LEGAL · AML / CFT

AML / CFT framework.

BloomBridge Group operates a risk-based anti-money-laundering and counter-terrorist-financing framework across its operating brands. No transaction advances unless the counterparty screening, beneficial-owner verification, and sanctions clearance can be documented.

Last updated: 14 May 2026 · Document ID: BB-GROUP-PROFILE-2026-V6 · Validity: 12 months from issue.

1. Policy statement

BloomBridge Group is committed to preventing money laundering, terrorist financing, sanctions evasion, and the misuse of its operating platforms for illicit purposes. The Group’s policy is to: (a) know the counterparties with which it transacts; (b) understand the source of funds and source of wealth of those counterparties; (c) screen counterparties against applicable sanctions, politically-exposed-person (PEP), and adverse-media data; (d) document each step in a form that survives bank-side compliance review.

2. Regulatory anchors

The framework is calibrated against, without limitation: the United States Bank Secrecy Act and the regulations of the Financial Crimes Enforcement Network (FinCEN); United States Office of Foreign Assets Control (OFAC) regulations; Financial Action Task Force (FATF) recommendations; the United Kingdom Money Laundering Regulations 2017 (as amended); the European Union Anti-Money-Laundering directives; the Botswana Financial Intelligence Act and BoMRA expectations; and the South African Financial Sector Conduct Authority (FSCA) framework as it intersects with SADC counterparty activity. The Group operates against ICC commercial standards (NCNDA, IMFPA, ICPO, LOI, FCO, SPA) in its physical-trade vertical.

3. Counterparty due diligence (CDD)

Standard CDD

  1. Verification of legal identity — certificate of incorporation, registered address, current officers.
  2. Verification of ultimate beneficial owners (UBOs) holding 25% or more, or otherwise exercising control.
  3. Confirmation of regulatory licensing where relevant (e.g., DCC, BoMRA, FSCA, banking licences).
  4. Confirmation of source of funds and source of wealth, with bank reference where applicable.
  5. Sanctions and PEP screening against OFAC, EU, UN, UK, and CN consolidated lists.
  6. Adverse-media screening.

Enhanced due diligence (EDD)

  1. Triggered for higher-risk jurisdictions, higher-risk activity (e.g., gold doré sourcing, controlled licensed strategic trade), PEP involvement, complex ownership structures, or adverse-media hits.
  2. EDD includes deeper source-of-funds analysis, independent verification of UBO chains, on-site or third-party inspection where appropriate, and senior-management sign-off prior to onboarding.

4. Sanctions screening

All counterparties and material related parties are screened at onboarding and on an ongoing basis against the consolidated sanctions lists maintained by OFAC, the European Union, the United Nations, the United Kingdom, and the People’s Republic of China. The Group does not transact with denied parties or in respect of denied jurisdictions, end-uses, or end-users. Detailed sanctions policy is published separately at /legal/sanctions-policy.html.

5. Transaction monitoring and escalation

Transactions are monitored against the documented profile of the counterparty. Unusual or unsupported activity — including informal offers, unverifiable proof of product (POP), non-bankable proof of funds (POF), unlicensed-origin documents, or procedures that cannot survive bank compliance — is escalated and may result in suspension or termination of the engagement. The Group reserves the right to terminate any engagement on AML / CFT grounds without further explanation where doing so is consistent with applicable law.

6. Recordkeeping

CDD and EDD records, screening output, transaction documentation, and escalation files are retained for a minimum of seven (7) years from the end of the business relationship, or longer where required by applicable law or where retention is necessary to support a regulatory or law-enforcement inquiry.

7. Training and governance

The Group’s principals and counterparty-facing personnel receive periodic AML / CFT training calibrated to their roles. Overall accountability sits with the Director General and the Chief Executive Officer; operational ownership in the SADC platform sits with the Chief Executive Officer of Kalahari Agritech, whose background in regulated global banking environments (Absa, ABN Amro Quantitative Risk Management) underpins the financial-risk discipline applied locally.

8. Reporting

Where the Group is required by applicable law to report suspicious activity to a competent financial intelligence unit, it will do so promptly. The Group does not tip off the subject of a report and does not disclose the existence of a report except to the extent permitted or required by law.