AML Policy

Threerae is committed to preventing the use of its products and services for money laundering, terrorist financing or any other financial crime. This summary sets out the principles we apply. Our full Risk Management and Compliance Programme is an internal document maintained in terms of the FIC Act.

Our Commitment

• We do not knowingly enter into or maintain a business relationship that facilitates money laundering or terrorist financing
• We identify and verify every client before establishing a business relationship or concluding a single transaction
• We maintain a risk-based approach, applying enhanced measures where a client, product or transaction presents higher risk
• We report to the Financial Intelligence Centre where the law requires us to, and we do so without informing the client that a report has been made
• We keep the records the FIC Act requires, for the periods it prescribes
• We train our staff on their obligations and on recognising suspicious activity

Client Due Diligence

Before we establish a business relationship we establish and verify who we are dealing with. For individuals this means verifying identity against your South African ID and confirming your residential address and income. For businesses it means verifying registration, establishing the ownership and control structure, and identifying the beneficial owners and the persons authorised to act on the entity's behalf.

We also screen for prominent influential persons and for persons or entities appearing on applicable sanctions and targeted financial sanctions lists, and we assess the purpose and intended nature of the relationship. Due diligence is not a once-off exercise — we keep client information current and review it during the relationship.

Risk-Based Approach

Not every relationship carries the same risk, and our measures scale accordingly. Where risk indicators are present — an unusual ownership structure, a transaction inconsistent with a client's known profile, reluctance to provide information, or a connection to a higher-risk jurisdiction or sector — we apply enhanced due diligence, seek additional information, and escalate for senior approval before proceeding. Where risk cannot be adequately managed, we decline or terminate the relationship.

Reporting Obligations

We report to the Financial Intelligence Centre as required, including:

• Cash threshold reports (CTRs) for cash transactions at or above the prescribed threshold
• Suspicious and unusual transaction reports (STRs) where we know or suspect that property is the proceeds of unlawful activity, or that a transaction relates to money laundering or terrorist financing
• Terrorist property reports (TPRs) where we possess or control property connected to a person or entity on a targeted financial sanctions list

Reporting is mandatory and is made regardless of the value involved in the case of suspicious activity. We do not disclose to a client that a report has been or may be made — doing so is an offence.

Record Keeping

We keep records of client identification and verification, of the business relationship, and of every transaction concluded, for the periods prescribed by the FIC Act. These records are retained in a form that allows them to be reproduced and made available to the Financial Intelligence Centre or a supervisory body on request.

Governance, Training And Independent Review

Accountability for anti-money-laundering compliance sits with senior management. Staff receive training appropriate to their role, covering client due diligence, recognising and escalating suspicious activity, and the prohibition on tipping off. Our programme is reviewed periodically and updated to reflect changes in our risk profile and in the law.

What This Means For You

You will be asked for identification and supporting documents before we can transact with you, and you may be asked for further information during the relationship. We appreciate that this adds friction. It is a legal requirement, it applies to every client equally, and it is part of what distinguishes a regulated lender from an informal one.