Governance

Last updated: 13 September 2026 (aligned with AML policy v3.0)

Legal entity: SYLIPAY TECH SARLU

Legal representative / Management: Aliou Bah (Founder & Managing Director)

Registered office: Lambanyi Wareah, Conakry, Guinea

Compliance Officer / MLRO: Emmanuel MAVIRI

Platform / URLs: https://sylichange.com (operated by SYLIPAY TECH SARLU; https://sylipay.app)

Governance / compliance contact: [email protected] (subject: Compliance / AML-CFT / BC-FT)

This page describes SYLIPAY TECH SARLU's governance for operating Syli Change, with a focus on AML/CFT / BC-FT compliance, segregation of duties and control of risk-sensitive decisions. The platform operates corridors across several African countries (Guinea / BCRG, Gambia, DRC, UEMOA, CEMAC, Sierra Leone, Ghana, etc.); the registered office is in Lambanyi Wareah, Conakry, Guinea.

SYLIPAY TECH SARLU is a non-custodial technology operator. This governance page describes the internal control framework; it is not a regulatory organisation chart for a licensed bank or e-money institution.

1. Accountability structure

Function	Main responsibilities
General management	Strategy, resources, legal accountability of the entity, validation of major policies, arbitration of structural decisions (thresholds, corridors, providers)
Operations / Admin	Daily KYC review, order handling, suspensions, user support, first analysis of operational anomalies
MLRO / Compliance Officer Emmanuel MAVIRI	Oversight of the LBC/FT programme, EDD escalations, SAR filings (CENTIF / FIU), annual internal compliance audits, independence of control, follow-up of sensitive cases
Technology / Security	Platform integrity, access management, technical logs, response to vulnerability reports

2. Segregation of duties (principle)

To the extent compatible with the size of the organisation, SYLIPAY TECH SARLU aims to distinguish:

Commercial / product functions (corridor development and user experience)
Operations functions (execution and case review)
BC/FT compliance functions (oversight, escalation, filings)
Technical functions (security and availability)

When the same person acts at several levels (small organisation), sensitive decisions must remain documented (rationale, date, evidence, outcome) to allow later review.

3. Role of the MLRO / Compliance Officer

Consistent with sector standards for crypto-to-fiat flows, SYLIPAY TECH SARLU designates an MLRO / Compliance Officer responsible for supervising the BC/FT framework (AML and CFT), distinct from purely commercial functions.

The Compliance Officer / MLRO function is officially held by Emmanuel MAVIRI. His prerogatives include, in particular:

Supervision of the LBC/FT (AML/CFT) programme and application of KYC / CDD / EDD policies
Handling of EDD escalations and compliance alerts
Suspicious activity / transaction reporting to the competent FIU (CENTIF or equivalent) when required by law
Annual internal compliance audits
Documentation of sensitive decisions and cooperation with authorities
Internal awareness of AML and CFT risks

The operations / admin team performs daily controls under this framework. High-stakes BC/FT decisions are escalated to Emmanuel MAVIRI under internal procedures. KYC onboarding and continuous sanctions / PEP screening are automated via Didit; positive hits or residual doubt are subject to mandatory MLRO review (hold / escalation / rejection).

4. Compliance alert queue (internal TM)

Triggers from the AML/CFT policy (§12 bis) feed an internal alert queue in the Admin console (“Compliance alerts”), independent of PSP / aggregator controls.

Who reviews: Operations / Admin first line; escalation to MLRO / Compliance for confirmed or escalated cases
Target timeline: 24 to 48 business hours for a first documented decision
Statuses: open → under review → cleared, confirmed or escalated
Notes: a decision note is required to close an alert
Audit trail: review actions are logged (admin actions)

The engine does not auto-block orders: it creates an alert, may flag the transaction (flagged) and notifies ops. Measures (freeze, information request, refusal) remain human decisions, in line with the AML policy §13. Rules and thresholds (velocity, structuring, round-trip, higher-risk corridors, etc.) are documented in policy §13 and in docs/alertes-conformite-tm.md.

Steering KPI / KRI: % of alerts handled within 48 h; age of the open-alert backlog; median KYC review time — tracked via Admin / exports, reviewed periodically by Emmanuel MAVIRI (MLRO). Transaction monitoring summary: Automated alerts for velocity, volume spikes, and wallet risk; manual review by the Compliance Officer for flagged and large transactions.

Operational detail (rules, thresholds, API): internal repository documentation docs/alertes-conformite-tm.md. Sanctions / PEP screening (Didit + MLRO review): docs/sanctions-pep-screening.md.

4 bis. Anti-fraud screening at registration

A preventive control applies upstream of account creation: the email address domain is checked against an internal register of suspicious domains and, if unknown, against an external reputation analysis (Abstract API). The full mechanism is described in the AML policy §8.1 bis.

Who administers: Operations / Admin maintains the register from the Admin console; MLRO / Compliance arbitrates contested cases
Nature of the control: preventive and automatic, it refuses account creation — it does not generate a TM alert and does not apply to existing accounts
Recourse: a legitimate user wrongly rejected may contact support; removing a domain from the register is a documented decision (§5)
Audit trail: manual additions and removals of domains are logged (admin actions)
Continuity: if the reputation provider is unavailable, the internal register continues to apply on its own, without blocking access to the service

This filter does not replace KYC: it limits spam and fraudulent registrations at the entry point, while identity verification remains fully required.

5. Documented compliance decisions

The following decisions must be traceable:

KYC approval / rejection and reasons
Account suspension or closure
Refusal, freeze or cancellation of an order for BC/FT or fraud reasons
Review and closure of TM compliance alerts (decision notes)
Manual addition or removal of an email domain in the registration screening register
EDD requests and responses obtained
Exchanges with payment providers (hold, recall, investigation)
Suspicious activity filings when required (without tipping-off the customer)

6. Role separation with providers

Crypto PSP (e.g. NOWPayments): crypto payment confirmation
Fiat / Mobile Money aggregators: local payment execution per corridor
Email reputation provider (Abstract API): risk signals on unknown domains at registration time
Identity / sanctions provider (Didit): automated KYC (document authenticity, biometrics / liveness) and continuous sanctions / PEP screening
SYLIPAY TECH SARLU: KYC/CDD governance (Didit oversight), caps, BC/FT review, TM alert queue, domain register, decide to proceed / suspend / refuse

A provider's tools do not replace SYLIPAY TECH SARLU's internal governance for Syli Change.

7. Escalation

Support / operations — standard user cases and operational anomalies
Compliance / MLRO (Emmanuel MAVIRI) — BC/FT suspicions, sanctions / PEP hits, serious fraud, EDD, escalated alerts, CENTIF / FIU filings
Management (Aliou Bah) — structural decisions (thresholds, corridor open / close, provider selection)
Competent authorities — on legitimate request or legal obligation

8. Policy review

Published compliance policies (AML/CFT, privacy, these pages) are reviewed when there is a material change in risk, product, corridors or applicable legal framework, and at least when management or the MLRO considers it necessary. The version in force is the one published on the website, with its date. Current AML policy reference: Version 3.0 - September 2026.

9. Related documents

Version francaise