AML / KYC POLICY

1. Purpose of the Policy

Tanir Credit & Accounting Services Limited is committed to ensuring its services are not misused for:

money laundering,
terrorism financing,
fraud, or other financial crimes.

This policy aligns with and ensures compliance with:

The Proceeds of Crime and Anti-Money Laundering Act (2009),
The Prevention of Terrorism Act (2012),
Central Bank of Kenya AML/CFT Guidelines,
FATF (Financial Action Task Force) Recommendations.

Key objectives:

Ensure lawful and transparent operations,
Safeguard the reputation of both the company and its customers,
Fulfil reporting obligations to the Financial Reporting Centre (FRC Kenya),
Integrate AML/CFT measures with the Data Protection Act (2019).

2. Customer Due Diligence (CDD)

Before establishing a business relationship, we verify the identity, legal status, and risk profile of each client.

For individuals:

Full legal name
National ID (Huduma Namba) or valid passport
Date of birth
Mobile phone number (linked to M-Pesa)
Residential address (with proof: utility bill or lease)
Source of income/employment details

For legal entities:

Certificate of Incorporation
CR12 form (shareholders/directors list),
KRA PIN Certificate
Identification of directors or authorized signatories,
Board Resolution authorizing borrowing,
Proof of business address
Recent bank statements (3–6 months)
Valid business license or permit.

3. Enhanced Due Diligence (EDD)

Applied in high-risk situations such as:

Politically Exposed Persons (PEPs)
Large or unusual transactions
Cross-border transfers
Suspicious customer behavior

EDD measures may include:

Additional verification of the source of funds,
Periodic review of high-risk clients
Continuous monitoring during the business relationship.

4. Ongoing Monitoring

All client accounts and transactions are monitored to detect unusual or suspicious activity, such as structuring, smurfing, or unexplained fund flows.
Suspicious transactions trigger an internal review and, where required, are reported to FRC Kenya as a Suspicious Transaction Report (STR).
Monitoring is risk-based and continues throughout the relationship.

5. Record Keeping

All KYC and transaction records are retained for a minimum of 7 years following the end of a business relationship or transaction date, as required under POCAMLA Section 45.
Records must remain readily retrievable for regulatory audits and internal investigations.

6. Staff Training

Employees receive regular training on:

AML/CFT laws and internal procedures,
Red flag indicators
Confidentiality and reporting obligations.

Frequency: at onboarding and annually thereafter.

7. Sanctions Screening

All customers and counterparties are screened against:

UN, EU, and OFAC sanctions lists,
Local CBK watchlists (where applicable).

Screening occurs:

Prior to onboarding,
Periodically throughout the relationship.

Note: The company does not conduct business with sanctioned or high-risk individuals or entities.

8. Responsibilities

Board of Directors: Oversight of the AML/KYC framework

Compliance Officer / MLRO: Policy implementation, reporting, and regulator liaison,

All Employees: Duty to escalate red flags and support investigations.

9. Reporting to Authorities

Tanir Credit & Accounting Services Limited fulfils all legal reporting obligations to FRC Kenya, including:

Suspicious Transaction Reports (STRs)
Cash Transaction Reports (CTRs)
Other threshold-based reports

FRC Website: https://www.frc.go.ke

Reporting Timeline: Typically within 7 days of detection.

10. Policy Review and Updates

This policy is reviewed annually or upon significant regulatory changes. Updates are approved by senior management and communicated to all staff. The latest version is published on the company website.

11. Contact for AML/KYC Matters

Compliance Officer:

Address: P.O. Box 1255 – 00232, Ruiru, Kenya
Email: info@tanirltd.co.ke
Phone: +254 104 674 738