Anti-Money Laundering Policy

Last updated: June 2026

1. Overview

Swiffy (Pty) Ltd ("Swiffy") is committed to the highest standards of Anti-Money Laundering (AML) compliance and the prevention of terrorist financing. This policy sets out our obligations and procedures to detect, prevent and report money laundering and terrorist financing activities.

Our AML policy means preventing the use of Swiffy's services by criminals, with the aim of money laundering, terrorist financing or any other criminal activity.

2. Scope

This policy applies to all employees, contractors, directors, and third parties acting on behalf of Swiffy. It covers all services offered by Swiffy, including payment processing, fund transfers, and related financial services.

3. Core Principles

3.1 No-Cash Policy

Swiffy neither accepts nor pays cash under any circumstances. All transactions are conducted through verifiable electronic payment channels to maintain full traceability of funds.

3.2 Know Your Customer (KYC)

All clients must complete identity verification procedures before engaging with Swiffy's services. We apply enhanced scrutiny to customers from jurisdictions identified as having inadequate AML standards or elevated financial crime risk.

3.3 Account Monitoring

Swiffy reserves the right to restrict, suspend or terminate accounts where there is reasonable suspicion of illegal activity, money laundering or terrorist financing. Such decisions are made based on staff assessment, automated monitoring and transaction analysis.

4. Compliance Procedures

Swiffy implements three primary AML mechanisms:

• Know Your Customer (KYC) and due diligence verification — identity documents, proof of address and source of funds documentation is collected and verified for all clients.
• Ongoing transaction monitoring — automated systems monitor client activity for suspicious patterns, unusual volumes, structuring, and other red flags.
• Comprehensive record keeping — all transaction records and customer verification documents are retained in accordance with applicable South African law and FICA requirements.

5. Customer Verification

Swiffy performs customer due diligence (CDD) on all clients before onboarding and at regular intervals thereafter. Enhanced due diligence (EDD) is applied where elevated risk is identified, including:

• Customers or beneficial owners from high-risk jurisdictions
• Politically Exposed Persons (PEPs) and their associates
• Transactions above prescribed thresholds
• Complex or unusual transaction structures

6. Reporting Obligations

Swiffy complies with all reporting obligations under the Financial Intelligence Centre Act (FICA) and other applicable South African legislation. Suspicious transactions are reported to the Financial Intelligence Centre (FIC) in accordance with legal requirements. Tipping off clients about such reports is strictly prohibited.

7. Staff Training

All Swiffy staff who handle financial transactions or customer onboarding are trained in AML obligations, red flag recognition, and internal reporting procedures. Training is conducted at induction and refreshed annually.

8. Sanctions Screening

Swiffy screens all clients and transactions against relevant sanctions lists, including those published by the United Nations, OFAC, and local South African regulators. Transactions involving sanctioned parties are blocked and reported.

9. Governance

Ultimate responsibility for AML compliance rests with the Board of Directors of Swiffy (Pty) Ltd. A designated compliance officer is responsible for the day-to-day implementation and oversight of this policy.

10. Policy Review

This policy is reviewed at least annually and updated as required to reflect changes in legislation, regulatory guidance, and business operations.

11. Contact

For queries relating to this policy, please contact us at compliance@swiffy.co.za.