• AML/CFT: Anti-Money Laundering/Combating the Financing of Terrorism.
• Money Laundering (ML): The process through which criminals attempt to conceal the origin and/or illegitimate ownership of assets acquired from criminal activities.
• Terrorist Financing: The act of providing financial support or funds to individuals or groups involved in terrorist activities, with or without the legitimate intention of using the funds for illegal purposes.
• Customer Due Diligence (CDD): The process of identifying, verifying, and monitoring customers to ensure compliance with AML/CFT requirements, including the preservation of customer records and reporting of suspicious transactions to the relevant authorities.
• Nigeria Financial Intelligence Unit (NFIU): The Nigerian national authority for receiving, analyzing, and disseminating financial intelligence related to money laundering and terrorist financing.

Introduction

The purpose of this policy is to outline the Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) strategies for Sancus Digital Limited. As a cryptocurrency exchange and digital assets platform operating in Nigeria, Sancus Digital Limited acknowledges the importance of adhering to AML/CFT laws and regulations. We are committed to ensuring that our platform does not facilitate money laundering or terrorist financing activities.

Legal Framework

The regulatory framework governing AML/CFT in Nigeria includes:

• Money Laundering (Prevention and Prohibition) Act 2022
• Terrorism (Prevention and Prohibition) Act 2022
• Central Bank of Nigeria (CBN) AML/CFT Regulations
• Securities and Exchange Commission (SEC) Guidelines
• Nigerian Financial Intelligence Unit (NFIU) Regulations

Sancus Digital Limited will ensure full compliance with these laws and any other regulations issued by relevant authorities in Nigeria.

Risk Assessment

Sancus Digital Limited will regularly conduct a comprehensive risk assessment to identify, assess, and mitigate the risks of money laundering and terrorist financing associated with its operations, customer base, and geographic location. This process will involve:

• Evaluating the business risks posed by the nature of the platform&aos;s operations.
• Identifying customers who may present higher risk profiles, including politically exposed persons (PEPs), high-net-worth individuals (HNWIs), and customers from high-risk jurisdictions.
• Updating risk assessments to account for any changes in the business environment or operations.

Customer Due Diligence (CDD)

Sancus Digital Limited will implement robust Customer Due Diligence (CDD) procedures to ensure the proper identification and verification of all customers before allowing them to open an account or initiate transactions. The CDD measures will include:

• Identity Verification Obtaining personal information such as government-issued ID, proof of address, and other relevant documentation.
• Purpose and Nature of Relationship: Understanding the purpose of the business relationship and the source of the customer's funds.
• Risk Profiling: Assessing the customer's risk level based on factors such as transaction history location, and business activities.

For customers deemed to present a higher risk, Enhanced Due Diligence (EDD) will be conducted. This includes additional scrutiny of transactions and background checks.

Transaction Monitoring

Sancus Digital Limited will continuously monitor transactions on the platform to detect suspicious activities indicative of money laundering or terrorist financing. This will involve:

• Monitoring for unusual transaction patterns, including high-frequency or high-value transactions.
• Flagging transactions from high-risk customers or jurisdictions.
• Investigating and reporting any suspicious transactions to the relevant authorities.

The company will employ an automated transaction monitoring system, leveraging a risk-based approach to assess each transaction's risk.

Record Keeping

Sancus Digital Limited will retain records of all business activities, transactions, customer identification documents, and verification processes for a minimum of five years from the date of the transaction or the termination of the business relationship, whichever is later. These records will be readily accessible for regulatory inspections or inquiries.

Reporting

In compliance with Nigerian AML/CFT laws, Sancus Digital Limited will report suspicious activities or transactions to the Nigeria Financial Intelligence Unit (NFIU) or any other relevant authorities. Employees are required to promptly report any transactions that raise suspicion, and the company will file the necessary Suspicious Transaction Reports (STRs) as required by law.

Training and Awareness

Sancus Digital Limited is committed to ensuring that all employees receive comprehensive training on AML/CFT policies and procedures. The training will:

• Educate staff on the identification and reporting of suspicious transactions.
• Keep employees informed of emerging trends in money laundering and terrorist financing.
• Include regular refresher courses to ensure staff remain updated on regulatory changes and best practices.

Internal Controls

Sancus Digital Limited will establish effective internal controls to support compliance with AML/CFT regulations. These controls will include:

• Ongoing monitoring of business activities and transactions.
• Clear reporting lines for identifying and escalating suspicious activities.
• Regular audits of the company's policies and procedures to ensure they remain effective in mitigating risks.

Sanctions and Enforcement

Failure to comply with AML/CFT regulations can result in serious consequences, including fines, sanctions, and criminal prosecution. Violations may lead to:

• Investigations by regulatory authorities.
• Financial penalties or sanctions.
• Possible criminal liability, including imprisonment, for individuals involved in money laundering or terrorist financing.

Sancus Digital Limited maintains a zero-tolerance policy towards non-compliance with AML/CFT laws.

Conclusion

Sancus Digital Limited is fully committed to complying with all applicable AML/CFT laws and regulations in Nigeria. We will continue to review and strengthen our policies and procedures to ensure they effectively prevent and detect money laundering and terrorist financing activities. Our commitment to transparency, customer protection, and regulatory compliance is essential to maintaining trust in our platform and ensuring a secure environment for all users.