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TangentoPay
TangentoPay
aml & ctf policy

Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF)
Policy

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Executive Summary & Statutory Authority
The purpose of this Global Anti-Money Laundering Policy (this “Policy”) is to ensure that Tangento Group. and its subsidiaries and affiliates (collectively, the “Company”), as well as all TangentoPay Personnel, comply with all applicable anti-money laundering laws and all laws countering the financing of terrorism in effect in the countries and jurisdictions where the Company conducts business and/or has operations (collectively “Anti-Money Laundering Laws”). Moreover, this Policy is also intended to ensure all Company business activities carried out with Third Parties comply with Anti-Money Laundering Laws. Capitalized terms used but undefined herein have the meanings assigned to them under Section B (Definitions). It is the policy of the Company to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable Anti-Money Laundering Laws. The Company has adopted a zero-tolerance standard with respect to conduct that violates Anti-Money Laundering Laws. As such, the Company seeks to do business only with Third Parties that conduct legitimate activities and that are committed to follow these standards.
This Policy sets out guidelines and mechanisms designed to ensure that all TangentoPay Personnel are well informed and trained to be able to detect, mitigate, prevent and report acts and/or transactions which could involve potentially illegally obtained resources, as well as to promote compliance with applicable Anti-Money Laundering Laws and to avoid possible damages to the integrity, stability and reputation of the Company.
Roles and Responsibilities
The Chief Operations Officer and legal staff have been designated as the “AML Compliance Officers” and shall oversee global compliance with this Policy and applicable Anti-Money Laundering Laws. The AML Compliance Officers are responsible for:
Supervising the implementation of the Policy;
Together with members of the Company's Legal Department, monitoring any changes in applicable laws and any prevalent techniques or cases related to Anti-Money Laundering Laws in order to ensure that the Policy remains effective and updated;
Ensuring that the training given to TangentoPay Personnel is consistent with this Policy; and
Providing to the Audit Committee of the Company's Board of Directors a summary report related to global compliance with this Policy at least once every year.
Definitions
For the purposes of this Policy, the following terms shall have the definitions set forth below:
AML refers to Anti-Money Laundering.
Cash Payment refers to, but is not limited to, remittances of cash (including coins and bank notes) or cash equivalents (including cryptocurrency), as well as payments via cashier's check, teller's check, traveler's check, money order, gift card and/or direct cash deposits, wire transfers or ACH transfers of cash to any Company bank account; notwithstanding this definition, a different definition could be established in accordance with applicable local law, as determined by the AML Compliance Officers.
TangentoPay Personnel refers to the Company's officers, directors, employees, distributors, consultants, agents, contractors, business partners, interns and any other third-party representatives acting on the Company's behalf.
Third Party refers to any of the Company's clients, prospective clients, vendors, prospective vendors, suppliers, prospective suppliers and any other person, entity or organization with whom the Company does or may do business or from whom the Company accepts payments or remuneration.
Ultimate Beneficiar(ies) refers to any entity or person that ultimately owns or controls a Third Party and/or the entity or person on whose behalf a transaction is made. This includes any entity (company, partnership, corporation, trust or other legal structure) or any person that has, directly or indirectly, 25% ownership or greater (or, any percentage ownership lower than 25%, in accordance with applicable local law) in the Third Party, or exercises effective control over the Third Party.
Institutional Framework & Governance
2.1 The AML Compliance Office
We have established an independent Compliance Unit led by the Money Laundering Reporting Officer (MLRO). The MLRO has direct access to the Board of Directors and is responsible for:
Filing Suspicious Transaction Reports (STRs) to ANIF Cameroon.
Managing the Kemit AI Fraud Detection rulesets.
Conducting semi-annual internal audits to ensure the integrity of the Tangento Group ecosystem.
2.2 Staff Training & Awareness
Every TangentoPay employee must undergo mandatory AML training upon hiring and annually thereafter. This covers:
Identifying "Red Flags" specific to African Fintech trends.
Proper handling of sensitive data under GDPR/CEMAC privacy laws.
The legal consequences of "Tipping Off" a suspect.
