AML & Compliance Policy.

Effective Date: April 1, 2025
Document Owner: LiquidPay Africa Ltd. — Compliance Function

1. Our Position

LiquidPay Africa Ltd. is committed to operating in full compliance with all applicable Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations in Nigeria and South Africa. We do not directly hold funds or process payments — however, we recognize our responsibility as a technology intermediary to ensure our platform is not misused.

All financial transactions facilitated by our platform are executed by licensed financial institution partners who maintain their own AML/CTF programs in compliance with the Central Bank of Nigeria (CBN) and the South African Reserve Bank (SARB).

2. Regulatory Framework

Our compliance approach is aligned with, but not limited to:

• CBN Anti-Money Laundering & Combating the Financing of Terrorism (AML/CFT) Regulations
• SARB Financial Intelligence Centre Act (FICA)
• The Financial Action Task Force (FATF) Recommendations
• The Money Laundering (Prevention and Prohibition) Act, Nigeria (2022)
• South Africa's Financial Intelligence Centre Amendment Act (2017)

3. Know Your Customer (KYC)

All users of the LiquidPay platform are required to complete identity verification before initiating any transfer. Our KYC process includes:

• Identification: Government-issued ID (BVN for Nigeria, SA ID or passport for South Africa)
• Proof of address: Where applicable and required by our licensed partners
• Enhanced Due Diligence (EDD): Applied for higher-risk profiles, including politically exposed persons (PEPs) and high-volume accounts

KYC verification is performed at onboarding and reviewed periodically. Users who do not maintain current, valid verification will be restricted from initiating transfers until resolved.

4. Transaction Monitoring

Transactions on the LiquidPay platform are subject to automated monitoring for patterns inconsistent with a user's profile, jurisdiction, or stated purpose. Flagged transactions may be:

• Reviewed by our compliance team before processing
• Delayed pending additional user information
• Declined where sufficient information cannot be obtained
• Reported to the relevant Financial Intelligence Unit (FIU) as required by law

5. Sanctions Screening

All users and beneficiaries are screened against applicable sanctions lists prior to transfer execution. These include lists maintained by the UN Security Council, OFAC (US), the EU, and equivalent Nigerian and South African authorities. Any match will result in immediate transaction blocking and regulatory reporting.

6. Suspicious Activity Reporting (SAR)

Where LiquidPay or its licensed partners identify reasonable grounds to suspect money laundering or terrorism financing, a Suspicious Activity Report (SAR) will be filed with the relevant authority — the Nigerian Financial Intelligence Unit (NFIU) or the South African Financial Intelligence Centre (FIC) — as applicable. We are legally prohibited from disclosing the existence of a SAR to any party.

7. Record Keeping

In accordance with regulatory requirements, LiquidPay and its licensed partners retain all customer data, transaction records, and compliance documentation for a minimum of 5 years from the date of the transaction or account closure, whichever is later.

8. Staff and Partner Obligations

All personnel with access to user data and transaction systems receive AML/CTF training appropriate to their role. Our licensed financial partners are selected in part based on the robustness of their own AML/CTF programs and are contractually bound to maintain these standards.

9. Contact

If you have concerns about suspicious activity, or questions about our compliance approach, contact our compliance team at: compliance@liquidpay.africa