Legal & Compliance

1. Introduction

These Terms and Conditions (“Terms”) govern your access to and use of the website, digital platforms, mobile applications, and financial services provided by Avenir MFB SARL (“Avenir Microfinance”, “we”, “our”, or “us”). By accessing our website or applying for or using our services, you agree to be legally bound by these Terms. If you do not agree, you must not use our services.

2. Company Information

Avenir MFB S.A.R.L is a limited liability company incorporated under the laws of the Democratic Republic of Congo and operating in compliance with applicable financial regulations, including those of the Central Bank of Congo (Banque Centrale du Congo – BCC), where applicable.

3. Eligibility

To use our services, you must: be at least 18 years old; be legally capable of entering into a binding contract; provide accurate and complete information; possess valid identification documents; and not be subject to legal or regulatory restrictions. We reserve the right to refuse service at our discretion, subject to applicable laws.

4. Services Provided

Avenir Microfinance provides digital microloans, short-term consumer or SME credit, loan management services, and digital account access for credit services. All loans are subject to approval based on internal credit assessment criteria. Approval is not guaranteed.

5. Loan Application and Approval

By submitting a loan application, you authorize us to verify your identity, authorize us to conduct credit checks, and confirm that all information provided is true and accurate. We reserve the right to approve or reject any application, adjust loan amounts, adjust interest rates based on risk assessment, and request additional documentation. Loan terms will be clearly disclosed before acceptance.

6. Interest, Fees and Charges

Interest rates, service fees, and penalties will be disclosed prior to loan acceptance. You agree to pay the principal loan amount, applicable interest, administrative fees (if any), and late payment penalties (if applicable). Failure to repay may result in additional recovery costs as permitted by law.

7. Repayment Obligations

You agree to repay your loan on or before the agreed due date, ensure sufficient funds are available in designated payment channels, and notify us promptly of any payment difficulties. Late payments may result in penalty charges, reporting to credit reference bureaus, and legal recovery action.

8. Default

You will be considered in default if you fail to make payment when due, provide false information, or breach any provision of these Terms. In case of default, we may demand immediate repayment, report to credit bureaus, initiate recovery proceedings, and suspend access to services.

9. User Responsibilities

You agree not to use our services for unlawful activities, not to attempt fraud or misrepresentation, to maintain confidentiality of login credentials, and to notify us immediately of unauthorized account access. You are responsible for all activity conducted under your account.

10. Privacy and Data Protection

Your personal data is processed in accordance with our Privacy Policy. By using our services, you consent to data verification, credit bureau reporting, and regulatory disclosures where required.

11. Intellectual Property

All website content, branding, logos, software, and materials are the property of Avenir MFB SARL. You may not copy, modify, distribute, reverse engineer, or reproduce any materials without written permission.

12. Limitation of Liability

To the extent permitted by law: we are not liable for indirect or consequential losses; we are not responsible for service interruptions caused by third-party providers; and we are not liable for delays due to force majeure events. Our maximum liability shall not exceed the outstanding loan amount involved in the dispute.

13. Suspension or Termination

We may suspend or terminate your access if you violate these Terms, if we suspect fraudulent activity, or if required by law or regulation. Termination does not eliminate repayment obligations.

14. Regulatory Compliance

Avenir Microfinance operates in compliance with applicable financial laws and regulatory requirements in the Democratic Republic of Congo, including anti-money laundering (AML) and know-your-customer (KYC) obligations. Users agree to cooperate with compliance requirements.

15. Dispute Resolution

In case of dispute, parties agree to attempt amicable resolution first. If unresolved, disputes shall be subject to the jurisdiction of the competent courts of the Democratic Republic of Congo. Applicable law: Laws of the Democratic Republic of Congo.

16. Amendments

We may amend these Terms at any time. Updated versions will be published on our website with a revised effective date. Continued use of services constitutes acceptance of the updated Terms.

17. Contact Information

1. Introduction

This Loan Terms and Disclosures document outlines the key terms, conditions, costs, and borrower obligations applicable to all credit facilities granted by Avenir MFB SARL. This document forms part of the Loan Agreement executed between Avenir MFB SARL and the Borrower.

2. Nature of Services

Avenir MFB SARL provides digital microcredit loans, short-term working capital loans, and SME and consumer loans. Avenir MFB SARL does not collect public savings or deposits unless specifically licensed to do so under applicable laws. All loans are subject to internal credit approval.

