Customer due diligence

In terms of customer due diligence, the compliance team of the firm provides the following assistance/support:

  • Identifying and verifying the ‘Know Your Customer’ (“KYC”) documents of  potential and existing clients in accordance with the Financial Services Commission’s Code.
  • Name search on various international lists such as OFAC and UN Security list.
  • Advising on documents to be requested for establishing source of fund and source of wealth.
  • Advising on KYC for complex structures, entities and types of clients not referred to in the Financial Services Commission’s Code.

Risk profiling

For risk profiling, we ensure that clients are able to manage their different risks while meeting their financial and corporate objectives. Our risk profiling service includes the following:

  • Creation of a risk profile sheet to assess clients / risk profiling of clients.
  • Regular review of clients’ businesses and assessment based on their risk status.
  • Regular name screening.
  • Advise on handling high risk clients such as bankruptcy.

On-going monitoring

The Financial Services Commission aims at ensuring that the nature of business of the licensees has not changed since the date of establishment of their businesses. The compliance team of R L C can provide clients with the following services to meet this on-going requirement of the Financial Services Commission:

  • Compliance audit of clients’ businesses.
  • Review of complex arrangements.
  • Assisting the Money Laundering Reporting Officer in assessing and investigating internal report.
  • Regular report on the system and control and recommendation to eliminate any weaknesses identified.


The firm’s training programs are tailor made to meet licensees’ requirement in terms of internal procedures, compliance weaknesses which they wish to eliminate and regulatory updates and development in anti-money laundering (“AML”) and compliance.

The compliance team of the firm conducts in-house training on procedures of licensees and also on AML development locally and internationally.

Record keeping

In order to help licensees to keep all their records in accordance with applicable laws, the firm proposes to:

  • Devise a compliance monitoring record keeping system.
  • Advise on paperless record system such that the licensees remain compliant with the different laws in Rwanda.
  • Maintain anti-money laundering and combating the financing of terrorism (“AML/CFT”) training record of the employees.

Ad hoc compliance services

  • Drafting procedures manual in conformity with the Financial Intelligence Anti Money Laundering Act of Rwanda and the AML Act of Seychelles.
  • Assistance in preparing for the regulator’s visit.
  • Provision of legal updates on AML.
  • Review of application for licensees with the regulator.
  • Ad hoc compliance queries.
  • Evaluating AML/CFT process and procedures.

We are here to help and are whole-heartedly committed to your success!