SYLIPAY TECH SARLU — Operator of the Syli Change platform
Version 3.0 - September 2026
Langue : Francais
Legal entity: SYLIPAY TECH SARLU
Legal representative: Aliou Bah (Founder & Managing Director)
Registered office: Lambanyi Wareah, Conakry, Guinea
Compliance Officer / MLRO: Emmanuel MAVIRI — [email protected] (subject: Compliance / AML-CFT / BC-FT)
Platform / URLs: https://sylichange.com (operated by SYLIPAY TECH SARLU; https://sylipay.app)
This policy sets out SYLIPAY TECH SARLU's framework for combating money laundering and the financing of terrorism (BC/FT), also known internationally as AML/CFT (Anti-Money Laundering / Combating the Financing of Terrorism) and in French as LBC-FT.
SYLIPAY TECH SARLU, operator of Syli Change (https://sylichange.com), is committed to preventing, detecting and addressing risks related to:
Syli Change enables individuals to buy and sell cryptocurrencies in local currencies via Mobile Money and other local methods across several African countries (and certain non-African corridors when available), including Guinea, The Gambia, DRC, the UEMOA zone, the CEMAC zone, Sierra Leone, Ghana, Liberia, Angola and other markets offered in the application (currencies: GNF, XOF, XAF, CDF, GMD, LRD, AOA, SLE, GHS, AED and others depending on the corridor).
SYLIPAY TECH is a non-custodial technology operator. This policy describes an internal BC/FT compliance framework; it does not constitute a banking licence, an e-money institution licence, or an investment service.
| Term | Meaning |
|---|---|
| BC / Money laundering | Process of concealing the illicit origin of funds to reintegrate them into the legitimate economy. |
| FT / Terrorist financing | Providing or collecting funds, by any means, with the intention that they be used, or in the knowledge that they will be used, in full or in part, to prepare, facilitate or commit a terrorist act, or to support a terrorist organisation / person. |
| AML | Anti-Money Laundering controls and programmes. |
| CFT | Combating the Financing of Terrorism controls and programmes. |
| BC/FT or LBC-FT | Combined money-laundering and terrorist-financing framework (French equivalent of AML/CFT). |
| KYC | Know Your Customer - customer identification and verification. |
| CDD / EDD | Customer Due Diligence / Enhanced Due Diligence. |
| MLRO | Money Laundering Reporting Officer - officer responsible for BC/FT reporting and oversight. |
| PEP | Politically Exposed Person. |
| SAR | Suspicious Activity Report to competent authorities. |
| RBA | Risk-Based Approach. |
SYLIPAY TECH aligns, to the extent applicable to its non-custodial model and operating corridors, with principles drawn notably from:
This policy is not legal advice. It describes SYLIPAY TECH SARLU's internal framework and may be supplemented by operational procedures (SOPs) shared with partners upon legitimate request.
SYLIPAY TECH SARLU's registered office is in Guinea (Lambanyi Wareah, Conakry). The Syli Change platform (https://sylichange.com) is designed for users and corridors across several African countries. The list of available countries and currencies is the one displayed in the application and may evolve.
| Zone / country | Examples | Currencies / notes |
|---|---|---|
| Guinea | Republic of Guinea | GNF — monetary authority of reference: BCRG (Banque Centrale de la Republique de Guinee) |
| The Gambia | Gambia | GMD |
| DRC | Democratic Republic of the Congo | CDF |
| UEMOA zone | Senegal, Cote d'Ivoire, Mali, Benin, Togo, Burkina Faso, Niger, Guinea-Bissau, etc. | XOF — regional framework associated with the BCEAO |
| CEMAC zone | Cameroon, Congo Brazzaville, Gabon, Chad, Central African Republic, and other member states as available | XAF — regional framework associated with the BEAC (Economic and Monetary Community of Central Africa) |
| West Africa (outside UEMOA) | Sierra Leone, Ghana, Liberia, Mauritania, etc. | SLE, GHS, LRD, MRU — depending on corridors activated in the app |
| Other corridors | Angola and additional markets offered | AOA and other displayed currencies; some non-African corridors (e.g. AED) may be offered occasionally |
SYLIPAY TECH applies country-specific caps, payment formats and controls. Where partner requirements and local law conflict, or applicability is unclear, operations may be refused, limited or suspended. When a SAR is required, it is filed with the FIU / competent cell of the relevant corridor, under MLRO supervision.
This policy applies to:
SYLIPAY TECH operates a non-custodial model: the platform does not hold user funds and acts as a technology facilitator between the user, crypto payment providers and Mobile Money / fiat aggregators.
Role separation (AML/CFT):
Zero tolerance for money laundering, terrorist financing, fraud and illicit funds. Any operation deemed BC/FT-risk may be refused, delayed or cancelled.
In line with sector standards for crypto-to-fiat flows, SYLIPAY TECH SARLU designates a Money Laundering Reporting Officer (MLRO) / Compliance Officer responsible for supervising the BC/FT (AML/CFT) programme, distinct from purely commercial functions.
The Compliance Officer / MLRO function is officially held by Emmanuel MAVIRI.