3. Loan Amount

• Minimum Loan Amount: USD 100
• Maximum Loan Amount: USD 5,000

Loan approval amounts depend on credit assessment, repayment capacity, and risk profile.

4. Interest Rates

Interest is charged on a flat rate basis unless otherwise stated in the Loan Agreement. The applicable interest rate will be clearly disclosed before loan acceptance.

5. Loan Tenure

Loans are granted for a period between a minimum of 1 month and a maximum of 24 months. The specific tenure is agreed upon at the time of loan approval and depends on the product tier.

6. Repayment Terms

Repayment may be structured as monthly installments (principal + interest), or bullet repayment (where applicable). Borrowers are required to pay installments on or before the due date and maintain sufficient funds in designated repayment channels. Early repayment is permitted and may be subject to specific conditions disclosed in the Loan Agreement.

7. Fees and Charges

The following fees may apply: a processing or administrative fee of 1% of the total loan amount; late payment penalties of 0.5% per day; recovery costs (where legally permitted); and legal enforcement costs (if applicable). All applicable fees will be disclosed prior to loan acceptance.

8. Late Payment and Default

A loan shall be considered in default if payment is not made by the due date, if false or misleading information was provided, or if the Borrower breaches any term of the agreement. Consequences of default may include late payment penalties, reporting to credit reference bureaus, suspension of future loan eligibility, and legal recovery proceedings.

9. Early Repayment

Borrowers may repay the loan before maturity. Where applicable, interest may not be recalculated unless specified, and early repayment fees (if any) will be disclosed in advance.

10. Credit Reporting

By accepting a loan, the Borrower consents to credit checks prior to approval, reporting of repayment performance to authorized credit reference bureaus, and sharing of default information as required by law.

11. Borrower Responsibilities

The Borrower agrees to provide accurate and truthful information, notify Avenir Microfinance of any material changes in financial condition, use the loan for lawful purposes, and comply with all contractual obligations.

12. Risk Disclosure

Borrowers are advised that failure to repay may negatively affect credit history, loan obligations are legally enforceable, and late payments may increase total repayment cost. Borrowers should carefully assess repayment ability before accepting a loan.

13. Data Protection

Personal data is processed in accordance with Avenir MFB SARL’s Privacy Policy and applicable data protection laws.

14. Regulatory Compliance

Avenir MFB SARL operates in compliance with applicable financial regulations of the Democratic Republic of Congo, AML laws, KYC requirements, and Central Bank regulatory oversight (where applicable).

15. Complaints and Dispute Resolution

In case of complaint, Borrowers may contact Avenir MFB SARL customer service. If unresolved, the matter may be referred to competent authorities or courts in the Democratic Republic of Congo. Governing Law: Laws of the Democratic Republic of Congo.

16. Borrower Acknowledgment

By signing the Loan Agreement or accepting a digital loan offer, the Borrower confirms that the loan terms were clearly explained, the interest rate and total repayment amount were disclosed, all questions were answered satisfactorily, and the Borrower understands the repayment obligations.

1. Our Commitment

Avenir MFB SARL is committed to promoting responsible, transparent, and ethical lending practices in support of financial inclusion in the Democratic Republic of Congo. We recognize that access to credit must be balanced with the borrower’s ability to repay without experiencing undue financial hardship. Our lending practices are guided by integrity, fairness, and respect for our clients.

2. Affordability and Credit Assessment

Before granting any loan, Avenir MFB SARL conducts a thorough assessment of the client’s repayment capacity; evaluates income sources, cash flow, and existing financial obligations; reviews credit history where available (including credit bureau data where applicable); and ensures that loan size and tenure are appropriate to the client’s financial situation.

3. Prevention of Over-Indebtedness

To protect clients from excessive debt, we apply prudent debt-to-income and cash-flow analysis standards, verify existing borrowing obligations, encourage responsible borrowing and discourage multiple concurrent loans, and provide financial education and clear repayment guidance. Our objective is sustainable lending relationships, not short-term loan volume growth.

4. Transparent Pricing and Disclosure

Avenir MFB SARL ensures that all loan terms are clearly explained before disbursement, including loan amount, interest rate, total cost of credit, fees and charges (if any), repayment schedule, and consequences of late payment. All loan agreements are provided in clear and understandable language. Clients are given adequate time to review terms before signing.

