Anti-Money Laundering & Counter-Terrorist Financing.

Our commitment: zero tolerance.

Nexus affirms absolute commitment against money laundering (ML), terrorist financing (TF) and all forms of financial crime. This commitment is at the core of our framework and applies to all our employees, directors, partners and subcontractors.

Legal and regulatory framework.

Our framework aligns with the most demanding international standards:

• FATF — 40 Recommendations on combating ML and TF
• EU Directives — 5AMLD (EU 2018/843) and 6AMLD (EU 2018/1673)
• French Law — Monetary and Financial Code, Articles L.561-1 onwards
• BCEAO Regulation — n° 09/2017/CM/UEMOA on AML/CFT
• BEAC/CEMAC Regulation — n° 01/CEMAC/UMAC/CM of April 11, 2016
• Local laws — national AML/CFT laws of Cameroon, Ivory Coast, Senegal, etc.
• UN Conventions — Vienna, Palermo, Merida and UN Security Council resolutions on sanctions

AML/CFT governance.

Money Laundering Reporting Officer (MLRO)

An MLRO is appointed at executive level, independent from commercial functions. Responsible for implementing, monitoring and ensuring effectiveness of the AML/CFT framework, and official liaison with FIUs (TRACFIN, CENTIF, ANIF).

Compliance Committee

Chaired by the CEO with MLRO, CCO, DPO, CFO and CISO. Meets monthly to review risk mapping, alerts, complex cases and validate framework evolutions.

Board of Directors

Receives a consolidated quarterly report on the AML/CFT framework and approves high-level policies.

Risk classification.

Nexus applies a Risk-Based Approach per FATF Recommendations. Every business relationship is assigned a risk rating:

Classification is dynamic, reassessed continuously based on observed transactions, regulatory updates and counterparty intelligence.

Customer due diligence (KYC / KYB).

At onboarding

Nexus systematically collects and verifies:

• Individuals — identity, date and place of birth, nationality, address, occupation, source of funds, purpose of the relationship.
• Companies — registration, statutes, legal representatives, beneficial owners (≥ 25%), capital structure, activity, sector, estimated turnover.
• Biometric verification — liveness-check selfie, comparison with ID photo using iBeta Level 2 certified algorithm.
• Document verification — OCR, forgery detection, cross-check with official registers.

Enhanced Due Diligence (EDD)

For high-risk: source-of-funds evidence, wealth declarations, MLRO-level approval, annual review.

Ongoing monitoring

The business relationship is subject to ongoing vigilance: data refresh every 5 years (standard risk) or every 12 months (high risk).

Transaction monitoring.

All transactions through Nexus infrastructure undergo real-time automated monitoring, complemented by human review for sensitive alerts.

Detection engine

• Static rules — amount thresholds, frequency, geographies, typological patterns (structuring, smurfing, layering).
• Behavioral profiling — comparing each transaction to customer baseline (expected volumes, recurring beneficiaries).
• Machine learning — anomaly detection models trained on history, validated by backtest and audit.
• FATF typologies — integration of typologies published by FATF, EGMONT and national FIUs.

Alert handling

Each alert is processed by the compliance team within 48 hours. Files escalated to MLRO receive a documented decision (dismiss, request info, SAR, termination).

Sanctions and Politically Exposed Persons (PEP) screening.

Sanctions screening

Every relationship and every beneficiary is screened in real-time against official lists:

• UN — Consolidated UN Security Council Sanctions List
• EU — Consolidated Financial Sanctions List
• OFAC — Specially Designated Nationals (SDN) and sectoral lists
• HMT — HM Treasury Consolidated List (UK)
• Local lists — national lists of the countries we operate in

Screening is refreshed daily to incorporate list updates.

PEPs

PEPs, their family members and associates undergo enhanced due diligence: MLRO-level relationship approval, source-of-funds justification, mandatory annual review.

Suspicious Activity Reports (SAR).

Per our legal obligations, Nexus files SARs with competent Financial Intelligence Units whenever a suspicion of money laundering or terrorist financing is identified.

• TRACFIN (France) — French-jurisdiction transactions
• CENTIF — National FIUs (Senegal, Ivory Coast, Benin, Mali, Burkina Faso, Togo, Niger, Guinea-Bissau)
• ANIF — National Financial Investigation Agency (Cameroon, Gabon, Chad, Congo, CAR, Equatorial Guinea)
• UTRF — Financial Intelligence Processing Unit (Morocco)

SARs are filed without delay upon MLRO analysis completion. Strict confidentiality applies: no information is communicated to the reported customer (tipping-off principle).

Asset freezing.

Upon detection of a counterparty subject to asset freezing measures, funds are immediately blocked and the competent authority is informed within legal deadlines.

Nexus has a documented procedure enabling freezing within 2 business hours of notification, with full transaction traceability.

Records retention.

Per FATF requirements and local laws, Nexus retains all supporting documents, KYC files, transaction histories and analysis reports for a minimum of 10 years from the end of the business relationship or the date of the last transaction.

Documents are stored encrypted, in certified infrastructure, with restricted and logged access (non-repudiation).

Staff training.

The effectiveness of the AML/CFT framework rests on employee skills and vigilance:

• Onboarding — mandatory AML/CFT training for all new hires, validated by assessment.
• Annual training — mandatory refresher for all employees.
• Advanced training — specialized sessions for compliance, support, sales and risk teams.
• External certifications — ACAMS, ICA, CGSS for compliance team members.
• Regulatory watch — internal newsletters, regulatory alerts, quarterly briefings.

Audit and control.

• Permanent controls — daily automated tests, key performance indicators.
• Periodic controls — quarterly compliance management review.
• Internal audit — independent annual review of the AML/CFT framework.
• External audit — biennial review by specialized independent firm.
• Regulatory examinations — full cooperation with BEAC, BCEAO, COBAC, TRACFIN and national counterparts.

Cooperation with authorities.

Nexus cooperates fully and in good faith with all competent authorities: FIUs, prudential regulators, judicial and customs authorities. We respond without delay to lawful information requests and judicial orders.

MLRO contact.

To report a suspicion or relevant information, you can also use our whistleblowing system shared across all compliance policies.