AML Policy

1. Purpose

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy outlines SendPadi’s commitment to preventing the use of its products and services for money laundering, terrorist financing, fraud, or other illicit activities. The policy establishes the framework for compliance with applicable laws and regulations, including those of the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU), the Economic and Financial Crimes Commission (EFCC), and international standards set by the Financial Action Task Force (FATF).

This policy applies to all SendPadi employees, directors, contractors, and agents, as well as all customers, individuals and entities that conduct business with SendPadi.

2. Scope

This policy applies to all SendPadi employees, directors, contractors, and agents, as well as to all customers (individuals and businesses) who use SendPadi’s services, including:

• Cross-border money transfers.
• Airtime, data, and utility bill payments.
• Virtual cards and online payments.
• Wallet-based transactions.
• Merchant and business payments.

3. Policy Statement

SendPadi is committed to:

• Preventing money laundering, terrorist financing, and financial crime.
• Identifying, assessing, and mitigating AML/CTF risks.
• Complying with all relevant regulatory requirements in Nigeria and globally.
• Cooperating with law enforcement and regulatory authorities.
• Promoting a culture of compliance across the company.

4. Customer Due Diligence (CDD)

SendPadi will implement a Know Your Customer (KYC) framework:

• Individual Customers:
• Full name, date of birth, residential address, nationality, government-issued ID, selfie verification, and phone/email validation.
• Business Customers:
• Certificate of Incorporation, business registration details, beneficial ownership information (UBO disclosure), corporate structure, and authorized signatories.

Enhanced Due Diligence (EDD) will be applied to:

• Politically Exposed Persons (PEPs).
• Customers from high-risk jurisdictions.
• Transactions involving unusually large amounts or complex structures.

5. Transaction Monitoring

SendPadi will establish systems to detect and report suspicious activity, including:

• Unusually high-value transactions.
• Structuring (smurfing) of deposits or withdrawals.
• Rapid movement of funds in and out of accounts.
• Transactions inconsistent with customer profile.
• Activity involving sanctioned countries, persons, or entities.

6. Record Keeping

SendPadi will maintain records of:

• Customer identification and verification documents.
• Transaction history and communications.
• Reports of suspicious transactions.
• All records will be securely stored for at least 5 years in compliance with regulatory requirements.

7. Reporting Obligations

SendPadi will:

• File Suspicious Transaction Reports (STRs) with the NFIU.
• Report large cash/transaction thresholds in line with CBN/EFCC guidelines.
• Cooperate fully with law enforcement and regulators in investigations.

8. Sanctions Compliance

SendPadi will comply with international sanctions regimes, including:

• United Nations Sanctions Lists.
• OFAC (Office of Foreign Assets Control) Sanctions.
• EU and UK Sanctions Lists.

All customers and transactions will be screened against these watchlists.

9. Training & Awareness

• Mandatory AML/CTF training for all employees at onboarding and annually thereafter.
• Specialized training for compliance, risk, and customer support teams.

10. Roles & Responsibilities

• Board of Directors: Oversight and approval of AML policy.
• Compliance Officer (MLRO – Money Laundering Reporting Officer): Responsible for monitoring, reporting, and enforcing AML/CTF compliance.
• Employees: Required to adhere to the AML/CTF policy and report suspicious activity.

11. Independent Audit & Review

SendPadi will conduct periodic reviews and independent audits of its AML/CTF framework to ensure effectiveness and compliance with evolving regulations.

12. Consequences of Non-Compliance

Violations of this policy may result in:

• Immediate termination of the customer account.
• Internal disciplinary action against staff.
• Regulatory penalties, criminal charges, or reputational damage.

13. Approval & Effective Date

This policy is approved by SendPadi’s Board of Directors and is effective as of 21st September 2025. It will be reviewed annually and updated as required.