5. Fair and Respectful Treatment

We treat all clients with dignity and respect, without discrimination based on gender, ethnicity, religion, social status, or background. Our staff are trained to provide accurate and honest information, avoid coercive sales practices, and maintain professionalism at all times.

6. Ethical Collection Practices

In the event of late repayment, we follow structured and respectful recovery procedures. We do not use intimidation, harassment, or abusive practices. We seek constructive solutions such as restructuring where appropriate, and we respect client confidentiality during collection processes.

7. Data Protection and Confidentiality

Client information is treated as confidential and used strictly for legitimate business and regulatory purposes. We comply with applicable data protection laws and regulatory requirements in the Democratic Republic of Congo.

8. Complaints and Dispute Resolution

Avenir MFB SARL maintains a formal complaints handling mechanism that allows clients to submit complaints through accessible channels, ensures timely investigation and resolution, and records and monitors complaints to improve service quality. Clients are informed of their right to escalate unresolved matters to relevant regulatory authorities where applicable.

9. Regulatory Compliance

Avenir MFB SARL operates in compliance with the laws and regulations governing microfinance institutions in the Democratic Republic of Congo and under the supervision of the Banque Centrale du Congo (BCC).

10. Continuous Improvement

We regularly review our lending policies, procedures, and staff training programs to ensure alignment with best practices in responsible finance and financial inclusion.

1. Policy Statement

Avenir MFB SARL is fully committed to preventing its products and services from being used for money laundering, terrorist financing, fraud, or any other financial crime. The institution adopts a zero-tolerance approach to financial crime and operates in full compliance with the laws and regulations of the Democratic Republic of Congo and directives issued by the Banque Centrale du Congo (BCC). This policy establishes the framework for identifying, assessing, monitoring, and reporting suspicious financial activities.

2. Legal and Regulatory Framework

This policy is implemented in accordance with applicable AML/CFT laws of the Democratic Republic of Congo, regulations and circulars issued by the Banque Centrale du Congo (BCC), and international standards set by the Financial Action Task Force (FATF). Where regulatory requirements evolve, this policy shall be updated accordingly.

3. Scope of Application

This policy applies to directors and shareholders, senior management, all employees and agents, and consultants and third-party service providers acting on behalf of Avenir MFB SARL. All staff are required to strictly adhere to this policy.

4. Governance and Oversight

4.1 Board of Directors

The Board is responsible for approving the AML/CTF policy, ensuring adequate resources are allocated, and overseeing implementation and compliance.

4.2 Compliance Officer / AML Officer

A designated AML Compliance Officer shall monitor implementation of this policy, ensure regulatory reporting, maintain suspicious activity records, liaise with regulators and competent authorities, and provide staff training. The AML Officer shall have sufficient independence, authority, and access to information.

5. Risk-Based Approach

Avenir MFB SARL adopts a risk-based approach by identifying and assessing ML/TF risks related to products, customers, delivery channels, and geography; classifying customers into low, medium, or high-risk categories; and applying enhanced due diligence measures where risk is elevated. Periodic institutional risk assessments shall be conducted at least annually.

6. Customer Due Diligence (CDD)

6.1 Customer Identification

Before establishing a business relationship, Avenir MFB SARL shall verify the identity of customers using reliable, independent documents; obtain and verify identification documents (national ID, passport, or legally acceptable alternatives); record proof of address where required; and identify beneficial owners for legal entities. No anonymous or fictitious accounts are permitted.

6.2 Enhanced Due Diligence (EDD)

Enhanced measures shall be applied to Politically Exposed Persons (PEPs), high-risk clients, unusual or complex transactions, and clients from high-risk jurisdictions. EDD may include additional source of funds verification, senior management approval, and increased transaction monitoring.

6.3 Ongoing Monitoring

The institution shall monitor customer transactions for unusual patterns, review high-risk accounts periodically, and update customer information regularly.

7. Politically Exposed Persons (PEPs)

Special procedures apply to domestic and foreign PEPs: identification at onboarding, senior management approval before relationship establishment, and ongoing enhanced monitoring.

8. Suspicious Transaction Reporting (STR)

If an employee identifies a suspicious transaction, the matter must be immediately reported internally to the AML Officer. The AML Officer shall review and determine whether an STR must be filed with the competent authority.