Emmanuel MAVIRI’s prerogatives include, in particular:
The operations / admin team executes day-to-day controls under this governance framework. High-stakes BC/FT decisions are documented and escalated to the MLRO under internal procedures.
Compliance contact: [email protected] (subject: Compliance / AML-CFT / BC-FT).
BC/FT questions, internal escalations or authority requests: [email protected] — subject Compliance / AML-CFT / BC-FT (attention: Emmanuel MAVIRI, Compliance Officer / MLRO).
In line with FATF / GAFI principles, SYLIPAY TECH SARLU applies a risk-based approach:
Customer due diligence results in a formal customer risk classification into one of three levels: Low, Medium or High. The level of diligence (standard CDD or EDD) and mitigation measures (limits, holds, refusal, information requests) depend on this classification, on transaction-monitoring alerts (sections 12–13) and on EDD cases (section 8.6).
Periodic KYC review frequency (section 8.4):
Before any account is created, the email address domain is automatically assessed in order to reject disposable, temporary, anonymous addresses and addresses associated with phishing or fraud. The control applies both to email / password registration and to registration via Google.
This filter is a fraud and spam prevention control at the entry point. It is in no way a substitute for KYC: an account created with an accepted address remains subject to the full verification procedure described below. If the external provider is unavailable, registration is allowed through (fail open) while the internal register continues to apply, so that a third-party technical incident does not block access to the service.
Activation of the filter, its thresholds and the domain register are administered from the Admin console. Manual additions and removals of domains are logged (section 16).
The cumulative volume allowed without KYC is 0 USD for all countries (section 9). Full KYC verification is therefore required before any operation, unless an explicit technical or operational exception is decided by SYLIPAY TECH SARLU.
KYC onboarding and identity verification are performed through the integrated third-party solution Didit. The verification process includes, as applicable:
In parallel, Didit performs systematic and ongoing screening against international sanctions lists (including UN Sanctions, OFAC SDN, EU Consolidated List and UK OFSI) and Politically Exposed Persons (PEP) databases (see section 14). Positive hits or residual doubt are referred for manual review by Emmanuel MAVIRI (Compliance Officer / MLRO) for hold / escalation / rejection decisions.
| Status | Meaning | Effect |
|---|---|---|
| pending | No complete KYC file submitted | Operations blocked until KYC is approved (0 USD cap) |
| submitted | Documents submitted / Didit verification in progress | Restrictions possible under applicable rules |
| approved | Identity validated; risk rating assigned | Higher limits / verified volumes, subject to risk tier |
| rejected | File refused | Operations restricted; resubmission possible after correction |
Upon successful CDD, each customer is assigned a formal risk rating of Low, Medium or High (section 7). Periodic KYC refresh is mandatory as follows:
| Risk rating | Periodic KYC review |
|---|---|
| High | At least every 6 months |
| Medium | At least every 12 months (1 year) |
| Low | Upon identity-document expiry or material trigger event |
Triggered in particular where there is:
Minimum information / document pack (as applicable):
Decision-maker: Emmanuel MAVIRI (Compliance Officer / MLRO) or a designated delegate under MLRO supervision. Target timeline: 48 to 72 business hours after complete documents are received. Record: requested / received documents, Didit screening outcome, decision (proceed / limit / refuse / hold) and notes retained in the compliance file.
Caps are displayed in the application and configurable by administrators (per country). Reference values at the date of this version:
| Type | Reference value |
|---|---|
| Cumulative volume without KYC - Guinea (GN) | 0 USD (configurable) |
| Cumulative volume without KYC - other countries | 0 USD (configurable; no default per-country override) |
| Per-transaction / corridor limits | As shown in-app and subject to operator / aggregator constraints |
| After approved KYC | Higher limits; partner caps may still apply |
The AML / BC framework aims to detect and prevent use of the platform to recycle illicit funds. Typical indicators (non-exhaustive):
Measures: caps, KYC, manual review, suspension, order refusal, evidence retention, partner / authority cooperation.
The CFT / FT framework is distinct from but complementary to AML. Terrorist financing may involve funds of lawful or unlawful origin; the objective is to prevent Syli Change from being used to collect, transfer or conceal funds for terrorist actors or activities.
| Aspect | AML / BC | CFT / FT |
|---|---|---|
| Primary focus | Illicit origin of funds | Destination / use of funds (terrorism) |
| Amounts | Often large or structured | May be small |
| Response | CDD/EDD, monitoring, SAR | Priority hold, sanctions screening, SAR, urgent cooperation |
SYLIPAY TECH SARLU does not rely solely on a crypto PSP's tools. Platform-owned monitoring combines automated detection and human oversight:
Automated alerts for velocity, volume spikes, and wallet risk; manual review by the Compliance Officer for flagged and large transactions.
Where suspicion of money laundering or terrorist financing arises, a suspicious activity / suspicious transaction report is filed with the competent FIU (CENTIF or equivalent financial intelligence unit) when required by law, under the supervision of Emmanuel MAVIRI (MLRO).
