Anti-Money Laundering Policy

Introduction

Anti-money laundering (AML) encompasses regulations, laws, and procedures designed to prevent criminals from disguising illegally obtained money as legal. Although AML regulations have a specific focus on financial transactions and criminal behaviour, their implications are far-reaching. For example, AML rules mandate that banks and other financial institutions that issue credit or accept customer deposits must follow guidelines to ensure they are not facilitating money laundering.

These regulations empower financial institutions to monitor customer transactions and report any suspicious financial activities. The term 'suspicious activities' can be somewhat ambiguous because it can vary from one financial transaction to another based on the circumstances surrounding the transaction or a series of transactions. For instance, a transaction by one customer might appear normal from our perspective, while a similar transaction by another customer might be considered suspicious. Several factors are considered when determining whether transactions are suspicious, including the amount, nature, and frequency of deposits/withdrawals.

CardPadi Nigeria Limited is committed to combating money laundering and fully complying with anti-money laundering laws in Nigeria. We understand our responsibilities and accept our role in the global fight against money laundering. This commitment takes precedence over all other privacy responsibilities outlined in our policies.

CardPadi will not hesitate to take all necessary and appropriate measures to prevent individuals involved in money laundering, fraud, or other financial crimes from using our products and services.

Our AML policies, procedures, and internal controls have been developed to ensure compliance with all applicable BSA regulations and FINRA rules. They will be regularly reviewed and updated to ensure that appropriate policies, procedures, and internal controls are in place to account for changes in regulations and changes in our services. Key components of our AML and Counter-Terrorism Financing (CTF) framework include the following:

Risk Management – Anti-money Laundering

We have established an independent, round-the-clock risk management team. Their primary objective is to provide regular reports to the board of directors, utilizing a risk-based approach for assessing and managing money laundering and terrorist financing risks. Our aim is to ensure full compliance with the requirements of the Money Laundering (Prohibition) Act, 2011 (as amended), Terrorism (Prevention) Act, 2011 (as amended), and Terrorism Prevention (Freezing of International Terrorists Funds and other Related Measures) Regulations 2013, along with associated laws and regulations. This commitment to rigorous risk management helps us maintain a strong stance against illicit financial activities.

Internal Control

This office is responsible for implementing procedures aimed at preventing criminals from using CardPadi's services for money laundering and terrorist financing. They also ensure that Cardvest's obligations under existing laws and regulations are fully met.

Compliance

This office has been specifically designated to oversee and coordinate day-to-day compliance with applicable legislation, regulations, rules, industry guidance, as well as money laundering laws and regulations. They help keep stakeholders informed by regularly communicating all AML (Anti-Money Laundering) issues.

They are responsible for promptly preparing and submitting all relevant reports to regulatory bodies in accordance with SEC and FIU (Financial Intelligence Unit) Rules and Regulations. Additionally, they closely monitor all transactions to detect any unusual or suspicious activities.

Customer/User Management

This is where we gather information about our users. We do so by implementing and managing a risk-based approach to Customer Due Diligence (CDD), which includes customer identification, verification, and Know Your Customer (KYC) procedures. To facilitate this, our customers/users are required to provide specific personal information when creating a CardPadi account. Additionally, they must generate tokens, OTPs (One-Time Passwords), and PINs for any withdrawal requests. The specific information and the extent of data required are determined by the customer's transactions, the account to be used, and, in some cases, the customer's country of residence.

On occasion, CardPadi may conduct heightened due diligence procedures for customers engaged in high-risk transactions, such as those involving large volumes.

Cardvest is committed to identifying and reporting any suspicious transactions diligently. Suspicious transactions may include:

1. Transactions structured to evade reporting and record-keeping requirements.
2. Transactions involving altered or false identification, inconsistent information, or any activity that CardPadi views as criminal.
3. Transactions associated with individuals or organizations considered to be involved in terrorist activities.