πŸ” Legal Document

KYC / AML
Policy

This policy sets out the Know Your Customer and Anti-Money Laundering standards applied by Mutual Life Africa across all products, currencies, and regions.

Effective: 1 June 2026
Version 1.0
FATF Aligned
Mutual Life Africa
Contents
01 Introduction

Mutual Life Africa is committed to preventing its products and services from being used for money laundering, terrorist financing, fraud, or any other financial crime. This policy establishes the Know Your Customer (KYC) and Anti-Money Laundering (AML) framework applied across all Mutual Life Africa products, platforms, and regions.

Mutual Life Africa operates in multiple jurisdictions and is subject to applicable financial crime prevention legislation in each. This policy is aligned with the Financial Action Task Force (FATF) recommendations and applicable national legislation including, but not limited to, South African Financial Intelligence Centre Act (FICA), United States Bank Secrecy Act requirements, and applicable European Union AML directives.

Compliance with this policy is mandatory for all customers, group administrators, and entities seeking to access Mutual Life Africa products and services.

02 Scope

This policy applies to:

All individual policyholders across funeral cover, life cover, and group cover products
All group administrators and organisations holding group policies
All credit facility applicants and borrowers
All registered beneficiaries receiving claim payments
All users of the Mutual Life Africa app and Mutual Africa Pay platform
Any entity or individual transacting with Mutual Life Africa across any supported currency or region
03 KYC Requirements

All customers must complete KYC verification before a policy can be activated, a credit facility can be disbursed, or a claim payment can be processed. The following information is required:

RequirementAcceptable Documents
Proof of identityValid national ID card, passport, or government-issued identity document
Date of birthAs confirmed on the identity document
NationalityAs stated on the identity document
Contact detailsValid email address and phone number
Residential addressRequired for credit applicants and high-value policy applications

Organisations. Group administrators and business policyholders must additionally provide proof of business registration, including a certificate of incorporation or equivalent, and identity verification for the named group administrator.

KYC is a legal requirement. Mutual Life Africa is legally obligated to verify the identity of all customers. Policies cannot be activated and claims cannot be paid until KYC verification is complete.
04 Verification Process

Mutual Life Africa uses a combination of self-service digital verification and authorised third-party identity verification to complete KYC checks.

Self-service verification. Customers may complete identity verification directly through the Mutual Africa Pay platform by submitting their identity document and completing the required verification steps. This process is available to all customers across all supported regions.

Third-party verification. Where additional verification is required, or where self-service verification cannot be completed, Mutual Life Africa uses an authorised third-party identity verification provider. The third-party provider conducts independent checks against identity databases and applicable watchlists. Personal data shared with the third-party provider is governed by binding data processing agreements.

Verification timeline. Standard KYC verification is completed within 1 to 3 business days of submission. Where additional documentation or manual review is required, Mutual Life Africa will notify the customer by email and provide a revised timeline.

05 Enhanced Due Diligence

Enhanced Due Diligence (EDD) is applied to higher-risk customers and transactions. EDD may be triggered by any of the following:

The customer is identified as a Politically Exposed Person (PEP) or is closely associated with a PEP
The customer is based in or transacting from a high-risk jurisdiction as identified by FATF
The transaction value exceeds applicable reporting thresholds
Unusual transaction patterns or activity inconsistent with the customer's profile are detected
Automated or manual screening flags a potential match against sanctions or watchlists

Where EDD is required, Mutual Life Africa may request additional documentation, delay policy activation or claim payment pending review, and in some cases decline the application or transaction.

