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AML / CFT / KYC / BC-FT Policy

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)

Contents

  1. Purpose and BC/FT - AML/CFT framework
  2. Definitions
  3. Standards and references
  4. African geographic coverage
  5. Scope
  6. Crypto-to-fiat operating model
  7. Compliance governance
  8. Risk-based approach (RBA)
  9. KYC / CDD / EDD procedure
  10. Limits and thresholds
  11. Anti-money laundering (AML / BC)
  12. Combating the financing of terrorism (CFT / FT)
  13. Transaction monitoring
  14. Internal manual review triggers
  15. Continuous monitoring improvement
  16. Sanctions, embargoes and PEPs
  17. Alerts, holds, SAR / suspicious activity reporting
  18. Data retention and traceability
  19. Training and awareness
  20. Prohibited activities
  21. Policy updates
  22. Document approval & sign-off

1. Purpose and BC/FT - AML/CFT framework

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.

2. Definitions

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.

3. Standards and references

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.

3 bis. African geographic coverage

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.

Zones and countries (non-exhaustive examples)

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

Local / regional authorities and references (by corridor)

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.

4. Scope

This policy applies to:

5. Crypto-to-fiat operating model

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.

Typical sell flow (crypto to local currency)

  1. The user creates a sell order and provides payout details (e.g. Mobile Money number).
  2. The crypto payment is processed via a crypto PSP (e.g. NOWPayments): invoice/address, on-chain detection, confirmation.
  3. Syli Change receives confirmation (webhook / status) and records the order, amount, rate and compliance metadata.
  4. The local payout is executed via an aggregator or Mobile Money channel (e.g. PawaPay or manual processing depending on the corridor), after applicable internal controls.
  5. The user receives funds; history remains available in the account and admin console.

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.

6. Compliance governance

6.1 Principles

6.2 MLRO / Compliance Officer (BC-FT)

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).

6.3 Compliance contact

BC/FT questions, internal escalations or authority requests: [email protected] — subject Compliance / AML-CFT / BC-FT (attention: Emmanuel MAVIRI, Compliance Officer / MLRO).

7. Risk-based approach (RBA)

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):

8. KYC / CDD / EDD procedure

8.1 Data at registration

8.1 bis Email domain screening at registration

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.

  1. Recognised mainstream provider (Gmail, Outlook, Yahoo, iCloud, Proton, national operators, etc.): registration allowed, with no external lookup.
  2. Internal suspicious domain register: the exact domain, its parent zone and its extension are checked against an internal list covering known disposable email services, extensions massively used for phishing, and higher-risk geographic zones. Any match results in refusal of account creation.
  3. Unknown domain: reputation analysis through a specialised provider (Abstract API). The signals used are the disposable nature of the address, the risk level of the domain and of the address, domain age, validity of MX records and format consistency.
  4. Adverse verdict: account refused and the domain added to the internal register, so that any later attempt is rejected without a further external lookup.
  5. Favourable verdict: registration allowed and the verdict cached for a configurable period.

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).

8.2 When verification is required

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.

8.3 Documents and identity verification (Didit)

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.

8.4 Statuses and customer risk classification

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

8.5 Review and target timelines

8.6 Enhanced due diligence (EDD)

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.

9. Limits and thresholds

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

10. Anti-money laundering (AML / BC)

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.

11. Combating the financing of terrorism (CFT / FT)

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.

11.1 CFT commitments

11.2 FT / CFT risk indicators (examples)

11.3 AML vs CFT distinction

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

12. Transaction monitoring (current framework)

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).

12.1 Systemic controls

12.2 Manual controls (AML and CFT)

12.3 Independence from the PSP

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.

12 bis. Internal manual review triggers

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.

13. Continuous monitoring improvement

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.

14. Sanctions, embargoes and PEPs

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).

15. Alerts, holds, SAR / suspicious activity reporting

15.1 Measures

15.2 Cooperation and reporting

Staff must not tip off the customer about the existence of a suspicious activity report where tipping-off prohibitions apply.

16. Data retention and traceability

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).

17. Training and awareness

18. Prohibited activities

It is strictly prohibited to use Syli Change for:

19. Policy updates

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.

20. Document approval & sign-off

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DOCUMENT APPROVAL & SIGN-OFF
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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


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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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