AML Procedure

Vodafone Agent ~ Anti-Money Laundering Procedure

1. Overview of the AML Policy
M-PESA is the electronic money transfer service offered by Vodacom Tanzania Limited. Vodacom Tanzania Limited, as the entity responsible for delivering the service, has an important role to play in furthering the local and international efforts against money laundering and terrorist financing. The most effective way to fulfill this commitment and to protect both the company and its staff is to know our customer, be alert to suspicious activity and train all staff to be proficient at identifying suspicious activity on a regular basis. This document is designed to inform all who come into contact with M-PESA what the procedures are to assist in the execution of the Vodacom M-PESA Anti-Money Laundering Policy.

2. Overview of the AML Procedures manual
This manual contains the procedures that must be followed and controls that must be implemented by all AML staff and agents to ensure compliance with both local and relevant international AML legislation and the M-PESA Anti-Money Laundering Policy.
Vodacom will review and update these procedures at least annually to take into consideration changes to the products, business conditions and regulatory environment. The annual review will also be used to evaluate how accurately the procedures reflect the product and how effective they are in controlling the AML threat.
All changes to this procedure manual must be approved by the Vodacom Group MLRO with significant changes also being approved by the Vodafone Group MLRO.

3. Agent Responsibilities in terms of AML Regulations

• M-PESA agents are agents for Vodacom Tanzania Limited, who provide M-PESA services to members of the public as well as recruit new M-PESA customers. These include agents who operate one or more outlets (stores) around Tanzania and retailers with a substantial distribution network like petrol stations/distributors etc.
• All M-PESA agents and their staff must be vigilant in the fight against money laundering and terrorist financing and must do their utmost to prevent the M-PESA product from being used for money laundering or terrorist financing activities.
• All agents involved with M-PESA will receive training outlining how to comply with M-PESA Anti-Money  Laundering Procedures and to make them aware of the criminal and civil liability that he/she may be subject to for failure to report suspicions or 'tipping off' a suspect of a internal or external AML investigation.
• Agents shall also ensure that all agent staff who deal with/work with the M-PESA product receive AML training. They shall among others, also comply with their contractual obligations to Vodacom in terms of corruption, anti-money laundering and terrorist financing which include ensuring that anyone acting on their behalf, their own agents/ sub- contractors if any, who deal M-PESA are trained and comply. This also includes ensuring that their M-PESA staff and others acting on their behalf have access to suspicious transaction reporting forms and reporting facilities prescribed in this procedure. In the event that they require staff to first report suspicious transactions to them, they shall still be obliged to ensure that the report is communicated to the Vodacom MLRO who will decide on the appropriate action to take.
• Agents are required to review any bulletins relating to M-PESA Anti-Money Laundering Policy or M-PESA Anti-Money Laundering Procedure updates which will be communicated by the Vodacom MLRO. Compliance with the M-PESA Anti-Money Laundering Policy and M-PESA Anti-Money Laundering Procedures is mandatory and is a condition of the contract. Failure to adhere to the M-PESA Anti-Money Laundering Policy and M-PESA Anti-Money Laundering Procedures may result in action up to and including termination of the contract.

4. Know Your Customer (KYC)

Knowing Your Customer (KYC) is a critical part of the overall M-PESA Anti-Money Laundering program. KYC refers to the process of verifying the identity of prospective customers. This is vital for the following reasons:
1.    To comply with the requirements of relevant Anti-Money Laundering legislation and regulations.
2.    To help Vodacom Tanzania Limited and Vodafone Group to be reasonably certain that the customers are who they say they are, and that it is appropriate to provide them with the service.
3.    To help identify, during the course of a relationship, what is unusual and potentially suspicious transaction behavior
4.    To assist law enforcement by providing available information on customers being investigated following the making of a suspicious activity report.

5. Customer KYC Procedure
The following information must be obtained from all applicants and captured on the customers M-PESA registration form.
·         Full name
·         Date and place of birth
·         Type and reference number of document used to confirm identity
·         Residential Address