Last updated: 07/01/2026

This AML and CTF Policy outlines the measures implemented to prevent the use of the platform for money laundering, terrorist financing, fraud, or other financial crimes.

The platform is committed to complying with applicable anti money laundering laws, regulations, and best practices in Nigeria and other jurisdictions where services are provided.

1. Purpose of This Policy

The purpose of this policy is to:

• Prevent the misuse of the platform for illegal or illicit activities
• Detect and report suspicious transactions and behavior
• Ensure compliance with applicable AML and CTF laws and regulations
• Protect users, partners, and the integrity of the financial system

2. Regulatory Framework

This policy is informed by and aligned with:

• Nigerian anti money laundering laws and regulations
• Guidance issued by relevant Nigerian regulatory authorities
• Financial Action Task Force (FATF) recommendations
• Applicable laws and standards in other African jurisdictions where services are offered

The platform adapts its AML controls to meet jurisdiction specific requirements where applicable.

3. Risk Based Approach

The platform applies a risk based approach to AML compliance.

This means that controls, monitoring, and reviews are proportionate to the level of risk presented by:

• Users
• Transaction types
• Geographic locations
• Payment methods
• Blockchain networks and assets involved

Risk assessments are reviewed periodically and updated as necessary.

4. Customer Due Diligence (CDD)

4.1 User Identification

All users are required to complete identity verification before accessing transaction features.

This includes the collection and verification of:

• Full legal name
• Date of birth
• Contact information
• Government issued identification
• Selfie or biometric verification where applicable

4.2 Enhanced Due Diligence (EDD)

Enhanced due diligence may be applied to higher risk users or transactions, including but not limited to:

• High transaction volumes
• Unusual transaction patterns
• High risk jurisdictions
• Politically exposed persons where applicable

EDD measures may include additional document requests or manual reviews.

5. Transaction Monitoring

The platform monitors transactions on an ongoing basis to identify suspicious activity.

Monitoring includes:

• Crypto deposit behavior
• Fiat payout patterns
• Fiat to crypto purchase activity
• Frequency and size of transactions
• Use of multiple bank accounts
• Rapid movement of funds

Automated and manual controls are used to detect anomalies and potential red flags.

6. Blockchain Risk and Wallet Screening

The platform uses reputable blockchain intelligence and risk assessment tools to evaluate crypto transactions.

This includes:

• Screening wallet addresses for risk exposure
• Identifying links to known scams, hacks, or illicit activity
• Assessing transaction proximity to flagged addresses

Transactions identified as high risk may be delayed, reviewed manually, or rejected in accordance with internal policies and legal obligations.

7. Sanctions and Watchlist Screening

Users and transactions may be screened against applicable sanctions lists and watchlists, where required by law.

If a match or potential match is identified, appropriate action is taken, which may include transaction blocking or reporting to authorities.

8. Suspicious Activity Reporting

Where suspicious activity is identified, the platform will:

• Document the activity internally
• Conduct further review and analysis
• Report the activity to relevant authorities where required by law

Users may not be notified of such reports where disclosure is prohibited.

9. Record Keeping

The platform maintains records of:

• User identification data
• Transaction data
• Risk assessments
• Monitoring and review actions
• Reports made to authorities

Records are retained in accordance with applicable legal and regulatory requirements.

10. Training and Awareness

Personnel involved in compliance, operations, and customer support receive appropriate training on:

• AML and CTF obligations
• Identifying suspicious activity
• Reporting procedures
• Data protection and confidentiality

Training is conducted periodically and updated as needed.

11. Roles and Responsibilities

The platform assigns responsibility for AML compliance to designated personnel or teams.

Responsibilities include:

• Implementing and maintaining AML controls
• Reviewing alerts and flagged transactions
• Ensuring regulatory reporting where required
• Keeping policies and procedures up to date

12. Third Party Relationships

Third party service providers involved in identity verification, payments, or compliance are subject to due diligence.

Contracts with such providers require adherence to applicable AML standards and cooperation with compliance reviews.

13. Enforcement and Disciplinary Measures

Failure to comply with this policy may result in:

• Transaction delays or rejection
• Account suspension or termination
• Reporting to regulatory or law enforcement authorities
• Disciplinary action for internal personnel where applicable

14. Policy Review and Updates

This AML and CTF Policy is reviewed periodically to ensure it remains effective and aligned with regulatory requirements.

Updates may be made in response to changes in laws, regulations, or risk assessments.

15. Contact and Reporting

Questions or concerns related to this AML policy may be directed through official internal or support channels.

Reports of suspicious activity may be escalated internally in accordance with established procedures.