Anti-Money Laundering (AML) Policy

1. Introduction

Koinpoint is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our procedures and controls to ensure compliance with applicable laws and regulations, including the Money Laundering (Prevention and Prohibition) Act of Nigeria and other relevant legislation.

2. Compliance Framework

Our AML compliance program includes:

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
• Know Your Customer (KYC) verification procedures
• Transaction monitoring and reporting
• Suspicious Activity Reporting (SAR)
• Record keeping and retention
• Staff training and awareness
• Risk assessment and management

3. Customer Identification and Verification

3.1 KYC Requirements

All customers must complete KYC verification before accessing our services. We collect and verify:

• Full name and date of birth
• Government-issued identification (National ID, International Passport, Driver's License)
• Bank Verification Number (BVN)
• National Identification Number (NIN)
• Biometric verification (facial recognition)
• Proof of address (utility bill, bank statement)
• Source of funds documentation

3.2 Enhanced Due Diligence

Enhanced Due Diligence (EDD) is required for high-risk customers, including those with large transaction volumes, politically exposed persons (PEPs), and customers from high-risk jurisdictions.

4. Transaction Monitoring

We monitor all transactions for suspicious activities, including:

• Unusual transaction patterns or volumes
• Transactions inconsistent with customer profile
• Rapid movement of funds (structuring)
• Transactions with high-risk jurisdictions
• Multiple small transactions to avoid reporting thresholds
• Transactions involving sanctioned individuals or entities

5. Suspicious Activity Reporting

We are required by law to report suspicious activities to the appropriate authorities, including the Nigerian Financial Intelligence Unit (NFIU) and other relevant regulatory bodies. We will file Suspicious Activity Reports (SARs) when we have reasonable grounds to suspect money laundering or terrorist financing.

6. Sanctions Screening

We screen all customers and transactions against international sanctions lists, including those maintained by the United Nations, United States Office of Foreign Assets Control (OFAC), and other relevant authorities. We will not process transactions involving sanctioned individuals or entities.

7. Record Keeping

We maintain comprehensive records of:

• Customer identification and verification documents
• All transactions (crypto, utilities, gift cards)
• KYC and CDD documentation
• Suspicious activity reports
• Correspondence with customers and authorities

Records are retained for a minimum of 5 years from the date of the last transaction or account closure, as required by law.

8. Transaction Limits

The following transaction limits apply based on KYC level:

• Level 0 (Unverified): No transactions allowed
• Level 1 (Basic): Limited transactions up to ₦50,000 per day
• Level 2 (Verified): Transactions up to ₦500,000 per day
• Level 3 (Enhanced): Higher limits subject to additional verification

9. Prohibited Activities

The following activities are strictly prohibited:

• Money laundering
• Terrorist financing
• Fraud and financial crimes
• Tax evasion
• Transactions with sanctioned entities
• Structuring transactions to avoid reporting requirements

10. Account Suspension and Closure

We reserve the right to suspend or close accounts that are suspected of money laundering, terrorist financing, or other illegal activities. We may also freeze funds pending investigation and report the matter to relevant authorities.

11. Staff Training

All staff members receive regular training on AML compliance, recognizing suspicious activities, and their obligations under applicable laws and regulations. Training is conducted annually and updated as needed to reflect changes in regulations and best practices.

12. Cooperation with Authorities

We fully cooperate with law enforcement agencies, regulatory authorities, and financial intelligence units in investigations related to money laundering, terrorist financing, and other financial crimes. We will provide information and documentation as required by law and court orders.

13. Customer Cooperation

Customers are required to cooperate with our AML procedures, including providing accurate information, responding to requests for additional documentation, and reporting any suspicious activities they may encounter. Failure to cooperate may result in account suspension or closure.

14. Updates to Policy

This AML Policy may be updated from time to time to reflect changes in laws, regulations, or our procedures. We will notify customers of material changes by posting the updated policy on our website and updating the "Last updated" date.

15. Contact Information

For questions or concerns regarding our AML Policy, please contact:

• AML Compliance Officer: aml@koinpoint.com
• Support: support@koinpoint.com
• Phone: +2348000000000