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Compliance, the bedrock of our trust.
Nexera operates under the strict watch of the Central Bank of Congo and cooperates with CENAREF. Our AML/CFT framework is written, tested, and ready to be audited by any regulator, partner bank, or institution.
A framework sized to stand up to scrutiny
sections in our written AML/CFT Policy
retention of records and audit logs
international sanctions lists covered
MLRO triage SLA on every alert
Six lines of defense that talk to each other.
Each pillar maps to a chapter of our AML/CFT Policy, executed through code, process, and human review.
BCC framework
Our stack complies with Instructions 24 and 27 of the Central Bank of Congo on electronic payment services.
3-tier KYC
Progressive verification (L1 phone, L2 ID + selfie, L3 full business KYC). Each tier unlocks specific transaction limits.
AML / CFT
Real-time suspicious transaction detection via a rules engine. Escalated to MLRO then reported to CENAREF when required.
Sanctions screening
Every account is automatically screened against OpenSanctions (OFAC, EU, UN, UK/OFSI, PEP) at signup and re-screened periodically.
Logging
Every transaction is timestamped, signed, and retained for 10 years. Full audit trail available to BCC or any auditor.
Data protection
TLS 1.3 in transit, AES-256 at rest. No data leaves the continent without explicit user consent.
We align with the standards that matter.
Central Bank of Congo
DRC regulator
CENAREF
DRC Financial Intelligence Unit
FATF
International standards
OFAC · EU · UN · UK OFSI
Sanctions lists
OpenSanctions.org
Consolidated dataset
Wolfsberg Group
Banking best practices
A formal, binding, signed document.
- 15 sections covering legal framework, governance, risk-based approach, CDD, PEPs, sanctions, monitoring, STR, training, audit, and annual review.
- Adopted and signed by the Managing Director. Reviewed at least annually.
- Applies to all employees, officers, and contractors with access to payment systems.
SODOTECH SARL
AML / CFT Policy
Version 1.0
≈ 10 pages
Annual review
Signé par
Henock BARAKAEL
Compliance Officer · SODOTECH SARL
Statut
Adoptée
A single point of contact for authorities.
Interim Money Laundering Reporting Officer (MLRO)
Henock BARAKAEL
Nexera Compliance Officer · Operations under SODOTECH SARL
Mandat
- Interface with the Central Bank of Congo, CENAREF, partner banks, and auditors.
- Receipt, analysis, and decision on every AML / CFT / sanctions alert.
- Suspicious transaction reporting (STR) to CENAREF within statutory deadlines.
- Annual policy review and compliance report to the Board.
A dedicated MLRO will be recruited as soon as transaction volume justifies it (> EUR 100k monthly TPV).
Report suspicious activity.
Merchant, employee, partner, or citizen: if an activity looks abnormal on Nexera, write to us confidentially. We systematically protect the identity of whistleblowers.
Where we stand, where we are heading.
AML/CFT Policy v1.0 adopted
Written, signed by the MD, published internally. OpenSanctions screening deployed on every new signup.
OpenSanctions API key activation
Shift from manual fallback to real-time automatic screening with daily delta updates.
Annual AML training
Certified training session for employees, contractors, and Board. Renewed every year.
Independent external audit
Commissioned annually with a qualified firm. Report shared with regulators and PSP partners.
Dedicated MLRO recruitment
Formal split of MD / MLRO roles once monthly TPV exceeds EUR 100k.
BCC EMI license application
Mid-term goal aligned with commercial trajectory and regulatory framework.
You represent an institution?
Bank, PSP, regulator, auditor: we gladly share our full Policy, our risk matrix, and evidence of execution. A call with the MLRO can be scheduled within 5 business days.
Write to compliance@nexera.africaThis page publicly summarizes our framework. It does not replace the written AML/CFT Policy, which is the binding document.