1. Customer Due Diligence (CDD)
Every user must be identified and verified before transacting beyond Tier 0 limits. CDD is risk-based and includes:
- Full name, date of birth, ID/passport number, nationality.
- Residential address (proof not older than 3 months).
- Live selfie matched to ID document.
- Sanctions, PEP and adverse-media screening.
2. Tiered limits
- Tier 1 (basic): up to USD 1,000 / day equivalent.
- Tier 2 (verified): up to USD 10,000 / day equivalent.
- Tier 3 (enhanced): up to USD 50,000 / day equivalent — requires source-of-funds.
3. Enhanced Due Diligence (EDD)
EDD is applied to PEPs, high-risk jurisdictions and unusual transaction patterns, in accordance with the FIC's Risk Management and Compliance Programme requirements.
4. Ongoing monitoring
All trades are subject to automated and manual monitoring for structuring, layering, mismatched counterparties, sanctions matches and other red flags. We may pause withdrawals, request additional documentation or close an account.
5. Reporting
We file Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs), Cash Threshold Reports (CTRs ≥ ZAR 49,999.99) and Terrorist Property Reports (TPRs) with the Financial Intelligence Centre as required by FICA. By law, we may not tip off the subject of a report.
6. Sanctions
We screen all users against the United Nations Security Council, the South African Targeted Financial Sanctions list and other applicable lists. We do not service users in or from comprehensively sanctioned jurisdictions.
7. Record-keeping
CDD, transaction and communication records are retained for at least 5 years from the end of the business relationship (FICA s.42–43).
8. Training & governance
Staff receive AML/CTF training at induction and annually thereafter. The Money-Laundering Reporting Officer (MLRO) reports to the Board.
9. Contact
MLRO: mlro@espees.exchange.