06 AML Obligations

Mutual Life Africa is committed to detecting and preventing money laundering and terrorist financing. The following AML controls are applied across all products and transactions:

Transaction monitoring β€” All premium payments, claim payouts, and credit disbursements are monitored for unusual patterns or amounts inconsistent with the customer's profile.
Suspicious activity reporting β€” Where a transaction or customer behaviour raises reasonable suspicion of money laundering or terrorist financing, Mutual Life Africa will file a Suspicious Activity Report (SAR) or equivalent with the relevant financial intelligence authority.
Tipping off prohibition β€” Mutual Life Africa is legally prohibited from informing a customer that a suspicious activity report has been filed or that they are under investigation. This is a legal requirement and not a matter of discretion.
Source of funds β€” For large transactions or higher-risk customers, Mutual Life Africa may request evidence of the source of funds used for premium payments.
07 Sanctions Screening

All customers, group administrators, and beneficiaries are screened against applicable international sanctions lists and watchlists at the time of onboarding and on an ongoing basis. These include:

United Nations Security Council sanctions lists
United States Office of Foreign Assets Control (OFAC) lists
European Union consolidated sanctions list
United Kingdom HM Treasury financial sanctions list
South African Financial Intelligence Centre (FIC) watchlists
Sanctioned individuals and entities. Mutual Life Africa is legally prohibited from providing insurance, financial services, or any other products to individuals or entities listed on applicable sanctions lists. Any application from a sanctioned person will be declined and reported to the relevant authority.
08 Ongoing Monitoring

KYC and AML compliance is not limited to onboarding. Mutual Life Africa conducts ongoing monitoring of all active accounts and policies to ensure that customer profiles remain accurate and that no unusual activity goes undetected.

Periodic re-verification. Mutual Life Africa may request updated KYC documentation from existing customers periodically or where a material change in the customer's profile or activity is identified. Customers are required to respond to re-verification requests within 30 days. Failure to respond may result in policy suspension.

Profile changes. Customers must notify Mutual Life Africa of significant changes to their circumstances, including changes of name, nationality, or country of residence, that may affect their KYC or risk profile.

09 KYC Failure & Refusal

Mutual Life Africa reserves the right to decline, suspend, or terminate any application, policy, or transaction where KYC verification cannot be satisfactorily completed. This includes where:

The customer fails to provide required documentation within the specified timeframe
Documentation provided cannot be verified as authentic
The customer matches a sanctions list or watchlist entry
Reasonable grounds exist to suspect money laundering, fraud, or terrorist financing
The customer refuses to provide required information

Where a policy is declined or terminated for KYC reasons, Mutual Life Africa will notify the customer by email. Premiums paid for periods during which cover was active will not be refunded. Mutual Life Africa is not obligated to disclose the specific reason for a KYC-related refusal where doing so would constitute tipping off.

No exceptions. KYC requirements apply to all customers regardless of relationship, policy value, or length of tenure. Mutual Life Africa does not grant KYC exemptions.
10 Record Keeping

Mutual Life Africa retains KYC and AML records in accordance with applicable legal requirements. All identity documents, verification records, transaction records, and compliance screening outcomes are retained for a minimum of 5 years from the date of account closure, and for a minimum of 10 years where a suspicious activity report has been filed.

Records are stored securely and are accessible only to authorised compliance personnel and regulatory authorities where legally required. All record retention and disposal is conducted in accordance with Mutual Life Africa's Data Protection and Sharing policy.

11 Data Protection

Personal information collected for KYC and AML purposes is processed in accordance with Mutual Life Africa's Data Protection and Sharing policy, the Protection of Personal Information Act (POPIA), and the General Data Protection Regulation (GDPR) where applicable.

KYC data is used solely for identity verification, compliance screening, and legal reporting purposes. It is not used for marketing and is not shared beyond what is required for regulatory compliance.

Where KYC verification is conducted through the Mutual Africa Pay platform or a third-party provider, personal data shared is governed by binding data processing agreements that require equivalent standards of data protection and security.

Customers have the right to access their KYC records held by Mutual Life Africa by submitting a written request to privacy@mutuallife.africa. Requests will be fulfilled within 30 days, subject to identity verification and any applicable legal restrictions on disclosure.

12 Contact
Compliance enquiries
KYC and AML queries
For all KYC verification queries, compliance enquiries, and data access requests related to this policy.
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