Introduction

Saaf Services Limited is a UK based company working as Money Service Business, regulated by the FCA and HMRC. We offer Money Transfer services through our registered office for individuals intending to remit money to Afghanistan. Company is led by the Director and MLRO; Mr. Haroon Elahi. Saaf Services Limited intends to use the services of Premier Forex (Intermediary Payment Service Provider) for settling the transactions.

The purpose of this Complaint Handling Policy is to ensure all customer complaints are handled promptly, fairly, and transparently, and to use complaints as opportunities for improvement.

The purpose of this RCA Framework is to provide Saaf Services Limited with a structured, repeatable approach to investigate, identify, and eliminate the underlying causes of significant incidents, failures, non-conformities or recurring problems that affect customer outcomes, regulatory compliance, operational resilience, safety, security or financial integrity.

Purpose

The purpose of this policy is to:

• Ensure Fair and Timely Resolution of Complaints: To provide a clear, transparent, and effective process for addressing complaints from consumers and other stakeholders.
• Promote Customer Satisfaction: To maintain high levels of customer satisfaction by resolving issues promptly and fairly.
• Comply with Regulatory Requirements: To ensure that Saaf Services Limited complies with relevant regulations, including those set forth by the Financial Conduct Authority (FCA), Consumer Duty regulations, and any other applicable laws.
• Enhance Service Quality: To use feedback from complaints Saaf Services Limited’s services, and customer interactions.

Objectives of RCA Framework

The RCA framework at Saaf Services Limited aims to:

• Identify the root cause of operational failures, fraud incidents, compliance breaches, and system failures.
• Prevent recurrence by implementing corrective and preventive measures.
• Ensure regulatory compliance with FCA, HMRC, and JMLSG guidelines.
• Improve business processes by eliminating inefficiencies and vulnerabilities.
• Enhance customer experience by reducing errors and transaction failures.

Scope

This policy applies to:

• All consumers, clients, and third parties who interact with Saaf Services Limited and wish to raise a concern or complaint about the company’s products, services, or conduct.
• All employees of Saaf Services Limited who are responsible for handling complaints and ensuring that they are resolved in accordance with this policy.
• All products and services provided by Saaf Services Limited, including money remittance services and related financial services.

The RCA framework applies to:

• Regulatory Compliance Issues – Breaches of AML (Anti-Money Laundering), KYC (Know Your Customer), and financial crime regulations.
• Fraud & Security Incidents – Internal or external fraud, cyberattacks, unauthorized transactions.
• Transaction Failures – Payment processing errors, delayed transfers, system downtimes.
• Customer Complaints & Disputes – Issues raised by customers related to service failures or financial losses.
• Operational & IT Failures – System crashes, cybersecurity breaches, data loss, and infrastructure failures.

Definitions

Complaint

A complaint is defined as any oral or written expression of dissatisfaction from a customer or potential customer that relates to the products or services offered by Saaf Services Limited. This may include dissatisfaction with the quality of service, delays in money transfer, security concerns, or customer support issues. A complaint is considered valid whether or not it involves financial loss, as long as the customer feels they have suffered distress, inconvenience, or lack of proper service. By adopting this broad definition, we ensure that all feedback is treated seriously and that customers have a reliable avenue to express dissatisfaction.

Complaint Handling Process

The complaint handling process refers to the steps Saaf Services Limited follows to investigate and resolve a complaint, including receiving the complaint, acknowledging it, investigating it, and providing a resolution.

Eligible complainant

An eligible complainant is an individual or entity that can bring a complaint against a firm under the FCA’s Dispute Resolution: Complaints (DISP) rules.

The FCA defines eligible complainants as:
Consumers – Individuals acting outside their trade, business, or profession.

Non-eligible complainant

A non-eligible complainant is any individual or entity that does not meet the FCA’s criteria for an eligible complainant under the DISP rules. These complainants cannot escalate their complaints to the Financial Ombudsman Service (FOS).

How to Make a Complaint

Saaf Services Limited encourages consumers and stakeholders to raise complaints in any of the following ways:

• Contact Person: Haroon Elahi
• Email: info@saafremit.co.uk
• At Premise: 6 Burlington Parade, Cricklewood Broadway, London, England, NW2 6QG.

Complaints Handling Policy and Procedures

This policy outlines the procedures for handling complaints and conducting root cause analysis (RCA) for Saaf Services Limited, a Money Services Business (MSB). The objective is to ensure compliance with FCA regulations, improve customer satisfaction, and address systemic issues effectively. To ensure all customer complaints are handled promptly, fairly, and transparently, and to use complaints as opportunities for improvement. A complaint is any expression of dissatisfaction, whether oral or written, about the services provided by Saaf Services Limited.

Complaint-Handling Procedure

Acknowledgement

When a complaint is received, it will be acknowledged within five business days. The acknowledgment will confirm that we have received the complaint, provide a reference number for tracking, and outline the next steps in the process. This acknowledgement reassures customers that their concerns are being taken seriously and allows them to track progress if they contact us again.

