1. INTRODUCTION
Savannah Digital Bit Oasis Private Limited (“Savannah Digital Bit Oasis”, “we”, “us”, “our”) is committed to preventing financial crime, including money laundering and terrorism financing, in all jurisdictions where we operate.
As a registered reporting entity under Kenyan law, we comply with the Proceeds of Crime and Anti-Money Laundering Act, 2009 (POCAMLA) and the Prevention of Terrorism Act, 2012, as administered by the Financial Reporting Centre (FRC) of Kenya.
In addition, we align our practices with international standards, including the Financial Action Task Force (FATF) Recommendations and equivalent laws and best practices from other jurisdictions where we operate.
We recognise that our digital asset and financial technology services could be misused for money laundering, terrorism financing, or financial fraud. To mitigate these risks, we maintain robust internal controls, staff training, and automated monitoring systems that meet and exceed the expectations of regulators and stakeholders.
Failure to comply with these obligations may result in serious penalties, legal or regulatory enforcement, and reputational harm. Savannah Digital Bit Oasis is therefore committed to continuous improvement, vigilance, and high ethical standards in all aspects of our business.
2. POLICY OBJECTIVES
Savannah Digital Bit Oasis’s AML/CTF Policy aims to:
- Comply with all relevant AML/CTF legislation in Kenya and any other jurisdictions of operation;
- Prevent, detect, and report suspicious or illegal activity;
- Foster a culture of compliance and accountability within the organization;
- Provide clear guidelines to all employees, contractors, and service providers;
- Align with international AML/CFT standards, particularly the FATF Recommendations.
3. OUR AML/CTF FRAMEWORK
Savannah Digital Bit Oasis implements the following controls:
- Compliance Measures: Designed to meet obligations under POCAMLA and FATF-aligned frameworks;
- Employee Training: Mandatory induction and periodic AML/CTF training for all employees, contractors, and third-party providers;
- Risk-Based Customer Due Diligence (CDD): Tailored verification and monitoring based on the customer’s risk profile;
- Ongoing Monitoring: Automated systems to detect unusual transactions and behavioural anomalies;
- Reporting: Timely submission of Suspicious Transaction Reports (STRs) and Cash Transaction Reports (CTRs) to the Financial Reporting Centre (FRC).
4. DEFINITIONS
- Money Laundering: The process of concealing the origins of illegally obtained funds to make them appear legitimate.
- Terrorism Financing: The collection or provision of funds for the purpose of supporting terrorist acts or organizations.
- Politically Exposed Persons (PEPs): Individuals entrusted with prominent public functions, including their close associates and family members.
5. CUSTOMER DUE DILIGENCE (CDD) & KNOW YOUR CUSTOMER (KYC)
We employ a risk-based CDD and KYC framework consistent with Kenyan law and global best practices:
- Identity Verification: Collection of valid government-issued documents (e.g., national ID, passport, KRA PIN) and proof of address;
- Beneficial Ownership Identification: Determining the natural persons who ultimately own or control the customer entity;
- Enhanced Due Diligence (EDD): Applied to high-risk clients, such as PEPs or clients from high-risk jurisdictions;
- Ongoing Monitoring: Continuous surveillance to detect unusual or suspicious activities.
CDD is required for all customer categories, including:
- Individuals (any nationality);
- Sole Proprietors;
- Kenyan and foreign-incorporated companies;
- Partnerships, Trusts, and Associations;
- Government entities and non-governmental organizations (NGOs).
6. PRIVACY & DATA PROTECTION
In accordance with the Kenya Data Protection Act, 2019, Savannah Digital Bit Oasis ensures that:
- Only relevant and necessary data is collected;
- Personal data is used exclusively for regulatory and compliance purposes;
- Data is protected through encryption, access controls, and secure storage;
- Customers are informed of their rights to access, correct, or request deletion of their personal data, subject to legal requirements.
For further details, please refer to our Privacy Policy available on our website.
7. FIVE KEY AML/CTF PRINCIPLES
- Compliance: Full adherence to Kenyan AML/CFT legislation and international standards.
- International Alignment: Consistent with FATF Recommendations and FRC guidance.
- Cooperation: Active collaboration with the FRC, law enforcement, and other competent authorities.
- Risk-Based Approach: Restrict or deny services where ML/TF risk is deemed unacceptably high.
- Program Governance: Maintain an adaptive, auditable compliance program reviewed regularly.
8. ROLES AND RESPONSIBILITIES
- Board and Senior Management: Provide oversight, allocate resources, and ensure effective program governance.
- MLRO (Money Laundering Reporting Officer): The appointed AML/CTF Officer responsible for implementing, monitoring, and reporting AML/CTF measures.
- Compliance Team: Maintain daily adherence to AML/CTF procedures, deliver training, and liaise with regulators.
All employees are obligated to complete AML/CTF training and immediately report any suspicious activity to the MLRO.
9. SAVANNAH DIGITAL BIT OASIS AML/CTF PROGRAM
Our AML/CTF program includes:
- ML/TF Risk Assessments: Regular evaluations of business model, customers, and geographic exposure;
- Training: Comprehensive onboarding and refresher sessions for all relevant personnel;
- Transaction Monitoring: Automated and manual systems for identifying irregular transactions;
- Record Keeping: Retention of all customer and transaction data for at least seven (7) years, as required under POCAMLA.
10. REPORTING OBLIGATIONS
Savannah Digital Bit Oasis is committed to timely and accurate reporting, including:
- All cash transactions equal to or exceeding KES 1,000,000 (or equivalent in other currencies);
- Suspicious transactions, regardless of amount;
- Cross-border fund transfers that may pose a money laundering or terrorism financing risk;
- Reports to the Financial Reporting Centre (FRC) in accordance with Kenyan law.
11. PENALTIES FOR NON-COMPLIANCE
Failure to comply with AML/CTF obligations may result in:
- Regulatory fines and sanctions under POCAMLA;
- Criminal prosecution or imprisonment;
- Revocation of licences or business registration;
- Reputational damage and loss of stakeholder confidence.
All employees must promptly report suspected non-compliance to the MLRO or designated compliance officer.