BUBURUZA BANK is dedicated to preventing its financial services from being used for money laundering or terrorist financing. This AML/CFT Compliance Framework is provided to all clients to ensure compliance with applicable international standards and legal obligations. It outlines our policies, procedures, and client responsibilities to maintain the integrity of our financial ecosystem.

Purpose

The purpose of this framework is to:

• Prevent money laundering and terrorist financing within BUBURUZA BANK’s operations.
• Ensure compliance with global AML/CFT standards.
• Protect clients and the bank from financial crime risks.

1. Scope and Applicability

• Covered Entities: This framework applies to all BUBURUZA BANK clients, including individuals, legal entities, settlors, beneficiaries, and correspondent bank clients utilizing services such as trust accounts, digital asset custody, loans, and investment banking.

2. General Obligations

Clients must adhere to the following obligations:

• Risk-Based Approach: Cooperate with BUBURUZA BANK’s risk assessments and mitigation measures.
• Customer Due Diligence (CDD): Provide accurate and complete information for identity verification and risk profiling.
• Reporting Suspicious Activities: Promptly report any suspected money laundering or terrorist financing to BUBURUZA BANK, which will escalate to relevant authorities as required.

3. Risk Assessment and Management

• Bank’s Responsibility: BUBURUZA BANK conducts a general risk assessment to identify and assess risks of money laundering and terrorist financing across its operations, including trust services, digital assets, and international transfers.
• Client Responsibility: Disclose business activities, sources of funds, and intended use of services to enable accurate risk classification (e.g., low, medium, high risk).
• Documentation: BUBURUZA BANK maintains risk assessment records, updated annually or upon significant changes, accessible via secure digital platforms.

4. Customer Due Diligence (CDD) Measures

Clients are subject to the following CDD measures:

• Basic CDD:
• Identity Verification: Provide government-issued ID (e.g., passport), address, and, for entities, registration details and beneficial ownership information.
• Purpose of Relationship: Declare the intended purpose and nature of the banking relationship (e.g., trust management, investment).
• Timing: Conducted at account opening, significant transactions, or when doubts arise about prior information.
• Enhanced Due Diligence (EDD):
• Applied to high-risk clients (e.g., politically exposed persons—PEPs), complex transactions, or jurisdictions with inadequate AML/CFT measures.
• Requires additional documentation (e.g., source of wealth) and ongoing monitoring.
• Simplified Due Diligence:
• Applied to low-risk clients (e.g., regulated entities), with reduced verification requirements, subject to periodic review.
• Beneficial Ownership:
• Clients must identify ultimate beneficial owners (UBOs) holding >25% ownership or control, verified via official registers or declarations.
• Retention: CDD data is retained for 5 years post-relationship end, extendable if required by authorities.

5. Ongoing Monitoring

• Transaction Monitoring: BUBURUZA BANK uses AI-driven systems to monitor client transactions continuously, ensuring consistency with known profiles.
• Client Cooperation: Clients must promptly explain unusual transactions or changes in activity upon request.
• Updates: Clients must update CDD information if circumstances change (e.g., address, ownership).

6. Reporting Obligations

• Suspicious Activity Reports (SARs):
• Clients must report suspicions of money laundering or terrorist financing to BUBURUZA BANK immediately.
• BUBURUZA BANK will escalate such reports to the appropriate authorities as required by applicable laws.
• Protection: Clients reporting in good faith are protected from liability.

7. Internal Controls and Training

• Bank Procedures: BUBURUZA BANK maintains written AML/CFT routines, reviewed annually, covering risk management, CDD, and reporting.
• Staff Training: Employees and agents receive annual training on AML/CFT risks and compliance.
• Client Awareness: Clients receive this framework and are encouraged to seek guidance via support@BUBURUZA.io.

8. Sanctions

• Sanctions Screening: Clients and transactions are screened against international sanctions lists (e.g., UN, EU). Matches result in account freezes and reporting.

9. Third-Party Reliance

• Delegated CDD: BUBURUZA BANK may rely on third parties for CDD, ensuring they meet international standards. Clients remain responsible for accuracy.
• Oversight: BUBURUZA BANK retains ultimate responsibility and monitors third-party compliance.

10. Record-Keeping

• Retention Period: All AML/CFT records (e.g., CDD, transactions) are kept for 5 years post-transaction or relationship end.
• Access: Stored securely on blockchain or digital ledgers, accessible to authorities upon request.

11. Penalties for Non-Compliance

• Client Consequences: Failure to comply may result in account suspension, termination, or reporting to authorities.
• Bank Measures: BUBURUZA BANK may impose sanctions (e.g., fines) for serious breaches by clients acting as intermediaries.

12. Client Responsibilities

• Compliance: Adhere to all AML/CFT requests from BUBURUZA BANK.
• Disclosure: Provide truthful, timely information and report suspicious activities.
• Legal Awareness: Understand and comply with local laws, as BUBURUZA BANK’s obligations do not exempt clients from their jurisdictional duties.

13. Contact and Support

• Queries: Contact support@BUBURUZA.io or use the Telegram app/BUBURUZA-BANK.io for assistance.
• Updates: Clients will be notified of framework amendments via digital platforms.

Conclusion

This AML/CFT Compliance Framework ensures BUBURUZA BANK and its clients meet international standards to combat money laundering and terrorist financing, fostering a secure and transparent financial environment. By adhering to these measures, we collectively uphold our commitment to financial integrity and innovation.