AML & KYC Policy

To protect the funds of our Customers (as defined hereunder) and ensure compliance with international trade standards, Beulamanje Limited (hereinafter “the Company”) operates fully in accordance with the law on combating money laundering and countering the financing of terrorism and criminal activities. The Company has established a Compliance Department that develops Anti-money laundering measures and Know Your Customer procedures (AML / KYC), which are obligatory for all employees of the Company.

The Department also determines the policy of engagement with those registered and holding accounts (hereinafter – “the Customers”) on the Mojabet.co.zm website (hereinafter – “the Website”). The Compliance Department ensures that all the operations of the Company are consistent with the international standards for combating money laundering and that all the documents provided by the Customer are up to date and comply with the relevant legal requirements.

As a result, by opening an account on the Website the Customer unconditionally accepts the AML & KYC policy, agrees with the following rules and undertakes to observe them: The Company has a list of documents which must be provided by the Customer for the purpose of identity verification at any time of asking including: a colour copy of the passport (the first two pages with pictures and details, as well as the page with the residential address stamp, if there is one) or a colour copy of the national ID card.

Registration process includes verification of the Customer’s phone number. Withdrawals from the Customer’s account may be delayed once we request a Customer’s identity and until verification of the documentation provided.

Withdrawals can be made only to the account belonging to a person identified as a Customer of the Company (personal account holder on the Website). Withdrawal of funds to third parties is prohibited. Internal transfers between Customers are also forbidden.

The Company may be obliged to share information about the Customer with financial institutions and law enforcement agencies, as required by the applicable laws, and has the right to do so without obtaining prior consent.

By using the Website, the Customer gives the Company his/her consent to performing these actions. In compliance with this paragraph, the Company holds all information about Customer payment transactions for at least five years.

The Customer undertakes to respect the legal norms, including international norms which aim to combat illegal money transfers, financial fraud, money laundering and legalisation of funds obtained by illegal means.

The Customer undertakes to make every effort to avoid direct or indirect complicity in illegal financial activities and any other illegal transactions using the Website.

The Customer guarantees the legal origin, legal ownership and the right to use the funds deposited to their account. If evidence of suspicious transactions is discovered on the Customer’s account, cash deposits from questionable sources (for example, when details of the sender and the account holder do not match) and/or any actions with signs of fraud (including any refunds or cancellation of payments), the Company reserves the right to conduct an internal investigation, block or close the Customer’s account, cancel any payments and suspend operations on the account until the end of the official investigation. When making a decision the Company is guided by the provisions of the applicable law.

The Company has the right to request additional information about the Customer if the withdrawal method requested is different from the deposit method.

The Company also reserves the right to block the Customer’s account during the investigation if the Customer refuses to provide additional information as requested by the Company. In the course of investigation, the Company has the right to request additional copies of the Customer’s identity confirmation documents, statements from Telco accounts supporting deposits, copies of any bank cards used to top up the account, copies of payment documents and other documents confirming the lawful possession and legal origin of the funds. The Company also has the right to request the original documents. The company will pay special attention to Customers located in high-risk territories.

The Company’s refusal to perform transactions which are considered by the Company as suspicious (including the blocking or closing of the Customer’s account) is not grounds for civil liability of the Company for failure to fulfil obligations to the Customer.

The Company is not obliged to inform Customers or other individuals about measures taken to counter the legalisation (laundering) of proceeds from crime and terrorist financing. Exceptions are: when informing Customers about the suspension of a particular service, the refusal to carry out a Customer request or open an account, and when requesting documents from the Customer. This anti-money laundering policy is an integral part of the Customer Agreement governing the terms by which the Customer opens an account on the Website.