Anti-Money Laundering Policy

UbiaConnect applies risk-based anti-money laundering (AML) and counter-terrorist financing (CFT) controls across all platform workflows, in line with applicable Tanzanian legal and regulatory obligations.

1. Regulatory Framework

Our AML and CFT programme is designed to comply with:

1. The Anti-Money Laundering Act of Tanzania.
2. The Financial Intelligence Unit of Tanzania (FIU) guidance and reporting requirements.
3. Applicable United Nations and African Union sanctions frameworks.
4. Bank of Tanzania and Capital Markets Authority directives as applicable.

2. Customer Due Diligence

All platform users are subject to know-your-customer (KYC) and customer due diligence (CDD) controls before accessing regulated workflows. This includes:

• Identity verification using government-issued documentation.
• Screening against sanctions lists, politically exposed person (PEP) registers, and adverse media.
• Source of funds and source of wealth assessment for investment activity.
• Enhanced due diligence (EDD) for high-risk users, jurisdictions, or transaction profiles.

3. Ongoing Monitoring

We conduct ongoing transaction monitoring and periodic review of user profiles to detect:

• Unusual transaction patterns inconsistent with stated financial profile.
• Payments from or to high-risk or sanctioned jurisdictions.
• Structuring, layering, or other indicators of money laundering typologies.
• Activity inconsistent with stated use of platform or investment objectives.

4. Reporting and Escalation

Where reasonable grounds exist to suspect money laundering, terrorist financing, or sanctions evasion, UbiaConnect will:

1. Escalate the matter to the Money Laundering Reporting Officer (MLRO).
2. Submit a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) to the FIU as required by law.
3. Take appropriate risk mitigation steps including account restriction, payment suspension, or access termination.
4. Maintain records in accordance with mandatory retention obligations.

5. User Obligations

Users must co-operate fully with UbiaConnect's AML and KYC processes. Failure to provide requested documentation, providing false information, or attempting to circumvent compliance controls may result in immediate suspension and mandatory regulatory reporting.

6. Records Retention

AML and compliance records are retained for a minimum of seven (7) years in accordance with Tanzanian regulatory requirements.

7. Governing Law

This policy is governed by the laws of the United Republic of Tanzania.