Anti-Money Laundering (AML) Policy for Irugoo

We are deeply committed to maintaining a transparent, safe, and compliant platform for all business activities. As a travel and hospitality marketplace, we understand the critical importance of protecting our platform from illegal activities, particularly money laundering and terrorism financing. Our Anti-Money Laundering (AML) Policy is designed to ensure that all users and business owners comply with national and international laws while fostering a secure and trusted environment for everyone.

1. Purpose and Objectives

The purpose of this AML Policy is to establish clear guidelines and procedures for identifying, preventing, and reporting potential money laundering activities. Our goal is to:

Prevent the use of Irugoo for laundering proceeds from criminal activities.
Ensure compliance with Rwanda’s laws and international regulations.
Promote transparency within all transactions carried out on our platform.
Protect the integrity of Irugoo and its users from being used as a vehicle for financial crime.

2. Scope

This policy applies to:

All users (travelers, customers, or anyone making transactions on the platform).
All business owners listing services such as stays, dining, car rentals, and attractions on Irugoo.
Irugoo’s employees, partners, and third-party service providers involved in handling transactions, compliance, and payments.

3. Legal Framework

Irugoo adheres to the anti-money laundering regulations set by:

Rwanda’s Financial Intelligence Center and related laws governing financial crime.
International standards such as those set by the Financial Action Task Force (FATF).
Anti-Terrorism Financing Laws that prohibit using funds for terrorist activities.

4. Know Your Customer (KYC) and Customer Due Diligence (CDD)

Our KYC and CDD processes are designed to ensure that all users and business owners are fully verified before engaging in any financial transactions on Irugoo.

KYC for Users:

Identification Documents: Every user must provide valid, government-issued identification (such as a passport or national ID) to verify their identity.
Phone & Email Verification: We verify the contact details of users to ensure their authenticity.
Payment Method Verification: Users must use verified and legitimate payment methods when making transactions.

KYC for Business Owners:

Business Registration: All business owners must submit valid business registration documents, tax identification numbers, and necessary operating licenses.
Identity Verification: The business owner or a key representative must provide valid identification.
Financial Information: Businesses may be asked to provide financial documentation to ensure they are operating legitimately.

Enhanced Due Diligence (EDD):

For high-risk users or businesses, Irugoo will perform Enhanced Due Diligence (EDD). This involves collecting additional information to assess the legitimacy of a user or business. High-risk profiles include:

Businesses from higher-risk regions or industries.
Users engaging in unusually large transactions or exhibiting suspicious activity.
Businesses that receive numerous complaints or poor reviews.

5. Transaction Monitoring

We continuously monitor transactions on the platform to detect and prevent suspicious activity. This includes:

Real-time tracking of transaction size, frequency, and location to flag unusual patterns.
Geographical Risk: Monitoring transactions from or to countries considered high-risk for money laundering or terrorism financing.
Payment Screening: All payments are processed through secure channels, ensuring they meet regulatory standards.

If suspicious activities are detected, we may:

Pause or block transactions for further review.
Request additional verification from the user or business involved.
Escalate the issue to relevant authorities in compliance with the law.

6. Red Flags for Money Laundering

The following are examples of behaviors that may indicate potential money laundering:

Multiple small transactions to avoid detection.
Inconsistent booking behavior or transactions that do not match typical customer or business patterns.
Use of anonymous or suspicious payment methods (e.g., third-party payments or cryptocurrency without clear identification).
Sudden changes in business or user profiles without valid reasons.
Bookings made from high-risk countries or by users who seem unrelated to the region they are booking.

7. Reporting Obligations

In accordance with Rwandan law, Irugoo is obligated to report any suspected money laundering or terrorism financing activity to relevant authorities. The following procedures are in place to ensure proper reporting:

Internal Reporting: Any Irugoo employee who detects suspicious activity must report it immediately to our compliance team.
Suspicious Activity Reports (SARs): Our compliance team will file a SAR with the relevant financial authority if we identify or suspect money laundering.
Record-Keeping: We maintain detailed records of transactions, user identification, and suspicious activity reports for at least five years.

8. Employee Training and Responsibilities

Irugoo staff are trained on AML best practices and are responsible for:

Recognizing suspicious activity and reporting it to the compliance team.
Implementing KYC and CDD procedures as part of onboarding new users and business owners.
Maintaining confidentiality while complying with legal obligations to report suspicious activities.

9. Penalties for Non-Compliance

Failure to comply with this AML policy may result in:

Suspension or termination of a user or business account.
Legal action if involvement in illegal activity is confirmed.
Reputational damage for any business found to be complicit in fraudulent transactions.

10. Protection and Security Measures

To ensure that our AML policy is effectively enforced, Irugoo employs the following security measures:

Data Encryption: All sensitive information, including financial and identification details, is encrypted and stored securely.
Secure Payment Gateways: All transactions are processed through secure, verified payment methods to prevent unauthorized access or tampering.
Access Control: Only authorized personnel within Irugoo have access to sensitive data, ensuring privacy and confidentiality.

11. Regular Policy Review

Our AML policy is reviewed regularly to ensure it remains effective and up-to-date with the latest regulations and industry standards. Irugoo reserves the right to modify the policy as needed to address emerging risks or regulatory changes.

By maintaining strict AML procedures, Irugoo aims to foster a safe, transparent, and trustworthy marketplace for all. We are committed to complying with legal obligations while also ensuring the security of our business partners and customers. Together, we can protect our community from financial crime and uphold the integrity of the platform.

For further information or questions regarding this AML policy, please contact us at compliance@irugoo.com.