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Protect yourself and your business
WWW.SAFARICOM.CO.KE
A Handy Guide to Anti-MoneyLaundering, Counter Terrorism &Know Your Customer Practice
Anti-moneyLaundering &KYC Booklet
Anti-moneyLaundering &KYC BookletSTAFF
Protect yourself and your business
SAFARICOM AML/CFT/KYC STAFF HANDBOOK
A handy guide to Anti Money Laundering, Counter Terrorism & Know Your Customer practice.
Introduction
Money laundering is a way of converting the proceeds of crime into assets that appear to have a
legitimate origin. This includes handling or controlling these proceeds or engaging in activities designed to
disguise their true origin.
Money laundering is associated with crimes that provide a financial gain. It’s a secondary criminal act
that follows an underlying criminal activity that generates money, which when laundered, results in the
offense of money laundering. Examples of some criminal activities Include:
• fraud, corruption,robbery,bribery
• drug dealing
• Illegal arms sales, smuggling
• computer fraud schemes
• counterfeiting of goods
• embezzlement & insider trading
• stolen goods
• human trafficking and poaching
• being directly involved in any criminal or terrorist property
• any other criminal activity that generates financial gain
MONEY LAUNDERING PROCESS
Criminal activity
Generates illegal money
Placement - the physical disposal of the initial proceeds derived from illegal activity
Layering - hiding the origin of funds by moving it and revolving around financial systems
Intergration - places the laundered proceeds back into the economy
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Criminal’s access and place the proceeds of their crimes into a financial product, such as M-PESA,
bank accounts, Western Union, forex exchange or can buy property and If undetected, the
funds will look legitimate.
Terrorism Financing
When a person unlawfully and willfully provides or collects funds with the intention that these
funds will be used in full or in part to carry out a terrorist act by terrorists or terrorist organisations.
Terrorist financing process
Terrorism
Cash collected and distributed
Recruitment
Upkeep
Purchase of firearms
Financiers of terror
The supporters of terrorengage in hidden
activity, both criminal orlegal, to generate funds
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Knowing Your Customer (KYC) Process
All customers intending to register for M-PESA must have registered their SIM cards on the Safaricom
network as per the guidelines issued by the Communications Authority of Kenya (CA).
All Customers wishing to use M-PESA must have their identity verified against acceptable identification
documents which include:
• Kenyan national identity card
• Valid passport (both local and foreign)
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• Military identity card
• Diplomatic identity card
• Alien identity card or Foreigners Certificate
The personal information you collect and record are only used to facilitate the completion of the
transaction. The record book should not be shared, photocopied or given to any other party apart from a
Safaricom appointed agent.
Suspicious Activity Report
Suspicious activity is any activity that is out of the ordinary and gives rise to a suspicion that the person is
trying to hide/conceal an underlying criminal activity.
How to Report a Suspicious Activity
If you suspect that something is not quite as it should be or a customer is engaging in any of the above
activities, then you have a cue for filing a Suspicious Activity Report.
Below are the key steps to follow:-
• Complete a SAR form in soft copy following the guidelines given on the form
• Send the SAR form as an attachment to: - [email protected].
• The form will automatically be received by the MLRO who will carry out investigations on whether the
suspicions are valid.
• You can also send an Email in confidence to [email protected] or directly to the Money
Laundering Reporting Officer (MLRO)
• After the report is sent the person who has made the report should ensure that they do not display or
communicate any suspicion to the customer or a colleague
Money Laundeing Offences
Fail to report
• You can be found guilty of money laundering if you know that someone is involved in money
laundering and you fail to report suspicion to Safaricom MLRO or directly to Financial
Reporting Center
• Knowingly handling, aiding or processing any proceeds of crime
Tip off
• It is an offence if you know that a report has been made to the Safaricom MLRO or the authorities
and you tell the customer of the suspicion of money laundering. This includes dropping hints to the
customer or a third party. The tipping off offence can even be committed by unintentionally telling a
third party, who then tells the suspect
Penalties
• The penalties for committing these offences range from up to 7 years in prison or fines of up to
2.5 million KES, or both
• Loss of business
• Costly court process