AML & Sanctions

1. Our position in the chain

We licence software on a subscription. We do not take deposits, issue credit, execute payments, exchange currency, or act as an agent for anyone doing those things. We are not a reporting institution under the Rwandan anti-money-laundering framework in the way a bank, insurer, mobile-money operator or dealer in precious metals is.

What we do hold is records. Books kept in our product may later be read by an auditor, a lender, the Rwanda Revenue Authority or an investigator, and we build the product on the assumption that those records must stand up.

2. Our commitments

• We do not knowingly provide the Service to anyone using it to disguise the origin of funds.
• We do not accept payment for subscriptions from sources we cannot identify, or in cash amounts designed to avoid a paper trail.
• We keep an audit trail on financial records in the product, and we do not offer a way to erase it.
• We cooperate with lawful requests from Rwandan authorities, and we act on valid court orders.
• Our team is briefed on the warning signs relevant to software of this kind.

3. Know your customer

When you subscribe we collect and keep, proportionate to the plan and the risk:

• Legal name of the organisation, and its TIN and VAT registration where applicable
• Name, role and contact details of the person who signs up and of the billing contact
• The payment instrument or bank account used for subscription payments
• For larger or higher-risk accounts, evidence of registration and of who ultimately owns or controls the organisation

We may ask for this information before activating or continuing an account. If it is refused, we may decline to onboard or may suspend the subscription.

4. Sanctions screening

We do not knowingly do business with a person or entity subject to United Nations sanctions, or to sanctions applicable to us under Rwandan law. Where a customer, a beneficial owner or a payment route is implicated by those measures, we decline or discontinue the relationship and, where required, report it.

Our screening covers our own customers and their subscription payments. It does not extend to the customers and suppliers you record in your books — that remains your responsibility under section 7.

5. What we will not do

• Build or enable features whose purpose is to hide, backdate or destroy transaction history
• Provide a second set of books designed to be shown to a different reader than the real one
• Remove or rewrite audit trails on request
• Accept a subscription payment from a jurisdiction or party we are prohibited from dealing with

6. How the product helps you comply

• Every financial posting carries a user, a timestamp and a revision history
• Corrections are made as traceable adjusting entries rather than silent edits
• Customer and supplier master records keep identifying details, including TIN
• EBM-backed purchases are flagged, so undocumented cost is visible rather than buried
• Cash, bank and mobile-money movements are reconcilable against statements
• Role-based access means an approval can be evidenced, not assumed

7. Your obligations

If your own business is a reporting institution, or is otherwise subject to AML and sanctions rules, those duties stay with you: customer due diligence, screening your counterparties, record retention, and reporting suspicious transactions to Rwanda's Financial Intelligence Centre. Our software supports good record-keeping; it does not discharge a legal obligation that the law places on you, and nothing on this page is legal or compliance advice.

8. Reporting a concern

If you believe the Service is being misused — by another user, by someone inside your own organisation, or by anyone claiming to act for us — write to info@opa.rw with “AML concern” in the subject. Reports are handled confidentially, reviewed by management, and escalated to the competent Rwandan authority where the law requires it. We do not retaliate against anyone who raises a concern in good faith.