Anti-Money Laundering (AML) and Counter-Terrorist Financing Policy

Last updated: 10 August 2026

Makumbi Phone Store does not allow its website, applications, wallet, or payment services to be used for money laundering, terrorist financing, fraud, or any other unlawful activity. This policy applies to customers, accounts, wallet deposits, withdrawals, refunds, orders, and payment-provider transactions.

1. Customer identification and verification

We may collect and verify customer information needed to provide our services and manage financial risk, including a customer’s name, phone number, email address, account details, and, where reasonably required, reliable identification or other supporting information. Customers must provide accurate information and must not use anonymous, false, or fictitious account details.

2. Wallets are tied to the depositing phone number

Every wallet deposit is linked to the mobile-money phone number that made the deposit. Only that same phone number may withdraw from the wallet.

Makumbi Phone Store does not allow cross-phone-number wallet transactions, transfers to another person’s number, or withdrawals to a different phone number from the one that funded the wallet. This control applies even where another person claims to have permission to receive the funds.

3. Risk-based checks

We may assess the risk associated with a customer, transaction, payment method, product, or delivery arrangement. Higher-risk, unusual, complex, or high-value activity may require additional information, source-of-funds or purpose-of-transaction details, enhanced verification, management review, or additional monitoring before we process it.

4. Prohibited activity

• Using another person’s phone number, account, identity, or payment instrument without lawful authority.
• Moving wallet funds between different phone numbers or requesting a third-party withdrawal.
• Breaking transactions into smaller amounts to avoid review or verification.
• Using the Platform for proceeds of crime, fraud, scams, terrorist financing, sanctions evasion, or unlawful trade.
• Providing false, misleading, or incomplete information during registration, payment, withdrawal, or review.

5. Ongoing monitoring and red flags

We may review transaction patterns and account activity for unusual or suspicious behaviour, including rapid deposits followed by withdrawal requests, repeated use of multiple phone numbers, activity inconsistent with the customer’s profile, unexplained third-party funding, unusual transaction patterns, or attempts to bypass our controls.

6. Sanctions, politically exposed persons, and high-risk relationships

Where appropriate and legally required, we may apply additional checks to high-risk customers or relationships, including politically exposed persons, persons connected to sanctioned parties, or activity involving high-risk jurisdictions. We may decline or restrict a transaction where required by law or where the risk cannot be reasonably managed.

7. Suspicious activity reporting and confidentiality

We may investigate, hold, decline, or suspend a transaction or account where we identify concerns. Where required by applicable law, suspicious activity may be escalated to the appropriate authorities, including the Financial Intelligence Authority. We may be prohibited from telling a customer that a suspicious transaction report or related review has been made.

8. Records and retention

We maintain appropriate records of customer information, transactions, reviews, decisions, and communications so activity can be reconstructed when necessary. Records are protected and retained for the period required by applicable Ugandan law; where the AML record-keeping provisions apply, the minimum period is generally ten years.

9. Data protection

Information collected for AML, fraud-prevention, payment, and legal purposes is handled confidentially and used only for legitimate operational, regulatory, security, or legal purposes, subject to our Privacy Policy and applicable law.

10. Compliance responsibilities

Makumbi Phone Store will maintain reasonable internal procedures and controls proportionate to the size and risk of its services. Relevant personnel and service providers may receive appropriate guidance, and controls may be reviewed and updated when risks, products, technology, or legal requirements change.

11. Refunds and withdrawals

Approved wallet withdrawals and applicable refunds are processed only to the original depositing phone number, subject to the applicable payment-provider rules, wallet terms, and any required verification. We do not redirect wallet funds or refunds to a different phone number at a customer’s request.

12. Policy basis and updates

This policy supports Makumbi Phone Store’s fraud-prevention and AML/CFT controls. It does not replace applicable law, regulatory guidance, payment-provider rules, or professional legal advice. We may update this policy when our services, risks, or legal obligations change.

For the applicable Ugandan framework, customers may consult the Financial Intelligence Authority guidance and the Anti-Money Laundering Act.

13. Contact

For questions about this policy, contact Makumbi Phone Store:

Tel / WhatsApp: +256701777777

Email: makumbiphonestore@gmail.com