AML & CFT Policy

Last updated 13 October 2025

Policy Statement

Moniass Technologies Limited (Moniass) is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in the operation of its peer-to-peer (P2P) escrow-based cryptocurrency trading platform. As a marketplace facilitator, rather than a financial institution or broker, Moniass provides users with a secure, real-time environment for crypto-fiat transactions using a request-driven negotiation model. Moniass acknowledges that the nature of digital assets and cross-border financial interactions exposes trading platforms to potential misuse for money laundering, terrorist financing, and proliferation financing. Accordingly, Moniass is fully committed to complying with the Money Laundering (Prevention and Prohibition) Act, 2022, and all applicable regulatory frameworks issued by the Central Bank of Nigeria (CBN), the Special Control Unit Against Money Laundering (SCUML), and other relevant authorities. This policy outlines Moniass’ dedication to:

  • Preventing its platform from being used for illicit financial activities.
  • Implementing robust Know Your Customer (KYC), Customer Due Diligence (CDD), and transaction monitoring mechanisms.
  • Ensuring user identification and wallet funding verification before participation in any trading activity.
  • Promoting user awareness and regulatory reporting as required under Nigerian law. Through a combination of real-time transaction controls, secure wallet infrastructure, user authentication, and regulatory alignment, Moniass aims to uphold a trusted and compliant environment for crypto-fiat exchange.

Scope

This policy applies to:

  • All employees, consultants, and contractors of MONIASS.
  • All transactions conducted via its platform and customers conducting transactions on it.
  • Clients, partners, investors, and third-party vendors associated with MONIASS’s operations.

Objectives

The objectives of the policy include:

  • Ensuring adherence to Nigerian AML/CFT regulations and standards.
  • Identifying, monitoring, and reporting suspicious activities or transactions promptly.
  • Safeguarding the MONIASS-operated platform from misuse for money laundering or terrorist financing.
  • Fostering a culture of transparency, compliance, and accountability across all operations.

Regulatory Framework

This policy adheres to the following laws and regulations:

  • Money Laundering (Prevention and Prohibition) Act, 2022.
  • CBN AML/CFT Guidelines 2022.
  • Economic and Financial Crimes Commission (EFCC) Act, 2004.
  • SCUML Directives for Designated Non-Financial Businesses and Professions.

Roles and Responsibilities

To effectively implement this AML/CFT policy, specific roles and responsibilities are assigned across MONIASS’ organisational structure to ensure accountability and seamless compliance.

Board of Directors:

The Compliance Office plays a central role in the day-to-day implementation and enforcement of the AML/CFT Policy. Responsibilities include:

  1. Monitoring adherence to AML/CFT requirements across the company’s operations and platforms.
  2. Reporting suspicious transactions or activities to the appropriate regulatory bodies, including the Nigerian Financial Intelligence Unit (NFIU) and SCUML.
  3. Developing and delivering regular training programs to employees to build awareness and ensure staff understand their AML/CFT obligations.
  4. Conducting internal audits and assessments to identify and address gaps in compliance.
  5. Liaising with external auditors and regulators on AML-related matters.

Compliance Officer:

The Compliance Officer plays a central role in the day-to-day implementation and enforcement of the AML/CFT Policy. Responsibilities include:

  1. Monitoring adherence to AML/CFT requirements across the company’s operations and platforms.
  2. Reporting suspicious transactions or activities to the appropriate regulatory bodies, including the Nigerian Financial Intelligence Unit (NFIU) and SCUML.
  3. Developing and delivering regular training programs to employees to build awareness and ensure staff understand their AML/CFT obligations.
  4. Conducting internal audits and assessments to identify and address gaps in compliance.
  5. Liaising with external auditors and regulators on AML-related matters.

Employees:

All employees are required to actively participate in maintaining the integrity of MONIASS’s AML framework. Specific responsibilities include:

  1. Strictly adhering to AML/CFT policies and procedures, including KYC (Know Your Customer) and due diligence processes.
  2. Promptly identifying and reporting any suspicious activities or transactions to the Compliance Officer.
  3. Participating in training programs to stay informed of AML/CFT regulations and MONIASS’s internal compliance protocols.
  4. Ensuring confidentiality and security of customer data as part of the due diligence process.

