Sammy Nyaga

Company Overview: Centiwise, Nairobi, Kenya.

Legal and Compliance Associate.

• Focused on corporate KYC/KYB, risk management, regulatory compliance, Contract Review, Corporate Entity registry and management, Strategic Expansion, Support to Business; Customer care; Management and the Board, Policy development and review, Company incorporation and partners law firms management.

Corporate KYC & KYB ONBOARDING

• Conducted comprehensive corporate KYC onboarding, including KYB(Know your Business), KYC for directors, shareholders, and Ultimate Beneficial Owners (UBO).
• Managed Enhanced Due Diligence (EDD) for high-risk corporate clients.
• Risk Management; Development and maintaining the company's risk register, high-risk client, and PEP registers.
• Prepare onboarding report on clients onboarded that month and which are high risk and or have PEPs.

Transaction Monitoring

• I have developed and prepared Country Transaction monitoring report to check for barred country Transaction as per our blacklisted country list (based on FATF, global sanctions list)
• I developed and prepared the Merchant monitoring report, broken into merchant specific business for risk classification, such as Forex business reports to monitor high risk High volume merchant businesses as well as clients activity generally.
• I monitor high value transactions to prevent AML or Terrorism financing by prepare High value client reports based on KYC onboarding of High net worth individuals and later transaction monitoring where certain clients consistently move high volumes.
• I prepare Chargebacks reports and chargeback ratios for clients to better guide business and customer support on which merchants need to increase volume or reduce instances of Chargebacks.
• I prepare reports on clients declined transactions to monitor for fraud errors, client breaches of card rules to protect the company by blocking the card or mobile number.

Policy development, review and Register

• Authored and periodically updated the companies policies; Risk Management Policy, Business Continuity Policy, Board Charter, Anti Corruption and Bribery have been developed and approved.
• Reviewing; HR manuals(hiring and separation, leave, sexual harassment, remuneration, per diem policies), Chargebacks policies, Technology and IT policy among others to be developed and later reviewed.
• I also developed and periodically updated the companies policies; Legal
• I offer advice on regulatory and legal matters during meetings.
• I prepare reports on CMA proposed regulations and guidelines for senior management.
• I prepare responses for CMA request for comments on new guidelines.
• I prepare requests for no objections by the CMA for appointment of key personnel such as the 4 year appointment of internal auditors.
• I prepare responses for the Kenya Revenue Authority (KRA) request for withheld tax for clients that come in due to the nature of the company business.
• I prepare reports of the legal and regulatory health of the company.

Reporting & Compliance

• Generated weekly, monthly, quarterly, and annual reports, including:
• Corporate register for all Centiwise companies across Africa, their regulatory filings status, their tax status, their legal and regulatory filings(business permit, resident director among others)
• Contract registers : specifically; tracking all active contracts and contracts nearing renewal date, periodic review of long term contracts to check if they still meet business needs.
• Reviewing the contract register to find key pain points in Service agreements with clients that are contentious and developing strategies on how to better structure said agreements for both current and future clients.
• Regulatory filings and compliance reports; including annual FRC compliance reporting, Minimum Operating Capital reporting per Central Bank of Kenya (CBK)Monthly , Legal health of company weekly and monthly report, client complaint report and regulatory changes report for senior management.

Cross-functional Collaboration

• Register new companies in Kenya, Africa and Mauritius.Set up local business license, set up bank accounts, manage directors.
• Partnered with the business department for client onboarding, contract reviews, NDA review and resolution of client complaints.
• Supported strategic partnership department for NDAs, pricing, and contract negotiations.
• Collaborated with management on strategic projects, including expansion into new regions, including establishment of new companies in those regions as well as managing partner law firms in those countries.

Training

• Developed and conducted in-house training on KYC/onboarding, data protection, PEP review, and fair client treatment.
• Created training materials aligned with Kenyan law, data protection regulations, and UK GDPR(post Brexit) and EU GDPR standards.
• Assisted in maintaining a culture of ethical conduct by providing training on relevant laws, regulations, and company policies.
• Implemented a centralized system for tracking regulatory inquiries, improving response times and overall efficiency in addressing concerns raised by regulators or clients.

Company Overview: EGM Securities, Nairobi, Kenya

Compliance

• I prepare reports on onboarded clients to enable post onboarding client monitoring
• I prepare reports on client KYC profiles for further review in cases of Politically Exposed Persons and Adverse media hits.
• I prepare for review reports on the risk profile of clients for senior management (Compliance Manger and Managing Director).
• I prepare internal compliance report for review by the compliance Manager for presentation to the Boards quarterly and annual compliance review.
• I perform internal compliance review of company marketing materials.
• I perform internal client monitoring for suspicious transactions from the payments department.

Legal

• I prepare contracts for 3rd party services such as service level agreements with our liquidity providers, services for office maintenance and utilities among all other contract related agreements such as parking, purchase of appliances.
• I review the company's internal policies annually to ensure they remain relevant, up to date and compliance with regulations which may or may not have changed such as the data protection and client handling policies.
• I review and ensure annual contracts that are up for renewal are suitable and favourable for the company.
• I offer advice on regulatory and legal matters during meetings.
• I prepare reports on CMA proposed regulations and guidelines for senior management.
• I prepare responses for CMA request for comments on new guidelines.
• I prepare requests for no objections by the CMA for appointment of key personnel such as the 4 year appointment of internal auditors.
• I prepare responses for the Kenya Revenue Authority (KRA) request for withheld tax for clients that come in due to the nature of the company business.
• I prepare reports of the legal and regulatory health of the company.

KYC

• I conduct Simplified and Enhanced Due diligence of clients to be onboarded.
• I ensure the clients submitted documents are authentic and match the clients details.
• I ensure the clients risk profile is acceptable and contact management in the event their risk is profile is high.
• I have onboarded 45 thousand clients to date.
• Conducted regular reviews of company policies and procedures for alignment with regulatory requirements and industry best practices.

Company Overview: Capital Markets Authority of Kenya, Nairobi, Kenya

Approvals and Licensing Department

• I undertook to prepare reports on the suitability of applications for; fund manager, investment advisor, stock broker and Investment Bank ensuring they fell in line with regulations.
• I prepared reports for the approval committee and presented the same to the committee on the suitability of an applicant.
• I prepared reports on the suitability and fitness of a proposed key personnel in an licensed market intermediary.
• I prepared reports on approval of a licensed entities proposed advertisement for review by the approvals department manager.
• I prepared and dispatched letters of no objections for approval of key personnel to licensed entities.
• I prepared reports on matters of legal importance as instructed my management and senior officers, such as a report on the International Organization of Securities Commissions(IOSCO) MOU.
• I sat in on meetings called for the applicants to put forward their case on how and why the business model was suitable for the Kenya capital market.

Equity Department

• I prepared reports on the suitability of private transfers for stocks and bonds for approval by the approval committee.
• I prepared reports on the suitability of collective investment schemes ensuring they fell in line with regulations.

Company Overview: Aziz & Company Advocates, Nairobi, Kenya

• I prepared briefs for the advocates on their case files as instructed.
• I prepared fillings for matters such as criminal and civil case fillings.
• I prepared responses to demand letters.
• I prepared affidavit for case fillings.
• I prepared legal reports on legal cases and their effect on current matters been handled by the firm.
• Self-motivated, with a strong sense of personal responsibility.
• Excellent communication skills, both verbal and written.