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Legal Document

AML POLICY

ANTI-MONEY LAUNDERING (AML) AND COUNTER-FINANCING OF ILLEGAL ACTIVITIES POLICY
NEXT GENETICS ONLINE

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1. PURPOSE

1.1 This Policy sets out the measures implemented by NEXT GENETICS DORPERS (PTY) LTD (“online”, “Platform”, “we”, “us”) to prevent:

* Money laundering
* Fraudulent financial activity
* Use of the Platform for unlawful purposes

1.2 This Policy aligns with:

* South African anti-money laundering principles
* Applicable financial and regulatory obligations

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2. PLATFORM STATUS

2.1 The Platform operates as an **online marketplace** and **limited payment facilitator**.

2.2 The Platform is NOT:

* A bank
* A financial institution
* A licensed financial services provider (unless otherwise stated)

2.3 Despite this, the Platform implements **risk-based controls** to prevent misuse.

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3. DEFINITIONS

3.1 “Money Laundering” means any activity intended to conceal the origin of illegally obtained funds.

3.2 “Suspicious Transaction” means any transaction that appears irregular, inconsistent, or indicative of unlawful conduct.

3.3 “User” means any registered person or entity on the Platform.

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4. RISK-BASED APPROACH

4.1 The Platform adopts a **risk-based approach** to monitoring transactions.

4.2 Risk factors may include:

* Unusual transaction patterns
* High-value or rapid transactions
* Repeated cancellations or reversals
* Inconsistent user information

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5. CUSTOMER VERIFICATION (KYC)

5.1 The Platform requires Users to undergo verification, including:

* Identity verification
* Business registration verification (where applicable)
* Submission of supporting documentation

5.2 The Platform may:

* Request additional information
* Refuse or revoke access

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6. TRANSACTION MONITORING

6.1 The Platform may monitor:

* Payment activity
* Escrow transactions
* Auction behaviour
* Account activity

6.2 Monitoring may be:

* Automated
* Manual

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7. SUSPICIOUS ACTIVITY DETECTION

7.1 Indicators of suspicious activity include:

* Use of multiple accounts
* Attempts to bypass payment systems
* Rapid movement of funds
* Inconsistent or false documentation

7.2 The Platform may flag such activity for review.

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8. ENFORCEMENT MEASURES

8.1 Where suspicious activity is identified, the Platform may:

* Freeze funds
* Suspend accounts
* Cancel transactions
* Require additional verification

8.2 Actions may be taken:

* Without prior notice
* At the Platform’s discretion

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9. REPORTING

9.1 The Platform reserves the right to report:

* Suspicious transactions
* Fraudulent conduct

To:

* Law enforcement authorities
* Regulatory bodies

9.2 The Platform may provide:

* User data
* Transaction records
* Communication logs

Where legally required.

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10. RECORD KEEPING

10.1 The Platform retains records of:

* User verification data
* Transactions
* Suspicious activity reports

10.2 Records are retained:

* For legal compliance
* For fraud prevention

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11. THIRD-PARTY PAYMENT PROVIDERS

11.1 Payments are processed via licensed third-party providers.

11.2 These providers may:

* Perform their own AML checks
* Enforce compliance measures

11.3 The Platform is not responsible for:

* Decisions made by payment providers
* External compliance processes

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12. USER OBLIGATIONS

Users must:

12.1 Provide accurate and truthful information

12.2 Use the Platform for lawful purposes only

12.3 Not engage in:

* Money laundering
* Fraud
* Financial abuse

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13. LIMITATION OF LIABILITY

13.1 The Platform shall NOT be liable for:

* Losses arising from AML enforcement actions
* Frozen or delayed funds
* Account suspensions

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14. INDEMNITY

14.1 Users indemnify NEXT GENETICS DORPERS (PTY) LTD against:

* Claims arising from unlawful financial activity
* Regulatory penalties caused by user conduct
* Third-party claims

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15. TRAINING AND AWARENESS

15.1 The Platform may implement:

* Internal compliance procedures
* Staff awareness measures

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16. AMENDMENTS

16.1 This Policy may be updated at any time.

16.2 Continued use constitutes acceptance of changes.

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17. GOVERNING LAW

This Policy is governed by the laws of the Republic of South Africa.

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18. CONTACT DETAILS

NEXT GENETICS DORPERS (PTY) LTD
2026/181336/07

250 Milner Street, 
Waterkloof, 
Pretoria, 
Gauteng, 
0181

info@nextgeneticsza.co.za

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END OF DOCUMENT
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