Anti-Money Laundering Policy

Ensuring Integrity and Compliance in Financial Operations

Introduction

Ewalletly Tech Ltd recognizes the critical importance of adhering to global and local regulations that prevent financial crimes, including money laundering and terrorist financing. As a forward-thinking fintech company operating in Nigeria, we are committed to the highest standards of integrity and ethical business practices.

Purpose

The purpose of Ewalletly's AML Policy is to provide a structured framework that ensures our compliance with all applicable anti-money laundering laws and regulations, including but not limited to the Nigerian Money Laundering (Prevention and Prohibition) Act.

Scope

This policy applies to all employees, contractors, agents, and partners of Ewalletly, regardless of their role or position. Any individual found violating the policy will be subject to disciplinary action, which may include termination of employment or legal proceedings where necessary.

Key Provisions

Our comprehensive approach to preventing money laundering and ensuring regulatory compliance

Customer Due Diligence (CDD)

Essential process for identifying and verifying customer identity before service engagement.

  • Know Your Customer (KYC) verification process
  • Source of Funds documentation requirements
  • Enhanced Due Diligence (EDD) for high-risk customers

Suspicious Activity Reporting (SAR)

Vigilant monitoring and reporting of transactions indicating potential financial crimes.

  • Unexplained large or frequent cash transactions
  • Transfers to/from high-risk jurisdictions
  • Complex transaction structures lacking business purpose
  • Customers avoiding KYC or providing false information

Record Keeping

Comprehensive maintenance of transaction records for regulatory compliance.

  • Minimum 5-year retention period for all records
  • Secure but accessible storage for authorized personnel
  • Advanced data protection measures for sensitive information

Training and Education

Continuous education builds an informed and vigilant workforce capable of identifying and preventing financial crimes.

Regulatory requirements training for all employees
Red flags identification and recognition
Internal reporting procedures and processes
Regular updates and refresher courses

Independent Compliance Officer

Our dedicated Compliance Officer oversees all AML efforts with expertise and authority to ensure effective implementation.

Overseeing AML policy execution and enforcement
Primary contact with regulatory authorities
Regular reviews and audits of AML programs
Filing STRs with Nigerian Financial Intelligence Unit

Monitoring and Review

We conduct regular reviews and updates to ensure our AML Policy remains effective and compliant with evolving regulations and financial landscapes.

Continuous Evaluation

Regular assessment of AML measures effectiveness and incorporation of new regulatory requirements.

External Audits

Independent evaluations by external auditors and consultants as part of our commitment to best practices.

Our Commitment

Ewalletly Tech Ltd takes its responsibility to combat money laundering seriously. By adhering to this comprehensive AML Policy, we aim to prevent, detect, and report any suspicious activities that could threaten the integrity of our business or the wider financial system. Every employee, contractor, and agent of Ewalletly is empowered and obligated to contribute to this effort, ensuring that we continue to operate in a legal, ethical, and transparent manner.

Last updated: June 2025 | For questions regarding this policy, please contact our Compliance Officer