Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

  • Introduction
  • Purpose
  • Scope
  • Key Policy Components
  • Client Responsibilities
  • Consequences of Non-Compliance
  • Training & Governance
  • Record-Keeping
  • Updates & Contact

1. Introduction

At Prima OTC Market, we are committed to maintaining the highest standards of integrity, transparency, and security. Our AML and KYC policies protect our clients, our platform, and the broader financial system by preventing money laundering, terrorist financing, and fraud.

2. Purpose

This Policy aims to:

  • Prevent Illicit Activity: Identify, deter, and report money laundering, terrorist financing, and other financial crimes.
  • Ensure Regulatory Compliance: Adhere to Ghana’s Anti-Money Laundering Act, 2020, and applicable international standards (FATF, Egmont Group).

Safeguard Stakeholders: Verify user identities and monitor transactions to protect both clients and the Prima OTC Market community.

3. Scope

This Policy applies to:

  • All Clients: Individual and corporate users of Prima OTC Market’s services.
  • Personnel: Employees, agents, and representatives involved in client onboarding and transaction processing.
  • Transactions: Every fiat and cryptocurrency transfer executed on our platform.

4. Key Policy Components

4.1 Customer Identification & Verification (KYC)

We employ a risk-based approach to verify every client before onboarding:

  • Individual Clients: Full legal name, date of birth, nationality, residential address, and contact information. Government-issued photo ID (Ghana Card, passport, or driver’s license) plus a recent proof of address.
  • Corporate Clients: Certificate of incorporation, Tax Identification Number (TIN), and official documentation for Ultimate Beneficial Owners (UBOs).
  • Enhanced Due Diligence: For high-risk profiles or large-value transactions, we perform deeper background checks, including adverse media screening and source-of-fund analysis.

4.2 Transaction Monitoring (KYT)

We continuously surveil transactional activity to detect and escalate anomalies:

  • Threshold Alerts: Transactions exceeding predefined value limits.
  • Pattern Analysis: Uncharacteristic trading behaviours compared to a client’s historical profile.
  • Jurisdictional Risk: Transfers involving high-risk countries or sanctioned entities.

4.3 Sanctions & Watchlist Screening

Every client and transaction is automatically screened in real time against leading global lists, including:

  • United Nations Security Council Sanctions
  • U.S. Office of Foreign Assets Control (OFAC)
  • U.K. HM Treasury (HMT)
  • Other relevant national and international sanctions databases

4.4 Suspicious Activity Reporting (SAR)

Our dedicated compliance team investigates flags and, when warranted, submits Suspicious Transaction Reports (STRs) promptly to the Financial Intelligence Centre (FIC) or other competent authorities.

5. Client Responsibilities

Clients must:

  • Provide accurate, complete, and up-to-date information.
  • Use the platform solely for lawful purposes.
  • Report any suspicious behaviour or potential breaches to our Compliance Desk.

6. Consequences of Non-Compliance

Failure to comply may result in:

  • Account Restriction: Temporary suspension pending investigation.
  • Account Termination: Permanent closure for serious breaches.
  • Regulatory Escalation: Notification to enforcement agencies and potential legal action.

7. Training & Governance

  • Ongoing Training: All staff undergo regular AML/CFT and sanctions-screening sessions.
  • Policy Reviews: We update procedures in response to regulatory changes and best practices.
  • Independent Audits: Periodic internal and external audits ensure the effectiveness of our controls.

8. Record-Keeping

We retain all relevant documentation for a minimum of six years, including:

  • Client identity verification records
  • Transaction logs and monitoring reports
  • Suspicious transaction investigation files and STR submissions

9. Updates & Contact

Prima OTC Market reserves the right to amend this Policy as regulations evolve. Material changes will be communicated to all clients. For questions or concerns, please contact our Compliance Team at compliance@primaotcmarket.com.

By using our services, you acknowledge that you have read, understood, and agree to abide by this AML & KYC Policy.