Investigation Process

Once logged, the complaint will be investigated thoroughly and fairly by the Complaints Officer. Our custom-made software will be used to record complaint details, store relevant documentation, and track progress. The investigation may involve reviewing transaction records, examining customer identification and proof of address documents, and assessing whether any breach of internal policies or regulatory requirements occurred. Where needed, the Complaints Officer may contact the complainant for clarification or further evidence. The goal of this process is to ensure that all complaints are handled objectively and that customers are provided with a fair resolution.

Resolution Timeline

We aim to resolve all complaints as quickly as possible, with a maximum timeframe of eight weeks in line with FCA DISP requirements. If a resolution cannot be provided within this period due to complexity or the need for additional investigation, we will contact the customer to explain the reason for the delay and provide an updated timeline. This ensures transparency and demonstrates our commitment to resolving matters within reasonable and regulated timeframes.

Final Response

Once the investigation is complete, we will issue a final response in writing. This will clearly explain the findings of the investigation, outline whether the complaint is upheld or rejected, and specify any corrective actions or remedies offered. Remedies may include an apology, corrections to records, compensation, or adjustments to our procedures where necessary. Importantly, the final response will also explain the customer’s right to escalate the matter to the Financial Ombudsman Service (FOS) if they remain dissatisfied with our resolution.

If the complainant is not satisfied with our final response, they have the right to escalate their case to the Financial Ombudsman Service (FOS). The FOS is an independent body that helps resolve disputes between financial services firms and their customers. We will provide the customer with the Ombudsman’s contact details, including website and telephone numbers, as well as the six-month timeframe within which they must escalate their complaint. This escalation route ensures that customers always have access to an independent, fair, and impartial review process beyond our internal procedures.

Record Keeping

• Maintain detailed records of complaints for a minimum of 5 years. Include the nature of the complaint, resolution, and any follow-up actions.

 

Security & Confidentiality in Complaint Handling

The protection of customer data is at the core of our complaint-handling process. Saaf Services Limited requires customers to provide proof of ID, proof of address, and bank statements when engaging with our services, ensuring proper identification before any complaint is processed. As a registered data controller with the Information Commissioner’s Office (ICO), we comply fully with the Data Protection Act 2018 and UK GDPR requirements. Sensitive data is never shared with any unauthorised person and only authorised person have access to complaint records.

Training and Awareness

Saaf Services Limited is trained in complaint-handling procedures as part of their induction and receives refresher training on an ongoing basis. Saaf Services Limited need to log complaints correctly, handle customer concerns empathetically, and escalate matters to the Complaints Officer when necessary. Training also emphasises the importance of FCA’s Treating Customers Fairly (TCF) principles, ensuring that we understand their duty to act in the best interests of customers at all times. Through regular training and awareness sessions, we maintain a consistent culture of customer protection and regulatory compliance across the business.

Root Cause Analysis (RCA) Framework

To identify and address the underlying causes of complaints, ensuring continuous improvement and prevention of recurring issues.

RCA Process

Step 1: Data Collection

• Categorize complaints based on themes (e.g., transaction errors, communication issues, service delays).
• Use data visualization tools to identify trends and patterns.

Step 2: Analysis

• Conduct a detailed review of processes, policies, and systems related to the complaints.
• Identify gaps, inefficiencies, or compliance breaches contributing to the issues.

Step 3: Root Cause Identification

• Use techniques such as the "5 Whys" or Fishbone Diagrams to pinpoint root causes.

Step 4: Action Plan

• Develop specific, measurable, achievable, relevant, and time-bound (SMART) corrective actions.
• Assign responsibilities and deadlines for implementing improvements.

Step 5: Monitoring and Review

• Regularly review the effectiveness of corrective actions.
• Present findings and progress to senior management during monthly compliance meetings.

Roles and Responsibilities

• Ensure timely and effective resolution of complaints.
• Maintain accurate records and provide regular updates to senior management.
• Oversee the implementation of the complaint-handling policy and RCA framework.
• Allocate resources for corrective actions and training.

 

Triggers — When to Launch an RCA

An RCA will be initiated for any incident meeting one or more defined triggers:

• incidents that affect customer funds or materially delay transfers;
• security incidents or data breaches (actual or near miss);
• repeated customer complaints on the same theme (e.g., multiple KYC rejections, recurring cash reconciliation variances);
• system outages or repeated API failures causing service degradation;
• regulatory breaches, suspicious activity reports, or AML control failures;
• incidents with potential reputational damage; and
• periodic review triggers from trend analysis (e.g., a Pareto grouping showing a dominant error type). By defining these triggers, Saaf Services Limited ensures that only appropriate events escalate to a formal RCA while still capturing systemic problems early.

Reporting and Governance

Internal Reporting

• Prepare quarterly reports summarizing complaint trends, RCA outcomes, and corrective actions.
• Share reports with senior management and the compliance team.

 

External Reporting

• Report serious complaints or systemic issues to the FCA as required.
• Provide relevant complaint data during FCA reviews or audits.

Continuous Improvement

• Use customer feedback and RCA findings to improve products, services, and internal processes.
• Regularly update this policy to reflect regulatory changes and organizational learning.

The objective of the Policy is to outline how Saaf Services Limited resolves complaints in an efficient, effective, and professional manner to ensure we maintain our reputation as a professional firm responsive to client needs and concerns.