Company terms & Compliance policy
Last modified on 28 May, 2025
Compliance Policy
Introduction
Bixi LTD ("the Company") operates the eDir mobile application, a platform that enables users to exchange money between USSD-based mobile wallets including EVC Plus, eDahab, Zaad, Sahal, eBesa, Premier Wallet, and other supported providers. The Company operates in collaboration with telecommunications operators, banks, and mobile money service providers in Somalia.
This Compliance Policy establishes the framework through which Bixi LTD ensures its operations comply with all applicable laws, regulations, and international best practices, including the Somalia Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Law 2016 and Central Bank of Somalia directives.
Objectives
The primary objectives of this Compliance Policy are:
- To prevent the eDir platform from being used for money laundering, terrorist financing, fraud, or other financial crimes
- To establish robust Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures for all users conducting wallet-to-wallet exchanges
- To implement transaction monitoring systems that detect suspicious patterns across supported wallet providers
- To comply with all applicable laws, regulations, and directives from the Central Bank of Somalia, Financial Reporting Center, and relevant telecommunications regulatory bodies
- To foster a culture of compliance across all business operations
Know Your Customer (KYC) Procedures
All users must complete identity verification before using eDir's exchange services. The KYC process includes:
Basic Verification (Tier 1):
- Full legal name
- Phone number (linked to USSD wallet)
- Date of birth
Enhanced Verification (Tier 2):
- Government-issued photo ID (National ID, Passport, or Driver's License)
- Selfie verification for identity matching
- Proof of address (where applicable)
Higher transaction limits require enhanced verification. Users who fail to complete verification within the required timeframe will have their accounts restricted.
Customer Due Diligence (CDD)
Risk-Based Approach: eDir applies a risk-based approach to CDD, categorizing users into risk levels based on transaction volume, frequency, geographic factors, and behavioral patterns.
Standard Due Diligence: Applied to all users during onboarding and periodically thereafter, including verification of identity and source of funds for transactions above defined thresholds.
Enhanced Due Diligence (EDD): Applied to high-risk users, including those with:
- Unusually high transaction volumes or frequency
- Transactions involving multiple wallet providers in rapid succession
- Politically Exposed Persons (PEPs)
- Users flagged by our monitoring systems
Business Accounts: Additional due diligence is required for businesses using eDir, including verification of business registration, ownership structure, nature of business, and expected transaction patterns.
Transaction Monitoring
Bixi LTD implements continuous transaction monitoring across all supported wallet providers to identify suspicious activities, including:
- Transactions exceeding defined thresholds for daily, weekly, and monthly limits
- Rapid sequential exchanges between multiple wallet providers (structuring/layering)
- Unusual patterns inconsistent with the user's profile or stated purpose
- Transactions involving flagged or sanctioned individuals
- Round-tripping (exchanging funds back and forth without apparent economic purpose)
Suspicious transactions are automatically flagged for review by the compliance team. Where required, Suspicious Transaction Reports (STRs) are filed with the Financial Reporting Center.
Transaction Limits
eDir enforces the following transaction limits to mitigate risk:
- Unverified users: Limited functionality until KYC is completed
- Tier 1 verified users: Standard daily and monthly transaction limits
- Tier 2 verified users: Elevated limits based on enhanced verification
All limits are subject to review and may be adjusted based on regulatory requirements, risk assessment, or at the Company's discretion. Users approaching or exceeding limits will be notified and may be required to provide additional documentation.
Compliance Officer
Bixi LTD appoints a Chief Legal and Compliance Officer (CLCO) with responsibility for:
- Overseeing implementation of this Compliance Policy across all operations
- Ensuring compliance with the Central Bank of Somalia regulations and AML/CTF requirements
- Managing relationships with regulatory authorities and responding to regulatory inquiries
- Reviewing and updating compliance procedures to reflect regulatory changes
- Overseeing the investigation of flagged transactions and filing of regulatory reports
- Reporting to the Board of Directors on compliance matters
Training and Awareness
All employees receive mandatory compliance training upon hiring and annually thereafter, covering:
- AML/CTF obligations under Somali law
- KYC procedures and red-flag indicators for suspicious activity
- Data protection and customer privacy requirements
- Reporting procedures for suspected violations
Training records are maintained and regularly audited. Employees who fail to complete required training will be restricted from performing compliance-sensitive functions.
Record Keeping
Bixi LTD maintains comprehensive records in accordance with regulatory requirements:
- Customer identification and verification records: retained for a minimum of 5 years after the end of the business relationship
- Transaction records: retained for a minimum of 5 years from the date of the transaction
- Compliance reports, STRs, and internal investigations: retained as required by the Central Bank of Somalia and Financial Reporting Center
All records are stored securely with appropriate access controls and are available for inspection by regulatory authorities upon request.
Sanctions Compliance
eDir screens all users and transactions against applicable sanctions lists, including:
- United Nations Security Council sanctions lists
- Relevant regional and national sanctions lists
- Lists maintained by the Financial Reporting Center of Somalia
Any matches or potential matches are escalated to the Compliance Officer for immediate review and appropriate action, which may include freezing the account and reporting to the relevant authorities.
Reporting & Whistleblowing
Bixi LTD encourages employees and partners to report suspected compliance violations without fear of retaliation. Reports can be made to:
- The Chief Legal and Compliance Officer directly
- Through the Company's confidential reporting channel
All reports are investigated promptly and confidentially. The Company prohibits retaliation against anyone who reports suspected violations in good faith.
Conclusion
Bixi LTD is committed to maintaining the highest standards of compliance and integrity in operating the eDir money exchange platform. This policy reflects our dedication to protecting our users, partners, and the broader financial system from misuse, while enabling safe and efficient money exchange between mobile wallets in Somalia.
This policy is reviewed annually and updated as necessary to reflect changes in regulations, business operations, or risk environment.
Last updated: March 2026
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