Crypto PSP tools (e.g. NOWPayments) and fiat aggregators (e.g. PawaPay) are complementary layers. They do not replace SYLIPAY TECH SARLU's BC/FT governance: KYC, caps, holds, refusals, Didit screening oversight and regulatory cooperation remain the platform operator's responsibility.
Independently of external provider tools, the following events trigger an internal manual review by the operations / admin team and, where appropriate, escalation to Compliance / MLRO. Decisions are documented (rationale, evidence, outcome).
| Trigger | Who reviews | Typical actions | Traceability |
|---|---|---|---|
| Hitting / exceeding the unverified volume cap (0 USD for all countries — configurable) | System + Operations / Admin | Block further operations beyond residual allowance; require KYC submission | KYC status, volumes, order history |
| KYC file submitted (documents received / Didit) | Operations / Admin; MLRO if Didit hit | Didit review + manual review where required; approve / reject; request resubmission | KYC status, rejection reason if any, timestamp |
| EDD trigger (profile / country / payout mismatch, unusual amounts or frequency, impersonation, scam, third-party funds, BC/FT indicator) | Operations / Admin; escalate to Compliance / MLRO if strong suspicion | Request information / documents; confirmation call if needed; temporary hold; order refusal | Review notes, documents requested / received, decision |
| Rapid order accumulation or high volumes vs history | Operations / Admin | Review account and recent orders; limit / suspend if risk | Order history, suspension decision |
| Mismatch between KYC name / phone / country / Mobile Money beneficiary | Operations / Admin | Hold payout / order; identity check; refuse if unresolved | Payout data, KYC, decision |
| Multiple accounts or suspicious reuse of payment instruments | Operations / Admin; Compliance if wider pattern | Link accounts; hold; close in case of fraud | Account / instrument links, decision |
| Support ticket / dispute alleging fraud, coercion or scam | Support then Operations / Admin | Investigation; hold if needed; awareness / closure as appropriate | Ticket, exchanges, decision |
| Provider request (hold, recall, BC/FT investigation) or authority request | Operations / Admin + Compliance / MLRO | Priority hold; provide evidence; cooperate | Request received, documents sent, decision |
| FT / sanctions / embargo indicator or refusal to justify | Compliance / MLRO (priority) | Hold / refuse / close; SAR if required; no tipping-off | Confidential file, decision, report if any |
| Forged, illegible, expired or inconsistent KYC documents | Operations / Admin | KYC rejection; operation restrictions; resubmission after correction | Rejected status, reason |
Target timelines: KYC review within 24 to 72 business hours under normal conditions; critical incidents (ongoing fraud, data breach, FT suspicion) at immediate priority. Timelines may be extended if information is incomplete.
These triggers are internal to SYLIPAY TECH SARLU. They sit on top of PSP / aggregator controls and do not depend on them to be activated.
SYLIPAY TECH SARLU operates an internal transaction-monitoring capability (Admin console — Compliance alerts), independent of PSP / aggregator controls.
Automated alerts for velocity, volume spikes, and wallet risk; manual review by the Compliance Officer for flagged and large transactions.
Alerts may be cleared, confirmed or escalated with decision notes. Target review timeline: 24 to 48 business hours. Holds, information requests and refusals remain human decisions under the MLRO. Where required by law, suspicious activity is reported to the competent FIU (CENTIF or equivalent).
Steering indicators (KPI / KRI): share of alerts handled within 48 h; age of the open-alert backlog; median KYC review time — reviewed periodically by Emmanuel MAVIRI (Compliance Officer / MLRO).
This policy is updated when the framework changes materially.
KYC onboarding and ongoing customer screening against sanctions and PEP lists are automated and continuous through the integrated third-party solution Didit. Screening covers, in particular:
Positive alerts or residual doubt raised by Didit are subject to mandatory manual review by Emmanuel MAVIRI (Compliance Officer / MLRO) for a documented decision (hold / escalation / rejection / clearance). Staff must not tip off the customer where tipping-off prohibitions apply (section 15).
Staff must not tip off the customer about the existence of a suspicious activity report where tipping-off prohibitions apply.
| Data | Retention |
|---|---|
| Transaction data | 10 years (BC/FT / best practice) |
| KYC documents | 5 years after account closure |
| Connection logs | 1 year |
Personal data processing details: Privacy Policy (French).
It is strictly prohibited to use Syli Change for:
This policy may be updated based on:
The version in force is the one published on this page (date and number in the header).
Objective: a reliable, secure service aligned with competent authorities and users, with a documented and continuously improving AML / CFT / KYC / BC-FT framework.
====================================================================== DOCUMENT APPROVAL & SIGN-OFF ====================================================================== Approved and adopted on behalf of Senior Management & Board: Signature: ___________________________ Name: Aliou Bah Title: Founder & Managing Director Entity: SYLIPAY TECH SARLU Date: September 13, 2026 ---------------------------------------------------------------------- Reviewed and acknowledged by Compliance / MLRO: Signature: ___________________________ Name: Emmanuel MAVIRI Title: Compliance Officer / MLRO Entity: SYLIPAY TECH SARLU Date: September 13, 2026 ======================================================================
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