Last updated: January 15, 2025
1. Policy Statement
The African Standards, Trade & Investment Accreditation Commission (“ASTIAC”) maintains a zero-tolerance policy towards money laundering, terrorist financing, and all forms of financial crime. This policy outlines our commitment to preventing the misuse of our accreditation services for illicit purposes and our adherence to international anti-money laundering and counter-terrorist financing standards.
2. Regulatory Framework
Our AML/CTF program is designed in alignment with the Financial Action Task Force (FATF) Recommendations, the Basel Committee's principles for sound management of AML risks, the European Union Anti-Money Laundering Directives, and applicable US federal regulations including the Bank Secrecy Act. We monitor evolving regulatory requirements and update our procedures accordingly.
3. Customer Due Diligence
ASTIAC conducts Customer Due Diligence (CDD) on all applicants, which includes:
- Identity verification using government-issued documentation.
- Verification of beneficial ownership for corporate and non-profit applicants.
- Screening against international sanctions lists (OFAC, EU, UN, HM Treasury).
- Politically Exposed Person (PEP) identification and risk assessment.
- Adverse media screening across global news sources.
- Source of funds verification where applicable.
- Country risk assessment based on FATF mutual evaluations and Basel AML Index.
4. Enhanced Due Diligence
Enhanced Due Diligence (EDD) is applied to applicants presenting higher risk factors, including those from jurisdictions identified by FATF as having strategic deficiencies, applicants with complex or opaque ownership structures, applicants with PEP connections, and cases where adverse media findings require further investigation. EDD may include on-site verification, extended background checks, and senior management sign-off.
5. Ongoing Monitoring
Accredited entities are subject to continuous monitoring following certification. This includes periodic re-screening against updated sanctions lists and monitoring for adverse media developments. Material changes in risk profile may trigger an ad hoc review or revocation of accreditation.
6. Suspicious Activity Reporting
ASTIAC staff are trained to identify indicators of suspicious activity. Where reasonable grounds exist to suspect money laundering, terrorist financing, or other financial crime, ASTIAC will file reports with the relevant Financial Intelligence Unit (FIU) and may suspend or revoke accreditation pending investigation. ASTIAC will not inform the applicant of any such filing (“tipping off” prohibition).
7. Record Keeping
All CDD and EDD records, including copies of identification documents, screening results, risk assessments, and decision rationale, are retained for a minimum of five (5) years after the termination of the accreditation relationship, or longer where required by applicable law.
8. Staff Training
All ASTIAC compliance staff undergo mandatory AML/CTF training upon hire and annually thereafter. Training covers identification of suspicious activity, CDD/EDD procedures, sanctions compliance, and regulatory updates. Training records are maintained and subject to internal audit.
9. Governance
The Chief Compliance Officer is responsible for the implementation and oversight of this AML/CTF policy. An independent internal audit of AML/CTF controls is conducted annually. The board of governors receives quarterly reports on compliance program effectiveness, screening volumes, and risk trends.
10. Contact
For questions about this policy or to report concerns, contact our compliance team at accreditation@astiac.org.