Customer Due Diligence (CDD)
The Company conducts appropriate due diligence checks (“DD Checks”) on Third Parties with which the Company does business after assessing potential AML risks based on red flags. Fapshi Personnel should be alert to suspicious behavior or “red flags” when doing business with, conducting DD Checks on, and/or monitoring continued engagement with Third Parties. Appendix A contains a non-exhaustive list of red flags that, if observed, should be reported to the legal department. If a red flag is spotted, the legal department should be notified and will investigate the red flag and take further action consistent with this Policy and all applicable Anti-Money Laundering Laws. Such an investigation may entail a thorough review of the business relationship with the Third Party and any previous transactions with the Third Party to ensure that such transactions were consistent with this Policy and the Company's knowledge of the Third Party, its commercial activity and risk profile, and, when necessary, the source of its funds. The following steps may be taken, at the discretion of the legal department, when a red flag is raised:
i. Verifying the Third Party's identity
For individuals, this can include requesting a copy of their passport or the national identity document containing their name, date of birth, physical address, tax identification number and valid government identification, consistent with local laws. For a legal entity, this can include requesting incorporation or related documents or certificates of good standing and/or existence from an appropriate governmental agency, as well as data regarding their legal representatives, owners or board members;
ii. Collecting from the Third Party a signed Third Party Anti-Corruption Compliance Letter for Third Party(ies);
iii. Identifying the Third Party's Ultimate Beneficiaries and verifying the Ultimate Beneficiaries against official documentation;
iii. Confirming the Third Party's legal status
By checking official and/or authenticated documents (such as copies of business licenses, tax registrations, articles of incorporation or organization, bank references, credit agency reports, or any other equivalents deemed reasonable);
iv. Identification of Third Party
Identifying, in the case of a Third Party entity such as a company, partnership, trust, etc., its place(s) of operations and the identity and nationality of its shareholders, administrators, and directors, as well obtaining copies of its bylaws, articles of incorporation, or equivalent in each country in which it operates;
v. Obtaining Third Party Information
Obtaining any other Third Party information which is collected as a part of ordinary business practice, such as financial statements, credit agency reports, bank references, bank account information and ownership and control structure;
vi. Screening the Third Party against relevant AML and sanctions lists.
These include, but are not limited to, the OFAC SDN List, the U.S. State Department's Terrorist Exclusion List, other relevant sanctions lists in the jurisdictions in which the Company operates, and commercially available AML lists; and
vii. Notifying the Third Party in writing of this Policy and the Third Party's obligation to comply with all applicable Anti-Money Laundering Laws
Once the DD Check information has been collected, the legal team shall determine whether the transaction or commercial relationship should proceed based on the information provided. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex. Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.
Customer Due Diligence (CDD) Hierarchy
TangentoPay employs a tiered approach to Know Your Customer (KYC) and Know Your Business (KYB).
Tier Profile Requirements
Standard (CDD) Local SMEs & Individuals ID/Passport, Business License, Proof of Address.
Enhanced (EDD) High-Volume & Foreign Entities UBO Declaration, Source of Wealth, 3 years of Financials.
Simplified (SDD) Public Entities/Listed Cos Verification of public record status.
(i) Beneficial Ownership (UBO)
In accordance with FATF Recommendation 24, TangentoPay must identify the "Ultimate Beneficial Owner"—any natural person holding 25% or more of shares or voting rights. We utilize global registries to verify these structures, ensuring no Sanctioned Entities bypass our gateway.
Transaction Monitoring & "Red Flag" Indicators
The Company shall undertake payment acceptance due diligence measures to reduce the risk of receiving monies involved in money laundering and terrorist financing activities. Third parties should be notified of the Company's acceptable forms of payment. The Company may accept a wire transfer which does not specify any bank account owner if it is legally permissible in the country where the transaction is taking place. The Company should keep a record of the Third Party's report of such wire transfer, including confirmation of the Third Party's bank account details (i.e., bank name and account holder name). TangentoPay Personnel should review Payments closely to look for any AML red flags outlined in Appendix A. Payments should be legal and commercially reasonable in consideration of local business practices and with respect to the Third Party. The Payment should be made in compliance with any notification and record keeping requirements of applicable local laws and regulations, and the Payment should not be made in such a way that it appears intended to circumvent such requirements. Our Payment Gateway uses real-time AI to flag anomalies.
