AML & CFT Policy

Payroid prohibits any use of our platform for:

• Money laundering
• Terrorism financing
• Proliferation financing
• Sanctions evasion
• Conversion of proceeds of fraud, theft, corruption, or any predicate crime

We will report suspicious activity to the Nigerian Financial Intelligence Unit (“NFIU”). We will cooperate fully and promptly with the Central Bank of Nigeria (“CBN”), the Economic and Financial Crimes Commission (“EFCC”), the Securities and Exchange Commission (“SEC”), and any other competent authority.

This policy is informed by and aligned with:

• Money Laundering (Prevention and Prohibition) Act 2022
• Terrorism (Prevention and Prohibition) Act 2022
• CBN Anti-Money Laundering, Combating the Financing of Terrorism and Countering Proliferation Financing of Weapons of Mass Destruction (AML/CFT/CPF) Regulations 2022, as amended
• SEC Rules on Issuance, Offering Platforms and Custody of Digital Assets 2022
• NFIU Regulations and reporting guidelines
• Financial Action Task Force (“FATF”) Recommendations
• United Nations Security Council Resolutions on targeted financial sanctions
• Nigerian Data Protection Act 2023 (where data processing intersects compliance)

We will not establish a business relationship with a customer without first verifying:

• Legal name, date of birth, and nationality
• Address (verified through documentation)
• Bank Verification Number (BVN) and National Identification Number (NIN), as required for the relevant KYC tier
• Source of funds and source of wealth, where required by risk tier

CDD applies to all new account openings, certain high-value transactions, and any occasion where existing customer information appears inadequate or outdated.

We apply Enhanced Due Diligence (“EDD”) where risk indicators are elevated, including but not limited to:

• Transactions above CBN-prescribed thresholds
• The customer is a Politically Exposed Person (“PEP”), a family member of a PEP, or a close associate of a PEP
• The customer is from, transacting with, or otherwise connected to a higher-risk jurisdiction as defined by the FATF
• Unusual patterns in transaction velocity, value, or counterparties
• Public adverse media about the customer

EDD measures may include:

• Source-of-funds documentation
• Source-of-wealth documentation
• Senior-management approval to onboard or continue the relationship
• Enhanced ongoing monitoring
• More frequent periodic reviews

We operate a tiered KYC structure aligned with CBN Tier 1, Tier 2, and Tier 3 customer categories. Higher tiers unlock higher transaction limits in exchange for additional verification steps. Limit thresholds and verification requirements per tier are disclosed in-app and updated when CBN guidance changes.

We screen all customers and counterparties against:

• UN Consolidated Sanctions List
• US OFAC Specially Designated Nationals (SDN) List
• UK HM Treasury Consolidated List
• EU Consolidated List
• Nigerian Sanctions List, as published by the relevant authority

Customers matching any sanctions list will be denied service. Matches will be reported as required by law.

We monitor transactions on an ongoing, automated basis. Risk indicators we look for include:

• Velocity beyond the expected baseline for the customer's tier and behavioural profile
• Structuring — multiple small transactions designed to avoid reporting thresholds
• Round-tripping — funds returning to source after one or more intermediate steps
• Sudden activity following long periods of dormancy
• Transactions to or from sanctioned addresses, mixer services, or known bad actors
• Inconsistency between declared source of funds and observed transaction behaviour

Alerts are triaged by our Compliance team within twenty-four (24) hours on business days.

Where we have reasonable grounds to suspect that funds are the proceeds of crime or related to terrorism financing, we will file a Suspicious Transaction Report (“STR”) with the NFIU within the prescribed timeline and format. STRs are filed by our Money Laundering Reporting Officer (“MLRO”) acting independently of commercial functions.

We will not “tip off” the customer about an STR. Customers should not interpret routine service delays as evidence of an STR; many delays are entirely operational.

We retain customer identification records, transaction records, STR-related documentation, and other AML/CFT documentation for a minimum of five (5) years from the end of the customer relationship, in line with the Money Laundering Act 2022 and the CBN AML Regulations.

Records are stored encrypted at rest, with strict access controls and audit logging. They may be disclosed only to authorized regulators, courts, or law enforcement upon lawful request.

We have appointed a Money Laundering Reporting Officer (“MLRO”) and a Deputy MLRO with clear escalation authority and direct reporting lines to senior management and the board. All staff complete AML/CFT training:

• On joining
• Annually thereafter
• After any material change to law or internal policy

The MLRO has independent authority to file STRs, escalate to senior management, and freeze suspicious transactions pending investigation.

As a Payroid customer you are expected to:

• Provide accurate, current, and complete information
• Respond to verification requests within the timeframes we set
• Refrain from providing false or forged documentation
• Not use Payroid to facilitate any illegal activity, directly or indirectly

Refusal to cooperate with verification, or evidence of false information, may result in account suspension, transaction reversal, and reporting to the relevant authority.

If you suspect that another account is being used for money laundering or terrorism financing, please email hello@payroid.co with the subject line “AML concern.” Reports are treated confidentially and forwarded to our MLRO. We do not retaliate against good-faith reporters.

For questions about this policy, email hello@payroid.co. For complaints about the application of this policy, follow our Complaint process.

Payroid Synergy Limited
RC 9553657 · TIN 2622489136936
Ogba, Lagos, Nigeria