Anti-Money Laundering Policy

Welcome to Easy Financial Services. This Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policy ensures key controls are documented and in adherence to the provisions of the Gambia Anti-Money Laundering and Combating Financing of Terrorism Act, 2012, and international best practices.

Easy Financial Services actively participates in domestic and international efforts to combat money laundering, terrorist financing, and other financial crimes. We are committed to preventing our services from being utilized as a conduit for illicit funds.

1. Purpose and Commitment

The purpose of this AML/CFT policy is to ensure that Easy Financial Services:

• Documents and maintains key controls for AML and CFT compliance
• Adheres to the Gambia Anti-Money Laundering and Combating Financing of Terrorism Act, 2012
• Follows international best practices and FATF 40 Recommendations
• Inculcates a strong AML/CFT compliance culture through staff training
• Complies with all applicable laws and regulations
• Prevents utilization of our services for money laundering or terrorist financing

2. Identification Requirements

In furtherance of Know Your Customer (KYC) obligations, Easy Financial Services requires employees to obtain information about customer identity by inspecting valid and acceptable identification.

Acceptable Identification for Individuals:

Acceptable identification means a form of unexpired, government-issued identification with photograph:

• Valid International Passport
• Valid Residential Permit issued by the Gambia Immigration Department
• Valid Driver's License issued by the Gambia Police Force
• Valid National Identity Card issued by the Gambia Immigration Department
• Valid Alien Identity Card issued by the Gambia Immigration Department
• Valid Gambian Passport issued by Gambia Immigration Department
• Valid Voter's Card issued by Independence Electoral Commission (IEC)

3. Sanction Policy

Any client found on a sanctions list will be declined and no transactions will be carried out. Easy Financial Services conducts open-source searches using online search engines to access:

• OFAC (Office of Foreign Assets Control) sanctions lists
• United Nations sanctions lists
• Other internationally accepted sanction lists in multiple formats
• Online sanctions databases

The institution maintains a dedicated sanctions program within the Compliance Department to aid effective monitoring.

4. Politically Exposed Persons (PEPs) Policy

Easy Financial Services requires specific procedures when dealing with Politically Exposed Persons (PEPs), whether as customers or beneficial owners. We must:

• Have appropriate risk-management systems to determine if a customer or beneficial owner is a PEP
• Obtain senior management approval for establishing or continuing business relationships with PEPs
• Take reasonable measures to establish the source of wealth and source of funds
• Conduct enhanced ongoing monitoring of the business relationship

Easy Financial Services also takes reasonable measures to determine whether a customer is a domestic PEP or holds a prominent function by an international organization. These requirements also apply to family members and close associates of such PEPs.

5. Risk Assessment

Easy Financial Services identifies, assesses, and understands the money laundering and terrorist financing risks for the institution and takes appropriate action to:

• Coordinate risk assessment mechanisms
• Allocate resources effectively
• Ensure risks are mitigated effectively
• Apply a risk-based approach throughout the AML/CFT regime
• Implement risk-based measures aligned with FATF Recommendations

Easy Financial Services reserves the right to request additional documentation and conduct risk assessments using standard risk assessment forms to be completed and submitted to the compliance department for approval prior to any transfers or transaction-related activities.

6. Foreign Currency Trading AML Risk Management

Easy Financial Services is engaged in buying and selling foreign currencies. All foreign exchange transactions comply with:

• AML/CFT regulations prescribed by the Central Bank of The Gambia
• Regulations of other recognized international organizations applicable in this jurisdiction
• All licensing requirements
• Financial Action Task Force (FATF) member state requirements

We maintain a risk-based approach to identify money laundering threats and implement commensurate measures as part of our internal AML/CFT program.

7. Training and Compliance Culture

All employees and agents of Easy Financial Services share responsibility for ensuring adherence to our AML/CFT commitment. Easy Financial Services has developed and implemented a comprehensive training program:

Employee Training:

• Every new employee must be trained on Easy Financial Services compliance policies and procedures before commencing work
• All staff receive regular training on AML/CFT best practices
• Training covers identification of suspicious activities and reporting procedures

Agent Training:

• Every new agent must be trained on Easy Financial Services policies and procedures before activation
• Agents receive comprehensive guidance on KYC requirements and compliance obligations
• Ongoing training ensures agents remain current with regulatory requirements

8. Record Keeping

Easy Financial Services retains all records for at least five (5) years, as required by the Anti-Money Laundering and Combating Financing of Terrorism Act, 2012. This includes:

• Customer identification documents and verification records
• Transaction records and details
• Risk assessment forms and documentation
• Compliance reports and monitoring activities
• Suspicious activity reports and follow-up actions

9. Suspicious Activity Reporting (SAR)

If suspicious activity is confirmed or further investigation is warranted, our compliance team takes the following action:

• Escalates the matter to senior management
• Files suspicious activity reports (SARs) with the Financial Intelligent Unit The Gambia (FIU)
• Facilitates further investigation and enforcement action
• Adheres strictly to regulatory reporting requirements

All suspicious activities, including but not limited to unusual transaction patterns, structuring, mismatched customer profiles, and high-risk jurisdictions, are promptly reported to the appropriate authorities.

10. Compliance Monitoring and Enforcement

Easy Financial Services maintains ongoing monitoring of customer accounts and transactions to:

• Detect potential money laundering or terrorist financing activities
• Identify changes in customer risk profiles
• Monitor transaction patterns and volumes
• Conduct periodic reviews of high-risk customers
• Enforce AML/CFT policies and procedures

Non-compliance with AML/CFT requirements may result in immediate account suspension, transaction denial, and escalation to appropriate regulatory authorities.

11. Contact Information