Know Your Customer (KYC) and Customer Due Diligence (CDD)

To prevent its platforms and services from being exploited for illicit activities, MONIASS shall implement a comprehensive KYC and CDD framework that guides the verification and monitoring of all customers and transactions in alignment with Nigerian AML/CFT regulations. a. Customer Identification: MONIASS will establish the identity of every customer before initiating any business relationship or allowing them to use the marketplace.

  1. Obtaining government-issued identification documents, such as a National ID/passport, driver’s license, or voter card, to verify the customer’s identity.
  2. Collecting key contact information, including proof of residence/registered address, sources of wealth, valid phone numbers, a functional email address, etc.
  3. Cross-checking submitted information with independent databases, where available, to ensure its authenticity.

b. Risk-Based Approach

MONIASS recognizes that different customers pose varying levels of risk. As part of its CDD measures:

  1. Customers will be categorized as low-risk, medium-risk, or high-risk based on factors such as transaction size, geographical location, and nature of transaction.
  2. High-risk customers, including politically exposed persons (PEPs) and those from high-risk jurisdictions, will undergo Enhanced Due Diligence (EDD), which includes: Gathering additional information, such as the source of funds and wealth.
  3. Obtaining senior management approval before establishing or continuing the relationship with them or permitting platform usage.
  4. Conducting more frequent transaction reviews to identify potential anomalies.

c. Verification:

MONIASS will validate all customer information through independent and reliable sources to ensure its accuracy and completeness. Verification measures include:

  1. Checking ID documents against official records.
  2. Confirming the customer’s address through utility bills or correspondence.
  3. Leveraging electronic verification systems or third-party services to corroborate information.

d. Ongoing Monitoring:

MONIASS will continuously monitor customer transactions and behaviors to detect inconsistencies, unusual patterns, or activities that may indicate money laundering or terrorist financing. Monitoring activities include:

  1. Flagging transactions exceeding predetermined values and risk categorizations.
  2. Tracking wire transfers and fund movements to/from high-risk jurisdictions or to/from high-risk profiles.
  3. Generating alerts for further investigation when suspicious activities are detected.

Record-Keeping

MONIASS is committed to maintaining detailed and accurate records of all customer information, transactions, and due diligence processes to ensure compliance with Nigerian AML/CFT regulations. These records serve as a crucial component in monitoring, reporting, and auditing activities to prevent money laundering and terrorist financing. a. Retention Period: MONIASS shall retain all records for a minimum of five years following the termination of a business relationship or the completion of a transaction, whichever is later. This includes:

i. ii. iii. Customer identification information (e.g., copies of identification documents, proof of address). Transaction records, including dates, amounts, and parties involved. Documentation of Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) measures undertaken.

b. Accessibility and Security:

i. ii. Records shall be stored in a secure and organized manner, ensuring they are protected against unauthorized access, tampering, or destruction. All records shall be easily retrievable to facilitate prompt inspection by regulatory authorities, including the Nigeria Financial Intelligence Unit (NFIU), SCUML, or other designated bodies.

c. Digital and Physical Records:

i. Where records are maintained digitally, MONIASS shall use systems that allow secure storage, retrieval, and audit trails. ii. Physical records will be stored in locked, secure locations with access limited to authorized personnel.

Suspicious Transaction Reporting

MONIASS is committed to identifying and reporting suspicious transactions to the Nigeria Financial Intelligence Unit in accordance with Nigerian AML/CFT regulations. This ensures that potential money laundering or terrorist financing activities are promptly flagged and addressed. a. Reporting Timeline: MONIASS shall report any suspicious transactions to the NFIU within 24 hours of detection. This rapid reporting requirement is critical to enabling timely intervention by authorities.

b. Definition of Suspicious Transactions:

A suspicious transaction is any activity that raises questions about its legality, origin, or purpose, especially if it deviates from a customer’s normal behavior or declared financial activities. Examples include:

  • Unusual or complex transactions significantly larger than the customer’s typical financial activity or without a clear purpose.
  • Inconsistencies with the customer’s profile. Transactions that don’t align with the customer’s stated business or financial activities.
  • Involvement with high-risk jurisdictions. Transactions linked to or routed through countries or regions identified as high-risk for money laundering or terrorist financing.

c. Internal Reporting and Investigation:

Employees must immediately report any suspicious activities to MONIASS’s Compliance Officer, who will assess the transaction and determine if it warrants reporting to the NFIU. Detailed documentation of the suspicious activity, including the rationale for reporting, must be maintained.

d. Confidentiality and Protection:

Reports to the NFIU shall remain strictly confidential, and MONIASS will not disclose the fact that a report has been made to the customer or any unauthorized party. Employees who report suspicious transactions in good faith are protected from retaliation or liability under Nigerian law. Failure to act on a Compliance Officer’s instruction may fully expose the NFIU and other regulatory authorities during any investigations that follow a reported suspicious transaction, providing all requested documentation and information.

