Zeal Forex Bureau
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Plot 1 Namaganda Plaza. P.O.Box 11562 kampala-Russel Rd (Ug).
Tel: 0414666898, 0785438382 Email -,
Tel: 0414666898,0785438382

Anti-Money Laundering (AML) Compliance policy

The Zeal forex bureau AML Policy is designed to prevent money laundering by meeting the Ugandan and international AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the company being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be adhered to.



Zeal Forex Bureau is committed to the highest standards of anti-money laundering (AML) and counter terrorism financing (CFT ), and requires management and employees to adhere to these standards so as to prevent the use of its products and services for any Money laundering purpose.

Zeal Forex Bureau examines its AML strategies and objectives on an ongoing basis, and maintains an effective AML policy that reflects its best practices as a domestic financial services provider.

Zeal forex bureau AML program includes appropriate KYC and Customer Acceptance policies, including establishing the identity of the true beneficial owners, adherence to all legal and regulatory requirements imposed by the government and its regulators.

Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income.

Criminals specifically target financial services firm, companies or institutions through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.

Anti-Money laundering refers to controls required of financial institutions and other regulated entities to prevent, detect and report money laundering activities.


It’s the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activity, allowing them to maintain control over the proceeds and ultimately, proving a legitimate cover for their source of income


It can also be referred to as “cleaning of money” in money laundering process, illegally obtained money is given the appearance of having originated from a legitimate source.



1. The company supports the fight against money laundering and terrorism by adopting this AMLCompliance Policy to prevent the Agent’s financial services from being used to promote such criminal activity.

2. Cooperate with all the authorities, to the extent that is permitted by applicable Laws, so as to help them in their efforts to prevent or fight money laundering, and the financing of terrorism proliferation.

3. The company will fully comply with both the intent and letter of all laws and regulations relating to AML, the prevention of terrorist financing and economic sanctions

4. The Agent will train its employees to comply with these laws and regulations.

5. Every employee of the company who conducts or is involved in a Money Service Business (MSB) operation is required to understand and comply with the contents of this document.

6. A copy of this AML Compliance Policy will be kept at each location conducting money services, in a place that is accessible to all employees conducting MSB and forex transactions.

7. Maintain all customer/transactions related records for at least 10 years or for longer period if the Law in the country requires so.




Gondha Tonny Is here by designated as the Anti-Money Laundering Compliance Officer.


  • Ensuring ongoing compliance with country and state specific AML regulations.
  • Implementing, reviewing, and updating this AML Compliance Policy as necessary due to changes in laws or regulations and ensuring that all employees involved are well advised of these changes.
  • Ensuring all employees are trained on AML/KYC compliance requirements before conducting MSB and forex transactions.
  • Ensuring ongoing AML training is conducted in an effective manner for all appropriate employees.
  • Ensuring all training is documented, including the date of the training, name of the trainer/trainee and topics discussed.
  • Monitoring day-to-day compliance with the related laws and regulations.
  • Ensuring accurate record keeping and reporting as mandated by the company and state specific regulations.
  • Ensuring that the AML Compliance Policy is subjected to periodic independent reviews.
  • Cooperating with law enforcement and Money service agents on AML reviews, audits and investigations.



Zeal Forex Bureau follows a rigid recruitment process, part of it being the mechanism of understanding any relationship of potential employees with any kind of crime/criminal activities.

Within our induction program, which consists of a number of intensive and hands-on training sessions, Zeal Forex Bureau trains the newly recruits in the principles, methodologies, policies and procedures of AML/KYC. Training on AML/KYC

Policy and Procedures is an ongoing procedure in Zeal Forex Bureau, with refresher training offered to all its employees every month at a minimum.

Training is to be provided to all employees (new and existing) before conducting MSB/forex transactions, and, at a minimum, must include:

  • Review of all requirements in this AML Compliance Program Verifying customer identification
  • All relevant transaction processing requirements
  • Identifying suspicious activity and structured transactions Reporting requirements related to all transactions
  • Recordkeeping requirements Additional training will be provided regularly to all employees based on, but not limited to, changes in government regulations,
  • Train and test employees to confirm that they are compliant with the overall requirements of the Compliance Program.

All training will be documented and retained in employee personnel files, other related AML files, or with the Training Log in the TRAINING RECORDS section of the Compliance Training Resource. An employee will also receive additional AML training in the event of a performance issue related to an AML incident.



One of the most effective ways to protect the business from becoming the victim of financial crimes starts with confirming the identity of the customers and knowing with whom money service/forex transactions are being conducted. To avoid processing transactions that could put the company at risk, the company will implement a ‘Know Your Customer (KYC)” process that includes, but is not limited to:

  • Requesting and documenting required customer information before processing transactions. Must include: type of ID, the ID number, and details of the customer and where possible call and confirm the genuinity before effecting payment.
  • Only accepting valid identification issued with a photo, wherever possible such as a driver’s license, passport, national identification card that contains the customer’s name, address and photograph
  • Ensuring data recorded is accurate.
  • Monitoring customer transaction activity


(Photo Required) The photo ID must be issued by a legitimate issuing body.

The customer’s name and likeness must match the information and picture on the photo ID.

If the customer is not a resident of UGANDA, he / she must present a passport, or other official document evidencing nationality or residence and Zeal forex bureau employee should try and contact the issuing authority to confirm authenticity of the identification.

The COMPANY will not accept any form of identification that has expired or appears to be altered or fabricated.