9. Record Keeping

Avenir MFB SARL shall maintain customer identification records for at least 10 years after the end of the relationship, retain transaction records for at least 10 years, and ensure records are accessible for regulatory inspection.

10. Sanctions Compliance

The institution shall screen customers against applicable sanctions lists, refuse or freeze transactions involving sanctioned individuals or entities, and immediately report matches to competent authorities.

11. Staff Training

All employees shall receive AML/CTF induction training upon hiring, annual refresher training, and specialized training for high-risk functions. Training shall include identification of suspicious transactions and reporting obligations.

12. Internal Controls and Audit

Avenir MFB SARL shall maintain clear segregation of duties, internal control procedures, periodic independent internal audits of AML compliance, and corrective action plans where deficiencies are identified.

13. Confidentiality

All AML-related investigations and reports shall remain strictly confidential. Unauthorized disclosure is subject to disciplinary action.

14. Non-Compliance and Disciplinary Measures

Failure to comply with this policy may result in internal disciplinary action, termination of employment, or legal or regulatory sanctions.

15. Policy Review

This policy shall be reviewed annually or whenever regulatory changes occur.

1. Purpose

Avenir MFB SARL is committed to protecting the confidentiality, integrity, and availability of all customer, employee, and institutional data. This Security & Data Protection Policy outlines the technical, organizational, and administrative safeguards implemented to ensure that all data is securely collected, processed, stored, and transmitted in compliance with applicable laws and regulatory requirements.

2. Scope

This policy applies to all employees, directors, contractors, and third-party service providers; all customer data (KYC, financial records, transaction data); all internal company data; and all digital platforms, mobile applications, servers, and physical records.

3. Types of Data Collected

• Personal identification information (name, ID, address, phone number)
• Financial information (income, credit history, transaction records)
• Biometric or digital verification data (where applicable)
• Device and usage data for digital services
• Corporate and employee records

4. Data Protection Principles

Avenir MFB SARL adheres to the following principles: lawfulness, fairness, and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality; and accountability.

5. Technical Security Measures

5.1 Encryption

End-to-end encryption for data transmission (SSL/TLS protocols), encryption of sensitive data at rest, and secure encryption key management procedures.

5.2 Access Control

Role-based access control (RBAC), multi-factor authentication (MFA) for critical systems, strong password policies and periodic reset requirements, and automatic session timeout mechanisms.

5.3 Network Security

Firewalls and intrusion detection/prevention systems, secure cloud hosting environments (where applicable), and regular vulnerability scanning and penetration testing.

5.4 Data Backup & Recovery

Automated daily backups, secure off-site or encrypted cloud backups, disaster recovery and business continuity planning, and regular recovery testing.

6. Organizational Security Measures

6.1 Staff Confidentiality

Mandatory confidentiality agreements, background checks for sensitive roles, and continuous training on cybersecurity and data protection.

6.2 Data Access Governance

Access granted strictly on a need-to-know basis, immediate revocation of access upon termination, and regular access rights reviews.

6.3 Third-Party Risk Management

Due diligence on technology vendors, data processing agreements with service providers, and contractual confidentiality and security obligations.

7. Physical Security

Controlled office access, locked cabinets for sensitive documents, CCTV monitoring where applicable, and secure server and IT equipment rooms.

8. Incident Response & Breach Management

Avenir MFB SARL maintains a formal incident response procedure that includes immediate containment and investigation, risk assessment and impact analysis, regulatory reporting where required, customer notification if necessary, and remedial action and system improvements. All security incidents are logged and reviewed by management.

9. Data Retention

Data is retained only for as long as necessary to fulfill contractual obligations, comply with regulatory requirements, and support legal and audit obligations. Upon expiry of retention periods, data is securely deleted or anonymized.

10. Customer Rights

Customers have the right to request access to their personal data, request correction of inaccurate data, request deletion where legally permissible, and withdraw consent where applicable. Requests must be submitted formally to Avenir MFB SARL’s compliance department.

11. Regulatory Compliance

Avenir MFB SARL operates in accordance with applicable data protection laws in the Democratic Republic of Congo, Central Bank regulatory requirements, AML and KYC standards, and international best practices for information security.

12. Policy Review

This policy is reviewed annually or whenever significant operational or regulatory changes occur.