with law enforcement and regulatory authorities, including the Financial Intelligence Centre (FIC).

3. Monitoring Transactions

Orbiko Africa uses advanced data analysis tools to monitor transactional patterns and detect suspicious activity. Monitoring includes:

• Daily checks against recognized sanctions and watchlists.
• Aggregating transaction data to identify unusual patterns.
• Opening cases for investigation if suspicious activity is detected.

Actions in Case of Suspicious Transactions:

• Reporting suspicious transactions to the Financial Intelligence Centre (FIC) via the Compliance Officer.
• Requesting additional documentation or information from users.
• Suspending or terminating user accounts if illegal activity is suspected.

4. Risk Assessment

Orbiko Africa adopts a risk-based approach to combat money laundering and terrorist financing, as recommended by FICA and international standards.

Risk-Based Approach:

• Higher-risk users (e.g., PEPs) undergo Enhanced Due Diligence (EDD).
• Resources are allocated to focus on areas with the highest risk.
• Risk assessments are updated regularly to reflect changes in the regulatory landscape or business operations.