ACCEPTABLE FORMS OF CUSTOMER ID (but may not be limited to :)

  1. Passport
  2. Voters id
  3. Drivers License
  4. National id.
  5. Travel document with photo east Africans only.
  6. financial card issued in Uganda
  7. Refugee id issued in Uganda



Multiple forex cash purchases/sale made by the same person in one business day must be aggregated, or added together, and treated as a single purchase/sale, even if purchased or sold at different times during the day.

Whenever the same consumer/customer purchases or sells $5,000 or more in forex, using cash, in the same day, you MUST obtain and record the following consumer transaction information on the large cash transaction BEFORE completing the transaction(s)

Name and physical/postal Address of location of the

  • Name and Address of consumer purchasing or selling
  • Date the consumer purchased/sold the forex.
  • Occupation/Job of consumer purchasing or selling.
  • Date of Birth of person purchasing or selling.
  • Type of valid identification issued photo ID provided (i.e. Drives License) and number on ID.
  • TOTAL amount of ALL money purchased/sold by the consumer.

All information must be obtained from the customer and documented BEFORE processing the transaction on the Money Business and forex transaction system.

Total Amounts More Than $10,000

Amounts more than $10,000 also requires a counter terrorism financing CTR to be E-Filed at Information must also be recorded on the Money Order Transaction Log as detailed above.


BEFORE processing any Money transfer send transaction, the company employee must:

  • Confirm the customer completed all necessary sections; front and back of the Money transfer Send Form.
  • Confirm the customer signed the Money transfer Send Form.
  • Completely and accurately enter all required customer information into the Money transfer system.

The Agent may require a customer to provide additional identifying information BEFORE completing any money services transaction depending on the type, amount, or circumstances surrounding the transaction.



BEFORE processing any money transfer send transaction, the company employee must:

  • Confirm the customer is using a valid identification issued with a photo.
  • Confirm that the customer name used on the form matches the name on the consumer ID.
  • Confirm that the customer signature used on form matches the name on the consumer ID.



Please refer the customer ID Requirements posted on the Money service business Counters.

Ensure all the necessary details are well documented.

If a customer refuses to provide any information required, the company CANNOT process the transaction.



BEFORE conducting any money transfer receives transaction, the company employee will:

  • Confirm the customer completed all necessary sections, front and back of the Money Receive form.
  • Confirm the customer signed the Money Receive Form
  • Completely and accurately enter all required customer information into the money transfer system


The company employees MUST require a customer to provide personally identifying information BEFORE completing any money service receive transaction.

Please refer the Customer ID Requirements posted on the MoneyGram, express and western union Counter.

If a customer refuses to provide any information required the Agent/company CANNOT process the transaction.



Maintenance of Records

  • Data Policy As an agent, you must safeguard nonpublic personal information. You may only ask for and collect the personally identifying information that is necessary to complete the transaction.
  • Records to be kept You must keep records of all transactions, regardless whether the ID of the customer Or client needed to be verified. All copies of supporting documents should be preserved in the archives and the same should be easily retrievable such as customer IDs, Trade Licenses, Invoice details etc at any given time.
  • Record Retention All record keeping and reporting documentation required by the Bank of Uganda and financial regulatory authority will be maintained for a minimum of ten (10) years and they will be made readily available upon legitimate request.
  • Consumer Privacy In accordance with the Privacy Act, the company must protect consumers’ personal and private information. All documents that contain consumers’ private and personal information will be stored in a secure location.

 Management and Controls of AML

  1. Controls
  2. A robust and strict KYC program
  3. Training and awareness program for  staff
  4. Processes to ensure staff reliability.
  5. Anti-Bribery and Corruption (ABC).



Adherence to the company AML program needs to be reviewed regularly to ensure that the Company’s efforts are successful. AML Officers in Zeal forex bureau are therefore obliged to conduct appropriate controls. The responsible AML Officer must ensure, by implementing adequate customer- and business related controls that are applicable AML requirements are being adhered to and security measures are properly functioning.

KYC Program

Zeal has implemented a strict KYC program to ensure all kinds of customers (natural or legal persons or legal structures, ) are subject to adequate identification. This program has been implemented in all branches.
KYC includes not only knowing the clients deals with (either as a single transaction or ongoing relationship), or renders services to, but also the Ultimate Beneficial Owners
The program includes strict identification requirements, name screening procedures and the ongoing monitoring and regular review of all existing business relationships.

Training Program

Zeal forex bureau has implemented a comprehensive AML training program to ensure that all staff and particular individuals responsible for transaction processing, initiating or establishing business relationships, undergo AML awareness training.

Zeal training is tailored to the business to ensure that staffs are aware of different possible patterns and techniques of money laundering which may occur in their everyday while transacting business.


Processes to ensure staff reliability

Zeal forex bureau has implemented processes to ensure that only reliable individuals are employed for example through referrals from high ranking individuals, obtaining police/Interpol letter, copies of academic documents, letter from previous employer if any, hand written application ,curriculum vitae and passport size photos.

Anti-Bribery and Corruption (ABC) .

Zeal does not tolerate bribery, or any form of corruption. All Zeal forex bureau employees and third parties that act on its behalf are strictly prohibited from having any involvement in acts of bribery and corruption.

  1. Compliance is the responsibility of each and every employee.
  1. Strict compliance is very much necessary with all laws and regulations.


  1. Noncompliance with the law is not worth the risk.
  1. Ignorance of the law is not self-defensive hence no excuse before the law.


  1. In case of doubt in conducting a transaction, please always refer to our AML Policy & Procedures or contact the Compliance Officer/management team.


Rates are subject to change .
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