Suspicious Activity Reporting LMS
Key: Irregularity Ranking
 
Ranking 1
Grave irregularity very likely to adversely affect Safaricomís profitability or reputation or customer goodwill including irregularities that are likely to raise regulatory compliance issues or issues with respect to compliance with Safaricom KYC (Know your customer), AML (Anti-money laundry) & CTF Combating terrorist financing procedures.
Ranking 2
Serious irregularity likely to affect profitability and likely to adversely affect the reputation and customer goodwill of M-PESA.
Ranking 3
Procedural irregularities unlikely to harm Safaricomís profitability or raise regulatory compliance issues or cause loss of customer goodwill.
 
 

Offence ranking; depending on the severity/frequency offence

#
Rank
Irregularity
Ranking
Penalty
Grave Irregularities
1
1
Breaking down of deposits to earn more commission
Offence 1
 
 
 
 
 
Claw back of commissions unjustly earned.
Mandatory Suspension of offending outlets for 3 months
Suspension of all Agentís outlets for 1 months.
 
 
 
Offence 2
Termination of agency contract
Claw back of commissions unjustly earned.
Blacklisting of Agent & its principal officers
Criminal charges for fraud/ theft/obtaining by false pretences;
Civil proceedings for fraud/restitution if clawback is not possible.
2
1
False Registrations to earn undeserving commissions
Offence 1
 
 
 
 
Claw back of commissions unjustly earned.
Mandatory Suspension of offending outlets for 3 months
Suspension of all Agentís outlets for 1 months.
 
 
 
Offence 2
Termination of agency contract
Claw back of commissions unjustly earned.
Blacklisting of Agent & its principal officers
Criminal charges for fraud/ theft/obtaining by false pretences;
Civil proceedings for fraud/restitution if clawback is not possible;
3
1
Not providing float despite customer giving cash/e-money
 
Giving customer less cash/e-money than what is due to them
Offence 1
Termination of agency contract.
Reimburse customer. Safaricom to transfer from Agent float Criminal charges for fraud/theft/obtaining by false pretences;
Blacklisting of Agent & its principal officers
4
1
Charging customers for registrations
 
 
 
Offence 1
 
 
 
 
Warning letter
Reimburse customer. Safaricom to transfer from Agent float
Suspension of offending assistant/outlet for 3 months
 
 
Charging customers for transactions
Offence 2
Reimburse customer. Safaricom to transfer from Agent float
Suspension of all Agent outlets for 3 months
 
 
Charging customers for SIMEX above normal price
Offence 3
Termination of agency contract
5
1
Withdrawing customer float without their consent
 
Asking for customer M-PESA PINS
 
Fraudulent SIM swap to defraud MPESA customers
 
Apparent Collusion with criminals to facilitate withdrawal of stolen float
Offence 1
Termination of agency contract
Reimburse customer. Safaricom to transfer from Agent float
Criminal charges for fraud/theft/obtaining by false pretences;
Blacklisting of Agent and its principal officers
        Non-Compliance with CDD, AML & CTF & Customer Protection Irregularities
6
2
Not using Identification when registering customers
Offence 1
Warning letter and suspension of offending assistant/outlet for 1 month
 
 
Registration forms not duly filled and signed
Offence 2
Suspension offending Agent outlets for 1 months
 
 
 
Offence 3
Suspension of all Agentís outlets for 1 months
Suspend offending outlet for 3 months
7
2
Agents transacting without seeing customer IDs
 Agents accepting copies of IDs
Offence 1
 
 
 
Warning letter
Suspension of offending assistant/outlet for 1 week
 
 
 
Agents accepting non-authorized identification
Offence 2
Suspension offending Agent outlets for 1 months
 
 
Assistants signing registration/log books on behalf of customers and Logbooks not filled in
Offence 3
Suspension of all Agentís outlets for 1 months
Suspend offending outlet for 3 months
Procedural Irregularities
8
3
Facilitating customersí direct deposits to avoid charges/ or because customer is not registered
Offence 1
 
Warning letter and suspension of offending assistant for 3 months 
 
 
 
Offence 2
Suspension of offending outlet for 1 months
 
 
 
Offence 3
Complete withdrawal of tills
9
3
Assists sharing pins
Offence 1
Warning letter and suspension of offending assistant for 3 months
 
 
 
Offence 2
Suspension of offending outlet for 1 months
 
 
 
Offence 3
Complete withdrawal of tills
10
3
Non-compliance to 1.5X float rule (both float and cash)
Offence 1
Warning Letter
 
 
Not maintaining minimum 30,000 float
Offence 2
Suspension of offending outlet until criteria met
 
 
 
Offence 3
Suspension of all agent outlets until criteria met
11
3
Irregular relocation of tills without prior consent and audit from Safaricom
Offence 1
 
Warning letter and Suspension of offending outlet until regularized
 
 
 
Offence 2
Withdrawal of offending till
 
 
 
Offence 3
Suspension of all agent outlets for 1 month
12
3
Till applications for non existent outlets
Falsifying information to secure agent tills
Offence 1
Blacklisting from till application for 3 months
Safaricom reserves the right to change the Agent Penalties and Irregularities from time to time