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ANTI MONEY LAUNDERING POLICY

Travel et Vogue: AML/CFT Compliance Policy

1. Policy Statement

Travel et Vogue is committed to the highest standards of financial integrity. We maintain a zero-tolerance approach to money laundering, terrorism financing, and the proliferation of weapons of mass destruction. This policy ensures compliance with the Proceeds of Crime and Anti-Money Laundering Act (POCAMLA) and the Prevention of Terrorism Act (POTA).

 

2. The Risk-Based Approach (RBA)

We do not apply a "one-size-fits-all" check. We categorize our clients and transactions based on risk:

  • Low Risk: Repeat clients with established, transparent income sources.

  • Medium Risk: New clients booking high-value solo travel.

  • High Risk: Clients from high-risk jurisdictions (as defined by FATF), Politically Exposed Persons (PEPs), or transactions involving large cash payments (over $15,000).

 

3. Customer Due Diligence (CDD) / Know Your Customer (KYC)

We must verify the identity of our clients before any business relationship is established.

 

  • Natural Persons: Valid Passport/National ID and proof of residence.

  • Legal Entities: Certificate of Incorporation, CR12 form (showing directors), and identification of the Ultimate Beneficial Owner (UBO)—any individual owning more than 10% of the entity.

  • Enhanced Due Diligence (EDD): For High-Risk clients, we must verify the Source of Wealth (SoW) and Source of Funds (SoF) to ensure the money used for the luxury booking is from a legitimate origin.

     

 

4. Suspicious Transaction Reporting (STR)

As a reporting institution, we are legally required to monitor for "Red Flags," including:

  • Clients who are unusually secretive about their identity or source of funds.

  • Payments made by third parties with no clear connection to the traveler.

  • Multiple small payments designed to stay below the $10,000 reporting threshold (Structuring).

  • Sudden cancellations of high-value trips with a request for the refund to be sent to a different bank account.

Legal Note: All suspicious activities must be reported to the Financial Reporting Centre (FRC) of Kenya via the "GoAML" portal within 7 days of the suspicion arising. Tipping off a client that they are under investigation is a criminal offense.

 

 

5. Record Keeping

Travel et Vogue shall maintain all KYC documents and transaction records for a minimum of 7 years after the business relationship ends. These records must be available for inspection by the FRC or the Tourism Regulatory Authority (TRA) upon request.

 

 

6. Appointment of a Compliance Officer

The CEO (or a designated senior manager) shall act as the Money Laundering Reporting Officer (MLRO). Responsibilities include:

  • Filing STRs and Currency Transaction Reports (CTRs).

     

  • Conducting an annual AML/CFT risk assessment of the business.

  • Ensuring staff are trained at least once every 24 months on new AML typologies.

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