AML & Financial Crime Policy

This policy sets out the proportionate controls used by Balad Ltd to manage anti-money laundering and financial-crime risks associated with olowo.app.

1. Purpose

This policy sets out Balad Ltd’s approach to preventing Olowo from being used for money laundering, terrorist financing, fraud, sanctions evasion or other financial crime.

The controls are designed to be proportionate to the services provided by Olowo and will be reviewed as the platform, regulatory status or services change.

2. Nature of the service

Olowo is a financial management platform. It does not hold customer money and does not initiate payment transactions. Where customers connect financial accounts or access regulated financial services through Olowo, the relevant regulated service is provided by an authorised third-party provider, such as Finexer.

Olowo will cooperate with its regulated providers and will not represent itself as performing regulated AML functions that remain the responsibility of those providers.

3. Responsibility

The Director has overall responsibility for Risk and Compliance and for ensuring that this policy is maintained and applied.

This includes oversight of financial-crime risks, ensuring appropriate procedures are in place, reviewing material concerns and coordinating escalation to relevant regulated service providers or authorities where required.

A dedicated MLRO will be appointed if required by the nature and regulatory scope of the services provided by the company.

4. Risk-based approach

Olowo will take a proportionate, risk-based approach to financial crime. Relevant risks may include the nature of the customer, the services being used, geographic exposure, unusual activity and information received from regulated service providers.

Controls will be reviewed where new products, services, jurisdictions or material financial-crime risks are introduced.

5. Customer and business verification

Where identity, business or eligibility verification is required for a regulated service, this will normally be undertaken by the relevant regulated provider in accordance with its own legal and regulatory obligations.

Olowo may collect or verify information where necessary for its own legitimate business, contractual or regulatory requirements. Information will not be collected merely to duplicate checks already appropriately performed by a regulated provider unless there is a clear requirement to do so.

6. Suspicious or unusual activity

Olowo does not conduct transaction monitoring as a bank or payment institution. However, suspicious activity, unusual system behaviour, suspected fraud or other financial-crime concerns identified through the platform, Admin Dashboard, system logs, customer support or staff observation will be recorded and reviewed.

Where a concern relates to a service provided by Finexer or another regulated provider, it will be escalated through the appropriate provider channel. The company will cooperate with reasonable requests for information relating to an investigation, subject to applicable law and data-protection requirements.

7. Sanctions and prohibited activity

Olowo will not knowingly facilitate activity that breaches applicable financial sanctions or other financial-crime laws.

Where sanctions screening is required as part of a regulated financial service, responsibility will ordinarily sit with the regulated provider unless otherwise agreed or required. Any sanctions concern identified by Olowo will be escalated for appropriate review.

8. Fraud prevention

Suspected fraud, account misuse, unauthorised access or manipulation of information will be investigated and appropriate steps taken to restrict access, preserve relevant records and escalate the matter where necessary.

Technical controls, access controls, security logging and incident-management procedures support the detection and investigation of potentially fraudulent or unauthorised activity.

9. Escalation and reporting

Financial-crime concerns must be escalated internally to the person responsible for Risk and Compliance. The concern will be documented and assessed to determine the appropriate action.

Where appropriate, the matter may be escalated to Finexer or another regulated provider. Reports to law-enforcement, regulatory or other competent authorities will be made where required by applicable law or regulatory obligations.

Information relating to a suspected investigation will be handled confidentially and will not be disclosed in a manner that could prejudice an investigation or constitute unlawful tipping off.

10. Record keeping

Appropriate records of material financial-crime concerns, reviews, escalations and actions will be maintained for as long as necessary to meet applicable legal, regulatory, contractual and legitimate business requirements.

Access to such records will be restricted to authorised personnel.

11. Staff awareness and training

Relevant staff and developers will receive appropriate awareness of financial-crime risks and their responsibility to escalate suspicious or unusual activity.

Training will be proportionate to the individual’s role and will be refreshed periodically and when material changes to the service or applicable requirements make additional training appropriate.

12. Third-party providers

Olowo relies on regulated third parties for regulated Open Banking and other financial services. The company will seek to work with appropriately authorised providers and maintain clear responsibility boundaries.

Olowo will cooperate with reasonable compliance, AML and financial-crime requirements imposed by its regulated providers and will promptly escalate relevant concerns through agreed channels.

13. Data protection and confidentiality

Personal information processed for AML, fraud prevention or financial-crime purposes will be handled in accordance with applicable data-protection requirements and Olowo’s information-security controls.

Information will be limited to authorised personnel and disclosed externally only where there is an appropriate legal, regulatory or contractual basis.

14. Review and change in regulatory scope

This policy will be reviewed at least annually and whenever there is a material change to Olowo’s services, regulatory position, financial-crime risk profile or relevant legal requirements.

If Olowo begins holding customer funds, initiating payments, or undertaking other activities that materially alter its regulatory responsibilities, its AML framework, governance, staffing and procedures will be reviewed before the relevant service is launched.