Anti-Money Laundering & Counter-Terrorism Financing (AML/CTF) Policy
1. Purpose and Scope
Pakimu Investment Limited T/A WanPaus Microfinance ("Pakimu") is committed to operating its microfinance platform in a manner that does not facilitate money laundering, terrorism financing, or other financial crime.
This AML/CTF Policy sets out the principles and controls Pakimu applies to detect, prevent, and report suspected financial crime on the WanPaus Microfinance platform ("the Platform"). It applies to all borrowers, staff, tenant administrators, and any other persons who access the Platform in any capacity.
This policy operates within the framework of applicable Papua New Guinea law, including the Anti-Money Laundering and Counter Terrorism Financing Act 2015 (PNG) ("the AML/CTF Act") and any regulations or directions issued thereunder by the Financial Analysis and Supervision Unit (FASU) or the Bank of Papua New Guinea (BPNG).
2. Prohibited Uses of the Platform
The following activities are strictly prohibited on the Platform:
- (a) Money laundering — using the Platform to conceal, move, or legitimise funds derived from criminal activity;
- (b) Terrorism financing — using the Platform to provide financial support, directly or indirectly, to any terrorist organisation, individual, or activity;
- (c) Structuring — deliberately breaking a transaction into smaller amounts to avoid detection or reporting thresholds;
- (d) Use of proceeds of crime — borrowing or repaying loans using funds that are the direct or indirect proceeds of illegal activity;
- (e) Fraud — using false identity, false income information, or multiple registrations to obtain credit;
- (f) Third-party repayment — having a loan repaid by an unrelated third party without Pakimu's prior written approval, which may indicate layering activity.
Violation of any of the above is a breach of our Acceptable Use Policy and may constitute a criminal offence under PNG law. Pakimu will report suspected violations to FASU and law enforcement without prior notice to the account holder.
3. Customer Due Diligence
Pakimu applies a risk-based approach to customer due diligence ("CDD"). At a minimum, every borrower must complete standard CDD before accessing loan products:
- (a) identity verification (see our KYC Policy);
- (b) confirmation of residential address;
- (c) email and phone number verification.
Enhanced Due Diligence (EDD) may be applied where a borrower is assessed as higher risk, including:
- accounts showing unusual repayment patterns (e.g. frequent large early repayments not consistent with stated income);
- accounts associated with multiple identity documents;
- accounts where the source of repayment funds cannot be reasonably explained;
- accounts of Politically Exposed Persons (PEPs) or their close associates.
Pakimu reserves the right to request additional information from any borrower at any time for CDD purposes. Failure to provide requested information may result in suspension of the account.
4. Transaction Monitoring
The Platform maintains comprehensive, immutable audit logs of all financial transactions. Pakimu monitors the Platform for patterns that may indicate financial crime, including:
- (a) repayments significantly exceeding the outstanding balance or originating from unexpected sources;
- (b) rapid successive loan applications following early repayments;
- (c) unusual geographic access patterns for a given account;
- (d) multiple accounts sharing identity attributes (document number, device fingerprint, email, phone).
5. Suspicious Matter Reporting
Where Pakimu identifies activity that raises a suspicion of money laundering or terrorism financing, we are required by law to file a Suspicious Matter Report (SMR) with the Financial Analysis and Supervision Unit (FASU) in accordance with the AML/CTF Act 2015.
Tipping off — informing a person that a report has been or may be filed about them — is prohibited by law. Pakimu staff and contractors are not permitted to disclose that an SMR has been filed.
6. Record Keeping
All customer identification records, transaction records, and AML/CTF-related records are retained for a minimum of seven (7) years from the date of the transaction or account closure, whichever is later, as required by the AML/CTF Act 2015.
7. Staff Training and Responsibilities
All staff with access to the Platform receive training on AML/CTF obligations, including:
- recognising indicators of money laundering and terrorism financing;
- the obligation to report suspicious activity to Pakimu's designated AML/CTF compliance officer;
- the prohibition on tipping off;
- record-keeping requirements.
Failure by staff to comply with AML/CTF obligations may result in disciplinary action and may expose the individual to personal criminal liability under PNG law.
8. Sanctions Screening
Pakimu will not knowingly extend credit to any individual or entity subject to financial sanctions imposed by the Government of Papua New Guinea, the United Nations Security Council, or any other applicable sanctions regime. Accounts identified as matching a sanctioned individual will be suspended pending further review and reporting to appropriate authorities.
9. Cooperation with Authorities
Pakimu will cooperate fully with FASU, BPNG, the Royal Papua New Guinea Constabulary, and any other lawful authority in connection with AML/CTF investigations. This includes providing records, account information, and testimony as required by court order or regulatory direction. Such disclosure does not require borrower consent where law enforcement authority exists.
10. Amendments
This policy will be reviewed at least annually and updated to reflect changes in applicable PNG law, regulatory guidance, and operational risk. Material amendments will be communicated to all platform users.
11. Contact
AML/CTF concerns may be reported confidentially to:
Pakimu Investment Limited T/A WanPaus Microfinance
Email: hi@wantekpng.com
Papua New Guinea
External reports may be made directly to FASU via www.fasu.gov.pg.