(i) Automated Monitoring Rules
Structuring (Smurfing): Multiple small deposits just under the 5,000,000 XAF reporting threshold.
Velocity Spikes: A 300% increase in transaction volume within 24 hours without prior notice.
Geographic Anomalies: A Cameroon-based merchant suddenly receiving 90% of traffic from high-risk "Blacklisted" jurisdictions.
(ii) Prohibited Business Types
TangentoPay strictly prohibits processing for:
Unlicensed Shell Banks.
Anonymous/Encrypted Virtual Asset providers without Travel Rule compliance.
Any entity on the FATF High-Risk list.
Sanctions Screening & Asset Freezing
We perform real-time screening against:
UN Security Council Consolidated List.
EU & OFAC Sanctions Lists.
CEMAC/CNEF Blacklists (Updated Jan 2026 for credit defaulters).
Mandatory Action: If a match is found, TangentoPay is legally required to freeze the assets immediately and report the match to ANIF within 48 hours.
Record Keeping & Data Retention
To facilitate legal investigations, TangentoPay maintains an immutable audit trail of all transactions and KYC data.
Retention Period: Records are stored for 10 years after the business relationship ends, per CEMAC Financial Standards.
Storage Security: All data is encrypted using AES-256 standards on segregated servers.
Suspicious Transaction Reporting (STR)
If you become aware of any known or suspected violation of applicable Anti-Money Laundering Laws or this Policy, you should immediately report the situation to the legal department at legal@tangentopay.com. Any manager or Human Resources representative who receives a report of a potential violation of this Policy or the law must immediately inform the legal department. You can also ask questions, raise concerns, or make reports of suspected compliance violations by contacting us: By phone (WhatsApp) using +237 654 33 74 09; or By web available at https://tangentopay.com/contact Reports should be factual instead of speculative or conclusory and should contain as much specific information as possible to allow the persons investigating the report to adequately assess the nature, extent, and urgency of the investigation. The Company will not permit retaliation of any kind against anyone who makes a report or complaint in good faith with a reasonable basis for believing that a violation of this Policy or other illegal, unethical, or inappropriate conduct has occurred. The Company encourages and highly values such good faith reporting of potential conduct that may violate Anti-Money Laundering Laws or this Policy. If the MLRO determines a transaction is suspicious, an STR is filed.
Confidentiality: The merchant is never informed of the investigation (Anti-Tipping Off).
Law Enforcement Liaison: TangentoPay cooperates fully with the General Delegation for National Security (DGSN) during official inquiries.
Data Access, Use, and Protection
In accordance with applicable Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and data protection regulations, TangentoPay maintains defined procedures governing the access, use, storage, and retention of user data.
i. Data Accessed
TangentoPay accesses only the categories of user data necessary to perform customer due diligence, verification, security controls, and regulatory compliance obligations. This may include limited third-party user data, where access has been explicitly authorized by the user.
ii. Data Usage
TangentoPay implements appropriate technical and organizational security measures to protect user data against unauthorized access, alteration, disclosure, or loss. These measures include secure storage systems, encryption, access controls, and continuous monitoring.
iii. Data Sharing
User data may be disclosed only where required for compliance, legal, or operational purposes. This includes disclosures to regulated third-party service providers, auditors, or competent authorities, where such disclosure is required by law or necessary to meet AML obligations. All disclosures are subject to confidentiality and data protection safeguards.
iv. Data Storage and Protection
TangentoPay applies appropriate technical and organizational measures to protect user data against unauthorized access, loss, misuse, or alteration. Security controls are implemented in line with industry standards and are reviewed periodically to ensure continued effectiveness.
v. Data Retention and Deletion
User data is retained for the minimum period necessary to satisfy AML, legal, and regulatory requirements. Upon expiration of the applicable retention period, or upon receipt of a valid deletion request, data is securely deleted or anonymized, unless retention is otherwise required by law.
