Anti-Money Laundering (AML) Policy

a. Customer Due Diligence (CDD)

Customer Due Diligence (CDD) is an essential process for identifying and verifying the identity of our customers before they can engage with our services. This process enables Vendyz to assess the risk profile of each customer and ensure that we are not facilitating illegal activities.

Key CDD Activities:

• Know Your Customer (KYC): All customers must undergo a KYC verification process, which includes obtaining and validating government-issued identification (e.g., national ID, passport) and proof of address.
• Source of Funds: Vendyz will require documentation to ascertain the legitimacy of a customer's funds or financial transactions. This step ensures that the money being used in our platform is not derived from illegal activities such as fraud, drug trafficking, or corruption.
• Enhanced Due Diligence (EDD): For customers who present a higher risk (e.g., politically exposed persons or individuals with suspicious transaction patterns), Vendyz will perform Enhanced Due Diligence (EDD), which may involve deeper scrutiny and continuous monitoring of the customer's financial activities.

b. Suspicious Activity Reporting (SAR)

All employees, contractors, and agents of Vendyz are required to remain vigilant and report any transactions or customer behavior that may indicate money laundering or other financial crimes. Suspicious activity may include, but is not limited to:

• Unexplained large or frequent cash transactions.
• Attempts to transfer funds to or from high-risk jurisdictions.
• Complex or illogical transaction structures that seem to lack a legitimate business purpose.
• Customers avoiding the KYC process or providing false or misleading information.

Reporting Procedures:

• Employees must report suspicious activities immediately to the designated Compliance Officer.
• The Compliance Officer will evaluate the report and determine whether to file a Suspicious Transaction Report (STR) with relevant authorities, such as the Nigerian Financial Intelligence Unit (NFIU).
• All reports of suspicious activity must be kept confidential, and employees are prohibited from alerting the customer that a report has been made (a practice known as "tipping off").

c. Record Keeping

In compliance with Nigerian AML laws, Vendyz is committed to maintaining comprehensive and accurate records of all customer transactions and activities for a specified retention period. This process is critical to ensure that we can support investigations and audits by regulatory bodies, if required.

Key Aspects of Record Keeping:

• Retention Period: All records related to customer identification (KYC), transaction histories, and suspicious activity reports must be kept for at least five years after the end of the customer relationship.
• Accessibility: Records must be stored securely but also be readily accessible to authorized personnel, including law enforcement and regulatory authorities, during investigations or audits.
• Data Security: Vendyz will implement advanced data protection measures to ensure that sensitive customer information is not compromised or accessed by unauthorized individuals.

d. Training and Education

Continuous education is key to building an informed and vigilant workforce. All employees at Vendyz, especially those in customer-facing roles, are required to undergo regular training on AML laws, company policies, and the latest money laundering typologies.

Training Components:

• Regulatory Requirements: Employees will be trained on Nigeria's AML regulations and Vendyz's specific obligations under those laws.
• Red Flags: Employees will be educated on the common red flags of money laundering and how to recognize them in customer transactions or behaviors.
• Internal Processes: Training will include a thorough understanding of Vendyz's internal reporting procedures, including how to submit a Suspicious Activity Report (SAR).
• Updates and Refresher Courses: Vendyz will provide periodic updates on changes to AML regulations and emerging trends in financial crime. Refresher courses will also be mandated to ensure all employees stay current with best practices.

e. Independent Compliance Officer

To oversee our AML efforts, Vendyz will appoint a dedicated Compliance Officer. This individual will have the expertise and authority to ensure that all aspects of the AML program are effectively implemented and enforced across the organization.

Responsibilities of the Compliance Officer:

• Overseeing the execution of the AML Policy, including customer due diligence, monitoring, and suspicious activity reporting.
• Acting as the primary point of contact between Vendyz and external regulatory authorities.
• Conducting regular reviews and audits of Vendyz's AML program to ensure its effectiveness and compliance with changing regulations.
• Delivering ongoing employee training and ensuring that all staff are aware of their responsibilities under the AML Policy.
• Filing Suspicious Transaction Reports (STRs) with the Nigerian Financial Intelligence Unit (NFIU) as required.