Effective Date: 1 February 2026. Version: 1.0.
1. Purpose
This Anti-Money Laundering and Counter-Terrorist Financing Policy sets out Developify's framework for preventing, detecting, and mitigating the risk of money laundering, terrorist financing, and related financial crimes. The Policy underpins the Risk Management and Compliance Programme (RMCP) and establishes the principles governing Developify's compliance with applicable anti-money laundering legislation. Developify recognises its responsibility to protect investors, safeguard the integrity of its platform, and contribute to the stability of the South African financial system.
2. Scope of application
This Policy applies to all clients, products, services, employees, officers, directors, and third-party service providers of Developify. It covers all business relationships and transactions conducted through the platform, including onboarding, investment activity, distributions, withdrawals, and any secondary trading functionality.
3. Regulatory framework
This Policy is adopted in accordance with the Financial Intelligence Centre Act, 38 of 2001, as amended, related directives and guidance notes issued by the Financial Intelligence Centre, and the Financial Action Task Force risk-based approach. It also takes account of exchange control and data protection requirements under the Protection of Personal Information Act.
4. Risk-based approach
Developify applies a risk-based approach to anti-money laundering and counter-terrorist financing. Risks are assessed across client type, geographic exposure, products, transaction behaviour, and delivery channels. Controls are applied proportionately and documented in the RMCP.
5. Governance and oversight
The Board and senior management are responsible for approving this Policy, setting risk appetite, and ensuring sufficient resources are allocated to AML compliance. A designated Compliance Officer and MLRO oversee the implementation and ongoing operation of this Policy and the RMCP.
6. Customer due diligence
Customer due diligence is conducted before onboarding clients, accepting funds, or when material changes or suspicions arise. This includes identifying and verifying clients and beneficial owners, understanding the purpose of the relationship, and confirming the source of funds.
7. Enhanced due diligence
Enhanced due diligence applies to higher-risk clients and scenarios, including trusts, stokvels, complex ownership structures, non-resident investors, politically exposed persons, and unusual transaction activity. Enhanced measures may include additional information, independent verification, and senior management approval.
8. Beneficial ownership
Developify identifies and verifies natural persons who ultimately own or control non-natural person clients. Beneficial ownership information is maintained and kept up to date.
9. Sanctions and PEP screening
Sanctions, politically exposed person, and adverse media screening are performed during onboarding, periodically thereafter, and when triggered by events. Potential matches are reviewed and escalated appropriately.
10. Source of funds and source of wealth
The origin of funds invested is assessed on a risk basis. Additional verification may be required for higher-risk transactions or clients.
11. Ongoing monitoring
Developify monitors transactions and client activity to ensure consistency with the expected risk profile and to identify unusual or suspicious behaviour.
12. Suspicious transaction reporting
Where money laundering or terrorist financing is suspected, Developify will submit reports to the Financial Intelligence Centre in accordance with legal requirements. Confidentiality and non-tipping-off obligations are strictly observed.
13. Recordkeeping
Records relating to customer due diligence, transactions, and reports are retained for a minimum of five years after termination of contractual relationship and are securely stored.
14. Data protection
All personal information collected for AML purposes is handled in accordance with POPIA and internal information security standards.
15. Training and awareness
Developify provides AML training appropriate to staff roles and responsibilities and updates training regularly.
16. Breaches
Breaches of this Policy may result in disciplinary action, termination of relationships, or regulatory reporting.
17. Review and approval
This Policy is reviewed annually and approved by the Board. Document title: Anti-Money Laundering & Counter-Terrorist Financing Policy. Version: 1.0. Effective date: 1 February 2026. Approved by: Board of Directors. Next review date: 1 February 2027.
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