Consequences of Non-Compliance
Violations of any applicable Anti-Money Laundering Laws or this Policy may result in criminal prosecution and/or the imposition of civil sanctions, not to mention potential long-term harm to the Company's reputation. Under no circumstances shall any TangentoPay Personnel facilitate or participate in any money laundering or terrorist financing activity. The Company will not pay any fine imposed on any TangentoPay Personnel or any Third Party and will not indemnify or reimburse any Rimini Street Personnel or any Third Party for any attorney's fees and/or costs incurred as a result of a breach of any Anti-Money Laundering Laws or this Policy. In addition, any breach of this Policy or any Anti-Money Laundering Laws may result in disciplinary action, including possible termination of employment, clawback/recoupment of bonuses or other incentive-based compensation, or such other remedial or disciplinary action as shall be appropriate under the circumstances, in accordance with applicable law. Conversely, the Company will fully support any TangentoPay Personnel or Third Parties who decline to engage in conduct that would place the Company's ethical principles and reputation at risk.
Amendments
Any changes or amendments to this Policy must be approved by the Company's Board of Directors with the exception of non-substantive changes/amendments to update
(i) the titles of any executive officer or member of senior management identified by title herein,
(ii) the name of any regulatory agency identified herein or
(iii) any Cameroonian or any international statute (or rules or regulations promulgated thereunder) referenced herein, which changes/amendments may be approved by the Company's Chief Executive Officer upon the recommendation of the Chief Legal staff.
Appendix A - Non-Exhaustive List of AML Red Flags
The Third Party shows unwillingness to provide identification documents, or any other data requested during the DD Check, or such information is incomplete, wrong or misleading;
The Third Party uses a false address;
The Third Party displays expired identification;
The Third Party provides inconsistent information;
The Third Party has complex shareholding structures which are not reasonably justified;
The Third Party's operations drastically change over time in volume or amount;
The Third Party shows unusual concerns related to the disclosure of any such data requested, particularly regarding its identity and type of business;
The Third Party unreasonably questions the requirements of documentation and handling of information;
The Third Party's financial information reflects asset concentration in subsidiaries or affiliates where there is an absence of audited financial statements;
The Third Party has multiple accounts under the same name for no apparent purpose;
The Third Party, including any individual associated therewith, or any of its subsidiaries or affiliates has a negative background, such as criminal records, civil penalties of any kind, or investigations regarding tax fraud, money laundering activities, and/or organized crime;
The Third Party, or one of its owners or board members, is on the Cameroon's Terrorist Exclusion List;
The Third Party refuses to or is unable to identify a legitimate source of its funds;
The Third Party transacts with important public figures, such as public officials or other politically exposed persons;
The Third-Party attempts to send or receive a payment, which are not commercially reasonable in considering of local business practices and with respect to the Third Party;
The Third Party makes payments through the accounts of different individuals or entities rather than through its own accounts;
The Third Party's payments are conducted through a credit institution of different nationality than that of the Third Party;
The Third Party frequently engages in transactions where payments equal the maximum amount allowed for withdrawals at financial institutions;
The Third Party seeks to bribe, threaten or persuade Rimini Street Personnel to avoid any obligation related to this Policy or Anti-Money Laundering Laws;
There are deposits in foreign currency made by multiple individuals for the same transaction;
The Third Party requests unjustifiably high or low prices for products or services which are not within market standards;
The Third Party requests or ensures that goods are transported through more than one jurisdiction for no apparent reason
The Third Party frequently changes its payment instructions;
The Third Party requests or proposes excessive modifications to letters of credit or similar documents;
The Third Party provides false invoices or invoices with miscellaneous charges that have not been previously approved by the Company;
The Third Party makes an unusually large amount of overpayment or requests a refund to be sent to an unknown Third Party as a result of a cancelled purchase order;
The Third Party's representative seems not to know basic facts about the Third Party's business, which raises suspicion as to whether he or she is actually employed by the Third Party;
The Third Party requests the Company to issue an invoice which does not accurately reflect an invoiced price or other material terms of the transaction;
The Third Party structures a transaction to circumvent the notification requirements of authorities or governments, for example, by paying one invoice with numerous money orders or cashiers' checks in amounts under the notification requirements; or
The Third Party has a broker, attorney, or other agent to facilitate the transaction, which is unusual for the type of business, and the Company has no proper information or documentation regarding such agent or such agent's authority.

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