Anti-Money Laundering Statement

Financial crime controls are not something to bolt on once a product is running. CelerCard is being built around them from the start, and every control set out below will be operating before a single customer holds or spends money with us.

CelerCard is in development and not yet open to customers. The service does not currently hold or transmit funds, issue cards or process transactions, and our website collects contact details from people who want to know when we launch.

The service will not open until the authorisations it requires are in place and the controls described below are operating.

Money laundering is the process of making money obtained through crime appear legitimate. Terrorist financing is the funding of terrorist activity, whatever the origin of the money.

A virtual card funded from local payment methods and usable with online merchants worldwide is a product that criminals would like to misuse, because it can turn local value into international spending power quickly. We take that seriously. Preventing this misuse protects our customers, the financial system of The Gambia, and the viability of the business itself.

CelerCard is built to meet the anti-money-laundering and counter-terrorist-financing laws of The Gambia, the requirements of the Central Bank of The Gambia, and the reporting obligations owed to the Gambia Financial Intelligence Unit.

We align our controls with international standards, including the recommendations of the Financial Action Task Force, and with the requirements of the partners through whom our card products are issued.

No customer will hold or spend money with CelerCard until all of the following are in place:

• Customer identity verification. Every customer will be identified and verified using reliable, independent documentation before any card is issued. There will be no anonymous accounts.
• Enhanced checks for higher risk. Additional scrutiny, including source-of-funds enquiries, where a customer or pattern of activity presents higher risk.
• Sanctions and PEP screening. Screening of customers against applicable sanctions lists and for politically exposed persons, both at onboarding and on an ongoing basis.
• Transaction monitoring. Monitoring of activity against expected customer behaviour, with defined thresholds and escalation.
• Suspicious transaction reporting. Prompt reporting of suspicious activity to the Gambia Financial Intelligence Unit, without tipping off the person concerned.
• Record keeping. Retention of identification and transaction records for the period the law requires.
• A named compliance officer. A designated person accountable for the programme, with the authority and independence to escalate concerns.
• Staff training. Training for everyone whose work touches customers or transactions, refreshed regularly.
• Independent review. Periodic testing of the programme by someone other than those who operate it.

When the service launches, opening an account will require valid government-issued identification and other information needed to verify who you are. We may decline an application, or suspend or close an account, where we cannot complete verification or where we have reasonable grounds for concern. Where the law prevents us from explaining why, we will say only that we are unable to proceed.

These obligations apply to everyone. They are not a judgement about any individual customer.

If you believe CelerCard is being used for money laundering, fraud or any other financial crime, tell us at info@celercard.com. Reports are treated confidentially and, where warranted, referred to the appropriate authority.

This is our public statement on financial crime. The programme document behind it — risk assessment, procedures and monitoring thresholds — is independently reviewed and is not published, because operational detail of that kind would assist the people it is designed to stop.

We update this statement as our controls and regulatory position develop.