Politically Exposed Persons (PEPs)

a. MONIASS recognizes the elevated risks associated with PEPs, including individuals holding or having held significant public positions, their close associates, and family members. f. Any suspicious transactions involving PEPs will be promptly reported to the relevant authorities as required by law. g. Employees shall receive regular training to equip them with the skills to identify and manage risks associated with PEPs, ensuring compliance with anti-money laundering laws and best practices.

b. Reliable resources, such as regulatory lists and screening tools, shall be used to identify PEPs during onboarding and throughout the business relationship.

c. Establishing or continuing a business relationship with a PEP requires prior approval from senior management and a thorough risk assessment based on factors such as the individual’s role, country of origin, and the nature of the relationship.

d. All transactions involving PEPs shall be subject to enhanced and continuous monitoring to identify unusual or suspicious activities, with periodic reviews of risk profiles to ensure up-to-date assessments.

e. Detailed records of all due diligence conducted, approvals obtained, and monitoring activities shall be maintained, ensuring adherence to Nigerian regulations.

f. Any suspicious transactions involving PEPs will be promptly reported to the relevant authorities as required by law. g. Employees shall receive regular training to equip them with the skills to identify and manage risks associated with PEPs, ensuring compliance with anti-money laundering laws and best practices.

g. Employees shall receive regular training to equip them with the skills to identify and manage risks associated with PEPs, ensuring compliance with anti-money laundering laws and best practices.

c. Due diligence on non-local PEPs:

shall be subject to Enhanced and continuous monitoring, to identify unusual or suspicious activities, with periodic reviews of risk profiles to ensure up-to-date assessments.

d. Maintenance of all due diligence conducted, approvals obtained, and monitoring:

activities shall be maintained, ensuring adherence to Nigerian regulations.

Training and Awareness

a. MONIASS shall conduct mandatory annual AML/CFT training for all employees to ensure compliance with regulatory requirements and promote awareness of money laundering risks.

b. Training topics will include identifying suspicious transactions, understanding KYC procedures, and adhering to relevant laws and regulations.

c. All new employees shall receive comprehensive AML/CFT induction training during onboarding to familiarize them with MONIASS’s policies and procedures.

d. Refresher training and updates will be provided regularly to address changes in regulations, emerging risks, and advancements in compliance practices.

Third-Party Management

a. MONIASS shall perform due diligence on third-party vendors, contractors, and partners to assess their compliance with AML/CFT requirements.

b. All agreements with third parties must include clauses mandating adherence to AML regulations and cooperation in risk management efforts.

Technology and Automation

a. MONIASS will leverage automated systems to enhance the efficiency and accuracy of its AML/CFT processes.

b. Automated tools shall be used to monitor transactions for unusual patterns or suspicious activities, ensuring timely detection and response.

c. Technology will automate Know Your Customer (KYC) procedures and verification processes, improving client onboarding and risk assessment.

d.The systems shall also generate detailed reports to support compliance efforts and regulatory reporting requirements.

Sanctions Compliance

a. MONIASS shall screen all customers and transactions against both international and local sanctions lists to ensure compliance with applicable regulations. b. Any transactions involving sanctioned individuals, entities, or jurisdictions shall be promptly frozen or restricted, in line with legal and regulatory requirements.

b. Any transactions involving sanctioned individuals, entities, or jurisdictions shall be promptly frozen or restricted, in line with legal and regulatory requirements.

Disciplinary Action

a. Any employee, contractor, or partner found in violation of this policy will be subject to disciplinary action, which may include termination of employment or contract.

b. In cases of serious non-compliance, the matter will be reported to the relevant legal and regulatory authorities for further action.

Reporting to SCUML and Regulatory Authorities

a. MONIASS shall ensure timely registration with the Special Control Unit against Money Laundering (SCUML) as required by law.

b. Periodic compliance reports, as mandated by relevant authorities, shall be submitted to ensure ongoing adherence to regulatory requirements.

Review and Update

This policy will be reviewed annually or as may be required by changes in laws and regulations.