Anti-Money Laundering & Know Your Customer Notice

1. How to read this page

Crowdfunding that involves the movement of investor funds and securities offerings is exposed to the same financial crimerisks as other capital–market activities. We must identify users, understand their risk profile, monitor activity, and where required, report to the Financial Intelligence Centre (FIC) and other bodies. We are not a bank and we do not give you legal advice; read this with the Risk Disclaimer and Regulatory Disclosures.

2. Legal framework (summary)

Under the Guidelines and Ghanaian law, a crowdfunding intermediary’s programme must, among other things, enable compliance with (non-exhaustive):

• Anti–Money Laundering Act, 2020 (Act 1044) and its regulations;
• Anti–Terrorism Act, 2008 (Act 762), as amended (including the Anti–Terrorism (Amendment) Act, 2014 (Act 875)); and
• Combating the financing of proliferation of weapons of mass destruction, as the law requires.

You must also comply with the Data Protection Act, 2012 (Act 843) and, where applicable, the Cybersecurity Act, 2020 (Act 1038)as they affect your use of the Platform—Ardent’s own duties under those Acts are summarised in the Privacy Policyand the SEC Guidelines’ provisions on data protection, privacy, and system integrity.

3. What the SEC Guidelines require (Guideline 15)

In substance, a licensed crowdfunding intermediary must, among other things:

• Collect and approve KYC documentation for issuers and investors, and maintain records, in the manner described below;
• Ensure that issuers do not receive funds directly from investors during the offer period (funds are processed through the prescribed channels); and
• Ensure that funds are processed electronically in line with the permitted modalities.

The way we operationalise these rules may evolve with our licence conditions, product design, and Commission guidance. Where our Terms of Useor in–app steps say something more specific, those rules apply to your account.

4. KYC, issuers (non-exhaustive)

For issuersseeking to offer securities, “KYC documentation” in the sense of the Guidelines includes (as applicable) at least:

• National Identification Card for the Directors and for all shareholders who hold more than 20% of the total shares in the issuer; and
• Proof of address for those same categories of natural persons, and the equivalentaddress evidence required for the issuer entity in line with our forms.

We will request additional documents to verify control, authority, and, where relevant, business substance of the offer (e.g. company certificates, authorisations, and materials used in the Offering Document process).

5. KYC, investors (non-exhaustive)

For investors who are natural persons, the Guidelines’ KYC list includes at least national ID and proof of address. For legal–entity investors, documentation must cover the Directors and shareholders with more than 20% of the total shares, including ID and address proof as required.

The crowdfunding intermediarymust have processes so that, in ordinary course, a prospective investor’s KYC is collected and approved before the investor is given access to the full Offering Document and beforea subscription is processed—subject tosummary information that may be shown earlier as the Guidelines and our flows allow.

6. How offer funds are handled

6.1 No direct payment to the issuer in the offer period

Issuers are prohibited from receiving funds directly from investors during the offer period. Funds are routed in line with the escrow or trust structure and the applicable payment and custodian arrangements described in the Offering Document and the Regulatory Disclosures page. This protects investors and helps evidence the flow of funds for AML/audit.

6.2 Electronic processing

The Guidelines require that funds be processed only electronically in the manner of the permitted modalities of the transaction. We do not support arrangements that are outside our approved rails.

7. When verification applies

We may require identification and supporting documents at onboarding, before a threshold is reached, before your first investment, or when you change payment methods, profile data, or risk factors. We may also re–verify periodically, or on alert from our monitoring tools or our partners. Issuers and users must respond honestly and promptlyto information requests. Failure to do so can delay or block access—see refusal below.

8. Screening and ongoing monitoring

We and our partners use automated and manual tools to check identities and to screen (where appropriate) sanctions, politically exposed persons (PEP), and other risk lists. We monitortransactions and behaviour for patterns that may suggest financial crime. Where risk iselevated, we may require source of funds or wealth information, additional documentation, or a senior review before completing an activity. We may rely on third–partypayment or infrastructure providers—their rules also apply in addition to ours.

9. Reporting, suspicious transactions, and tipping off

If we are required by law to file a suspicious transaction reportor other report with the FIC, law–enforcement, or a regulator, we will do so. These reporting obligations are separate from customer complaints. The law may criminalise “tipping off”(telling a person that they are, or are about to be, reported in a way that could prejudice an investigation). That means that in some situations we cannot tell you whya payment was blocked or an account is restricted—even if the delay is frustrating. If you need help on a service issue (e.g. a bug), use the Complaints & Dispute Resolution process; for serious or urgent financial crimeconcerns, contact the FIC in line with the FIC’s public guidance.

FIC: fic.gov.gh.

10. Refusal, suspension, and exit

We may refuse to onboard, delay or block a transaction, orterminate or suspend a relationship if we cannot complete verification, if information is inconsistent, if a sanctions or risk hit cannot be resolvedto our satisfaction, or if we consider the financial–crime risk to be unacceptable or a breach of law. Where the Guidelines require us to reject investors from prohibited jurisdictions for retail participation inoffshore offerings, we will implement those controls. Nothing in this notice limits our rights in the Terms of Use.

11. Record keeping

The Guidelines require a crowdfunding intermediary to keep and preserve certain records (including in relation to KYC, offer documentation, and platform activity) for a period of at least seven (7) years (from the time specified in the instrument), at the principal place of businessin Ghana—with equivalent duties where cloud or third–party storage is used. We retain and destroy personal data in line with the Privacy Policy and legal minima, including for AML/audit. See also complaintsfor record–keeping on feedback.

12. Data protection

Personal data collected for AML, KYC, and audit is processed in accordance with the Privacy Policy, the Data Protection Act, 2012 (Act 843), and, where applicable, the Cybersecurity Act, 2020 (Act 1038), and the data protection and security provisions of the SEC Guidelines. You have rights in relation to your data, subject to legal and security exceptions (e.g. where disclosure would be unlawful).

13. Platform complaints vs. FIC and SEC

Service complaints, bugs, and disputes about the Platform’s operations should be directed through our complaints channel first. Conduct of licence holders andsecurities–market concerns may in appropriate cases be brought to the attention of the SEC. Money–laundering or terrorism–financing suspicion (not ordinary banking errors) is a matter for law– enforcement and the FIC’sprocesses—not a substitute for the complaints mailbox.

14. Contact

Compliance: compliance@ardentafrica.com
General: hello@ardentafrica.com