How we guard against money laundering and terrorist financing, and the identity checks we carry out, in line with the Financial Intelligence Centre Act (FICA). This is a client-facing summary; our full internal AML/CTF programme is available to regulators and auditors on request.
Makeba Markets (Pty) Ltd (FSP 53160) is an "accountable institution" for the purposes of the Financial Intelligence Centre Act 38 of 2001 ("FICA"), and is committed to preventing the use of its services for money laundering, terrorist financing, or proliferation financing. This document summarises the Company's approach for the benefit of Clients.
The Company applies a risk-based approach to client due diligence, transaction monitoring, and ongoing review, calibrated according to factors including the Client's jurisdiction, product usage, transaction patterns, and source of funds.
Before onboarding a Client, the Company verifies the Client's identity, residential address, and, where relevant, the identity of beneficial owners, using reliable, independent documentation or electronic verification sources. Typically we require:
Where the Client is a legal entity, the Company additionally requires constitutional documents (such as a certificate of incorporation and memorandum of incorporation), a register or confirmation of directors and beneficial owners, and identification and verification documents for all beneficial owners holding, directly or indirectly, the threshold ownership or control interest prescribed under FICA.
Enhanced due diligence is applied to higher-risk Clients, including politically exposed persons, Clients from higher-risk jurisdictions, and Clients exhibiting unusual transaction patterns, in accordance with our PEP and Sanctions Screening Statement. This may include additional source-of-wealth verification and senior management approval before establishing the relationship.
The Company monitors Client transactions and account activity on an ongoing basis for patterns inconsistent with the Client's known profile or that may indicate money laundering, terrorist financing, or other financial crime, and refreshes Client due diligence information periodically or upon a material change in risk.
The Company retains client due diligence records and transaction records for a minimum of five years following termination of the business relationship, or longer where required by Applicable Regulations.
Where the Company identifies a transaction or activity giving rise to knowledge or suspicion of money laundering or terrorist financing, it is legally obliged to report the matter to the Financial Intelligence Centre, and may be prohibited from disclosing that a report has been made.
The Company does not open or maintain anonymous accounts, accounts in fictitious names, or accounts for the benefit of undisclosed third parties.
The Company will not activate trading functionality, and may restrict deposits or withdrawals, until the required verification documentation has been received and approved. The Company reserves the right to decline an application or close an Account where satisfactory verification cannot be completed.
Employees and representatives receive regular AML/CTF training appropriate to their role, and the Company's compliance function oversees the implementation and effectiveness of this Policy. Questions may be sent to info@makebamarkets.com.