African Community Fund

KYC/AML Compliance Directive

Directive No.: ACF-DIR-005 | Effective Date: 04/05/2026 | Version: 1.0

PREAMBLE

WHEREAS the African Community Fund (the "Fund") operates as an international institution with full juridical personality under Article 2.1 of its Charter;

WHEREAS Article 7.4 requires a good faith declaration regarding the source of funds or gold for share subscription, consistent with applicable Know Your Customer (KYC) protocols;

WHEREAS Article 10.1(b) mandates that the Executive Committee establish policies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations;

WHEREAS Article 14.2(c) entrusts the Executive Committee with ensuring compliance with the Charter and applicable international standards;

WHEREAS Article 5.3 requires all Members to act in good faith and adhere to the Fund's principles of operational integrity, long-term value creation, and responsible stewardship;

WHEREAS Article 13.5 authorizes the Chair to adopt directives consistent with the Charter to implement the Fund's mission;

NOW THEREFORE, the Chair hereby issues this KYC/AML Compliance Directive to establish minimum standards for customer due diligence, sanctions screening, transaction monitoring, and reporting across the Fund's ecosystem.

ARTICLE 1: PURPOSE AND SCOPE

1.1 Purpose: This Directive establishes a risk-based framework to prevent the Fund from being used for money laundering, terrorist financing, tax evasion, sanctions evasion, or other illicit financial activities.

1.2 Applicability: This Directive applies to:

  • (a) All Class A (Governance) and Class B (Non-Governance) Members;
  • (b) Beneficial owners, authorized signatories, proxies, and controlling persons;
  • (c) Intermediaries, paying agents, custodians, and technical integrators accessing Fund systems;
  • (d) All share subscriptions, transfers, capital calls, loan applications, withdrawals, and gold/currency transactions.

1.3 International Alignment: Standards herein align with Financial Action Task Force (FATF) Recommendations, relevant UN conventions, and internationally recognized banking compliance frameworks.

ARTICLE 2: RISK-BASED APPROACH

2.1 Risk Classification: All Members and transactions shall be assigned a risk rating (Low, Medium, High) based on:

  • (a) Jurisdiction of incorporation and operational footprint;
  • (b) Entity type (sovereign, financial institution, corporate, NGO, individual investor);
  • (c) Transaction volume, frequency, and payment method (gold vs. fiat);
  • (d) Presence of Politically Exposed Persons (PEPs) or complex ownership structures.

2.2 Proportionality: Customer Due Diligence (CDD) measures shall be proportionate to the assessed risk level. Enhanced Due Diligence (EDD) shall apply to High-risk relationships.

2.3 Methodology Approval: The Executive Committee shall approve and periodically update the risk classification matrix and scoring methodology.

ARTICLE 3: ONBOARDING AND INITIAL VERIFICATION

3.1 Good Faith Declaration: All applicants must execute a Source of Funds/Gold Declaration consistent with Article 7.4, certifying lawful origin and compliance with applicable AML/CTF laws.

3.2 Entity Verification:

  • (a) Certified certificate of incorporation/registration;
  • (b) Memorandum & Articles of Association or equivalent constitutional documents;
  • (c) Proof of physical address and operational jurisdiction.

3.3 Beneficial Ownership Identification:

  • (a) Identification of all natural persons holding ≥25% direct/indirect ownership or exercising effective control;
  • (b) Where ownership is opaque, the controlling officer(s) must be identified and verified.

3.4 Authorized Signatory Verification:

  • (a) Government-issued photo identification;
  • (b) Board resolution or authorization letter confirming signatory mandate;
  • (c) Digital identity verification via the ACF Certificate Authority (ACF-DIR-002).

3.5 Gold Subscription Verification: Payments in gold shall be accompanied by assay certificates, chain-of-custody documentation, and independent valuer confirmation per Article 7.3.

ARTICLE 4: ONGOING MONITORING AND ENHANCED DUE DILIGENCE

4.1 Transaction Monitoring: The Fund shall employ automated and manual monitoring to detect:

  • (a) Unusual transfer patterns or rapid share movements inconsistent with stated purpose;
  • (b) Structuring to avoid reporting thresholds;
  • (c) Discrepancies between declared source of wealth and transaction volume.

4.2 Periodic Review Cycles:

  • (a) High-Risk: Annual review with EDD refresh
  • (b) Medium-Risk: Biennial review
  • (c) Low-Risk: Triennial review

4.3 Enhanced Due Diligence (EDD) Triggers:

  • (a) PEP status (domestic, foreign, or international organization);
  • (b) Operations in high-risk or non-cooperative jurisdictions per FATF grey/black lists;
  • (c) Complex, layered ownership or use of nominee structures;
  • (d) Large-scale gold subscriptions or cross-border transfers exceeding $5M USD equivalent.

4.4 EDD Requirements: Senior management approval, independent intelligence gathering, deeper source of wealth/origin of funds documentation, and ongoing transactional scrutiny.

ARTICLE 5: SANCTIONS SCREENING AND PROHIBITED ACTIVITIES

5.1 Real-Time Screening: All Members, beneficial owners, signatories, and counterparties shall be screened against:

  • (a) UN Security Council Consolidated List
  • (b) OFAC SDN and Sectoral Sanctions Lists
  • (c) EU Consolidated Financial Sanctions List
  • (d) UK HMT Sanctions List
  • (e) African Union and regional sanctions frameworks

5.2 Prohibited Activities: The Fund shall not engage in transactions involving:

  • (a) Sanctioned individuals, entities, or jurisdictions;
  • (b) Terrorist financing or proliferation networks;
  • (c) Proceeds of corruption, fraud, or organized crime;
  • (d) Activities violating international humanitarian law.

