Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy

Effective Date: 5th of April, 2025

Billpago Digital Integrated Limited (“CIPAGO”) is committed to full compliance with applicable Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) laws and regulations in Nigeria, including but not limited to the Central Bank of Nigeria (CBN) AML/CFT Regulations 2022, the Money Laundering (Prevention and Prohibition) Act, 2022, EFCC SCUML directives, and Financial Action Task Force (FATF) standards.

1. Purpose

This AML/CFT Policy establishes a framework to prevent, detect, and report money laundering, terrorist financing, and other financial crimes within our operations. It outlines responsibilities of the Board of Directors, management, employees, and the appointed AML Compliance Officer (AMLCO).

2. Scope

This policy applies to all directors, employees, contractors, agents, and partners of CIPAGO, and covers all products, services, and business relationships.

3. Governance & Responsibilities

• Board of Directors – Provides oversight and approves this AML/CFT Policy.
  • Ayola Awosemo, Director
• AML Compliance Officer (AMLCO) – Responsible for daily AML/CFT compliance, reporting, training, and liaison with regulators.
  Appointed AMLCO: Lydia Fashade
• Employees – Must adhere to this policy, conduct due diligence, and promptly escalate suspicious activities.

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

CIPAGO conducts CDD and Enhanced Due Diligence (EDD) in accordance with Nigerian AML/CFT laws. Requirements include:

• Verifying customer identity with government-issued ID, BVN, and proof of address.
• Identifying and verifying beneficial owners of corporate customers.
• Applying enhanced checks for Politically Exposed Persons (PEPs) and high-risk customers.

5. Risk-Based Approach

CIPAGO applies a risk-based approach to AML/CFT compliance. Customers, products, services, and geographies are risk-rated (low, medium, high) and controls applied proportionately.

6. Transaction Monitoring & Reporting

We monitor transactions for unusual, inconsistent, or suspicious activity. In line with CBN and SCUML directives:

• Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs) are filed promptly with the Nigerian Financial Intelligence Unit (NFIU).
• Automated and manual reviews are conducted to identify red flags.

7. Record Keeping

All KYC records, transaction data, and internal reports are retained for a minimum of five (5) years as required by law.

8. Sanctions, Screening & Blacklists

All customers and transactions are screened against:

• United Nations (UN) Sanctions Lists
• Office of Foreign Assets Control (OFAC) Lists
• CBN, EFCC, and SCUML domestic watchlists
• Adverse media checks

9. Training & Awareness

CIPAGO provides mandatory AML/CFT training to all staff annually, including awareness on red flags, reporting obligations, and consequences of non-compliance.

10. Independent Audit & Review

An independent internal or external audit of AML/CFT controls shall be conducted annually to assess compliance effectiveness and identify gaps.

11. Disciplinary Actions

Employees, agents, or partners who violate this policy will face disciplinary actions, including termination of employment or business relationships, and possible legal prosecution.

12. Policy Review

This AML/CFT Policy shall be reviewed annually, or sooner if there are regulatory changes, new risk factors, or operational developments.