AML/CFT Policy

Introduction Zurafin Technologies Ltd. (hereafter, the “Company”) is dedicated to complying with all applicable laws and regulations, including those related to anti-money laundering (AML) and countering the financing of terrorism (CFT), as well as the guidelines provided by the Central Bank of Nigeria (CBN).

The objective of this policy is to establish a comprehensive framework for Zurafin Technologies Ltd.'s AML/CFT program, aiming to prevent and detect potential money laundering and terrorist financing activities.

Scope Money laundering involves the criminal process of converting illegally obtained funds into legal investments, concealing their true source. It is a global issue with severe economic, social, and political consequences. To counter this, every government fights against money laundering and terrorist financing to safeguard the economy from criminal funds.

As a financial institution, Zurafin Technologies Ltd. is aware of the vulnerabilities of its products and services, especially in digital currency services. Thus, we have implemented stringent measures to prevent money laundering and the financing of terrorism.

Our AML/CFT Policy

Risk Assessment: Zurafin Technologies Ltd. will conduct a risk assessment to identify and assess the money laundering and terrorist financing risks associated with its business. This assessment will consider the nature of the Company’s products, services, customers, geographic locations, and delivery channels. It will be regularly reviewed and updated to ensure relevance and effectiveness.

Customer Due Diligence (CDD): Zurafin Technologies Ltd. will perform customer due diligence (CDD) on all new and existing customers to verify their identity and assess the level of risk associated with the customer. Enhanced due diligence (EDD) measures will be applied to high-risk customers.

Transaction Monitoring: The Company will monitor all transactions for unusual or suspicious activity. The transaction monitoring system will identify and analyze patterns of activity indicating potential money laundering or terrorist financing. Suspicious transactions will be documented and reported to relevant authorities as required by law.

Transaction Limits: To comply with AML/CFT regulations, Zurafin Technologies Ltd. has established transaction limits for its customers based on the level of customer verification and the type of transaction. Limits may vary depending on payment method and customer location, subject to adjustments at the Company's discretion with customer notification.

Record Keeping: Zurafin Technologies Ltd. will maintain accurate and complete records of all customer transactions, retaining them for the minimum period required by law. Records may be kept longer based on the Company’s risk assessment or regulatory requirements.

Reporting: The Company will report suspicious transactions to relevant authorities as required by law and cooperate with law enforcement and regulatory authorities. Employees are required to report any suspicious activity to the designated compliance officer.

Training: Zurafin Technologies Ltd. will provide training to all employees on AML/CFT policies and procedures tailored to their job functions. Training will cover the identification and reporting of suspicious transactions.

Compliance Officer: Zurafin Technologies Ltd. has appointed a compliance officer responsible for ensuring compliance with all AML/CFT laws and regulations. The officer oversees the AML/CFT program, provides training, and ensures regular reviews and updates.

Review and Update: The AML/CFT program will be regularly reviewed and updated to maintain currency and effectiveness. The review will assess the program's effectiveness and consider changes to the regulatory environment or the Company’s business impacting the AML/CFT program.