5.3 Compliance Hold & Suspension: Upon detection of a sanctions match or credible suspicion, the Executive Committee may temporarily freeze share transfers, suspend economic distributions, and restrict system access pending investigation, consistent with Article 10.5 and Article 14.2.

ARTICLE 6: REPORTING AND WHISTLEBLOWER INTEGRATION

6.1 Internal Reporting: Fund staff, compliance officers, and appointed agents must file internal Suspicious Activity Reports (SARs) to the Fund Compliance Officer within 24 hours of detection.

6.2 Whistleblower Channels: Secure, confidential reporting mechanisms shall be maintained for Members, employees, and third parties to report suspected Charter or AML violations. Reports shall be reviewed by the Executive Committee and, where appropriate, escalated to independent auditors.

6.3 External Reporting: Where required by supplementary agreements or host jurisdiction law, the Fund may file regulatory reports without waiving core immunities under Chapter V, unless expressly authorized by the Executive Committee per Article 22.

6.4 Non-Retaliation: The Fund prohibits retaliation against any person who reports suspicious activity in good faith.

ARTICLE 7: RECORD KEEPING AND DATA PROTECTION

7.1 Retention Period: KYC/AML records, transaction logs, screening results, and SAR documentation shall be retained for a minimum of seven (7) years following the termination of the Member relationship or conclusion of the relevant transaction.

7.2 Secure Storage: Records shall be stored in encrypted, access-controlled systems integrated with the Digital Share Registry (ACF-DIR-004) and compliance vaults.

7.3 Data Privacy: Personal data shall be processed in accordance with international data protection principles. Cross-border data flows are protected by Chapter V immunities (Articles 18-22), though Members remain responsible for domestic regulatory compliance when accessing Fund systems.

7.4 Member Obligation: Members must promptly update KYC information upon material changes. Failure to maintain current documentation may result in suspension of transfer rights or economic distributions per Article 8.4 of the Charter.

ARTICLE 8: GOVERNANCE, TRAINING, AND ACCOUNTABILITY

8.1 Compliance Function: The Executive Committee shall appoint a Chief Compliance Officer (CCO) responsible for implementing this Directive, managing screening systems, and reporting on AML/CTF program effectiveness.

8.2 Training: Mandatory annual AML/CTF training shall be provided to all Fund staff, Executive Committee members, external auditors, and technical partners. Members are encouraged to train their authorized signatories on KYC obligations.

8.3 Accountability: Willful or negligent violation of this Directive may result in:

  • (a) Restriction of Digital Share Registry access;
  • (b) Delay or rejection of share transfers, loan applications, or withdrawals;
  • (c) Referral to the Executive Committee for membership review or forfeiture proceedings under Article 10.3.

ARTICLE 9: AUDIT AND DIRECTIVE REVIEW

9.1 Independent Audit: The AML/CTF program shall undergo annual review by external auditors of recognized international standing, with findings reported to the Executive Committee.

9.2 Penetration & Process Testing: Biennial independent testing of screening algorithms, alert triage, and SAR escalation workflows shall be conducted.

9.3 Directive Review: This Directive shall be reviewed biennially by the Executive Committee to incorporate FATF guidance updates, technological advancements, and operational feedback. Amendments shall be published on the Fund's official website.

ARTICLE 10: ENTRY INTO FORCE AND LANGUAGES

10.1 Entry into Force: This Directive enters into force upon signature by the Chair and publication on the Fund's official website.

10.2 Supremacy: In case of conflict between this Directive and the Charter, the Charter shall prevail.

10.3 Languages: In accordance with Article 28.1, this Directive is authentic in English, French, Portuguese, and Arabic. In case of discrepancy, the English text shall prevail for technical and compliance specifications.

SCHEDULE A: RISK CLASSIFICATION MATRIX (SUMMARY)

Risk Tier Jurisdiction Entity Type PEP Exposure Review Cycle
Low FATF-compliant, transparent regulatory regime Publicly listed banks, sovereign wealth funds None 3 years
Medium Developing financial systems, moderate transparency Private banks, corporates, NGOs Domestic PEPs 2 years
High FATF grey/black list, offshore secrecy, conflict zones Private investment vehicles, trusts, shell structures Foreign/International PEPs 1 year + EDD

SCHEDULE B: REQUIRED DOCUMENTATION BY ENTITY TYPE

Document Sovereign Central Bank Commercial Bank Corporate/NGO Individual Investor
Certificate of Registration N/A ✓ ✓ ✓ Government ID/Passport
Constitutional/Charter Docs ✓ ✓ ✓ ✓ N/A
Board Resolution (Signatory) ✓ ✓ ✓ ✓ N/A
UBO Register / Ownership Chart N/A N/A ✓ ✓ Declaration of Control
Source of Wealth/Funds Declaration ✓ ✓ ✓ ✓ ✓
Gold Assay & Chain of Custody If applicable If applicable If applicable If applicable If applicable

SCHEDULE C: COMPLIANCE CONTACTS & REPORTING CHANNELS

Function Contact Purpose
KYC Onboarding Support [email protected] Document submission, verification status, corrections
Sanctions Screening Alerts [email protected] Match resolution, freeze notifications, clearance
Whistleblower & Ethics Portal [email protected] Secure, anonymous reporting of suspected violations
Audit & Program Review [email protected] Independent testing, annual audit coordination

Adopted by the Chair of the African Community Fund on 04/05/2026.
Shared Value, Shared Prosperity.

Digital Signature md5-vdTTLjNEZX/+WaKN+X4Orw==
Verify digital signature
©2026 African Community Fund
africancommunityfund.com