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ANTI–MONEY LAUNDERING (AML) & COUNTER–TERRORIST FINANCING (CTF) POLICY

Meta Cooperation Company (MCC) PLC / MetaCoun.com
Last Updated: November 22, 2025

1. Introduction

Meta Cooperation Company (MCC) PLC (“MCC”, “we”, “our”) is committed to full compliance with all applicable Anti–Money Laundering (AML) and Counter–Terrorist Financing (CTF) laws and regulations of:

  • The Republic of Cameroon

  • CEMAC Regulations

  • COBAC (Commission Bancaire de l’Afrique Centrale)

  • OHADA corporate best practices

  • International standards including the FATF Recommendations

This AML/CTF Policy outlines the controls MCC PLC implements to prevent:

  • Money laundering

  • Terrorist financing

  • Fraudulent transactions

  • Identity theft

  • Illegal financial activity

MetaCoun.com is a digital wallet and payment platform, not a bank. However, as a financial services operator working with licensed institutions, MCC PLC must follow the same level of due diligence and AML requirements as financial institutions.

2. Purpose of This Policy

This AML/CTF Policy ensures:

  • Protection of MCC PLC, its customers, and partners

  • Prevention of illegal financial activity

  • Compliance with local and international AML laws

  • Secure and transparent digital financial operations

  • Strong internal controls and risk governance

3. Legal Framework

This policy aligns with the following:

Cameroon & CEMAC / COBAC Regulations

  • CEMAC Regulation No. 01/03-CEMAC-UMAC on AML/CTF

  • COBAC Anti–Money Laundering Guidelines

  • Cameroon Financial Intelligence Unit (ANIF) requirements

  • Criminal Code provisions on financial crime

International Standards

  • Financial Action Task Force (FATF) Recommendations

  • USA PATRIOT Act–style enhanced due diligence (best practice)

  • EU AML Directives (benchmark standard)

4. Definition of Money Laundering & Terrorist Financing

Money Laundering involves:

  • Hiding the origin of illegally obtained funds

  • Moving or converting funds to appear legitimate

  • Using legitimate businesses or digital platforms to hide illegal profits

Terrorist Financing involves:

  • Providing funds to individuals or organizations involved in terrorism

  • Funding operations, logistics, or recruitment activities

  • Using legitimate financial channels to disguise illegal intent

5. MCC PLC AML Compliance Principles

MCC PLC follows these five core principles:

  1. Know Your Customer (KYC)

  2. Customer Due Diligence (CDD)

  3. Monitoring and Reporting of Suspicious Activity

  4. Record Keeping and Data Preservation

  5. Internal Controls, Training, and Enforcement

6. Know Your Customer (KYC) Requirements

All users of MetaCoun.com must complete mandatory KYC verification before accessing financial services.

KYC information may include:

  • Full name

  • Phone number

  • Email address

  • Date of birth

  • Government-issued ID (National ID, Passport, or Driver’s License)

  • Selfie verification (where applicable)

  • Proof of residence (for high-risk accounts)

  • Additional identity checks for merchants

MCC may request enhanced information for:

  • Large transactions

  • Unusual account behavior

  • Business accounts

  • Merchants

  • High-risk countries or sectors

7. Customer Due Diligence (CDD)

MCC applies multiple levels of CDD:

a. Standard Due Diligence

Required for all users during onboarding.

b. Enhanced Due Diligence (EDD)

Required when:

  • A transaction exceeds regulatory limits

  • A user is identified as high-risk

  • A merchant engages in flagged business categories

  • Suspicious identity patterns occur

  • Large or irregular cross-border transfers occur

EDD may include:

  • Source-of-funds verification

  • Additional identity documents

  • Video verification

  • Proof of income

c. Ongoing Due Diligence

MetaCoun monitors activity continuously to detect abnormalities.

8. Prohibited Transactions

MetaCoun prohibits the use of its platform for:

  • Money laundering

  • Terrorism financing

  • Drug trafficking

  • Human trafficking

  • Fraud

  • Scams or Ponzi schemes

  • Illegal gambling

  • Sale of prohibited goods

  • Cybercrime

  • Tax evasion

  • Bribery and corruption

  • Transactions involving sanctioned individuals or entities

Users engaging in these activities will be:

  • Immediately suspended

  • Reported to authorities

  • Permanently banned

  • Subject to legal action

9. Transaction Monitoring

MCC reviews account activity using:

  • Automated monitoring systems

  • Manual review by compliance officers

  • Behavioral risk scoring

  • Fraud detection tools

Monitoring identifies:

  • Unusually large or rapid transactions

  • Multiple transactions designed to avoid limits (“structuring”)

  • Suspicious merchant behavior

  • Sudden changes in account patterns

  • Transfers from or to high-risk jurisdictions

  • Use of stolen identities

10. Reporting Suspicious Activity

MCC PLC will report suspicious activity to the Cameroon Financial Intelligence Unit (ANIF) or other regulators as required.

Suspicious Activity Reports (SARs) may be filed when:

  • User behavior indicates illegal activity

  • False or altered identity documents are submitted

  • Transactions appear fraudulent or deceptive

  • Activity matches terrorist financing patterns

MCC PLC is legally prohibited from notifying users when a SAR has been filed (“tipping off rule”).

11. Record Keeping

MCC PLC maintains secure records of:

  • KYC documents

  • Customer identification

  • Transaction history

  • Suspicious activity reports

  • Compliance reviews

These records are kept for the legally required period of at least 5–10 years, depending on the regulation.

12. Internal Controls & Compliance Officer

MCC PLC employs strong internal compliance controls, including:

  • Dedicated AML/Compliance Officer

  • Escalation procedures

  • Independent audits

  • System access controls

  • Staff accountability

The AML Officer is responsible for:

  • Reviewing transactions

  • Approving EDD actions

  • Filing SARs

  • Liaising with regulators

  • Updating AML policies

13. Staff Training

All MCC PLC employees with access to customer data or financial activity receive regular AML training on:

  • Fraud detection

  • Risk indicators

  • Reporting procedures

  • Data protection

  • Regulatory updates

Training occurs:

  • During onboarding

  • Annually

  • Whenever regulations change

14. Sanctions Compliance

MCC does not conduct business with individuals, entities, or countries listed on:

  • United Nations Sanctions Lists

  • FATF High-Risk Jurisdiction List

  • U.S. OFAC Sanctions List (for international compliance)

  • CEMAC/COBAC Restricted Lists

Accounts linked to sanctioned parties will be blocked immediately.

15. User Responsibilities

By using MetaCoun.com, you agree to:

  • Provide accurate information

  • Not engage in any illegal activity

  • Not use MCC to disguise the origin of funds

  • Not attempt to bypass verification requirements

  • Cooperate with any compliance requests

Failure to comply may result in account closure and legal action.

16. Policy Updates

MCC PLC may update this AML/CTF Policy at any time.
The revised version becomes effective upon publication.

Users will be notified through:

  • Website updates

  • Email communication

  • App notifications (where applicable)

17. Contact Information

For AML or compliance inquiries, contact:

AML / Compliance Department
Meta Cooperation Company (MCC) PLC
Meta Quarters Road
Bamenda, North West Region
Cameroon Africa