AML/CFT Policy

1. Purpose

To prevent KPIE GLOBAL LIMITED’s platforms and services from being used for money

laundering or terrorist financing activities, in line with national and international regulations (e.g.,

NDIC, CBN, FATF guidelines).

2. Scope

Applies to all employees, partners, digital platform users, and transactions processed by KPIE

GLOBAL LIMITED.

3. Key Principles

3.1. Know Your Customer (KYC)

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All customers must be verified through government-issued IDs, BVN, CAC documents,

etc.

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Ongoing customer due diligence is required for high-risk profiles.

3.2. Transaction Monitoring

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Real-time monitoring systems flag unusual or high-value transactions.

Triggers include sudden spikes in activity, multiple account transfers, and off-pattern

behavior.

3.3. Suspicious Activity Reporting (SAR)

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Suspicious activities must be reported to the appropriate authorities (e.g., NFIU) without

alerting the customer.

Internal SAR logs are maintained securely and are audit-ready.

3.4. Record Retention

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AML records are retained for a minimum of 5 years.

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Includes KYC data, transaction history, and SAR filings.

3.5. Staff Training●

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Mandatory AML/CFT training for all staff annually.

Specialized training for compliance and customer-facing roles.

4. Governance

Role Responsibility

Compliance Officer Oversees AML/CFT policy implementation

Risk & Internal Audit Conducts periodic reviews and risk

assessments

Customer Service Team Frontline detection and reporting

5. Sanctions Screening

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All customers and transactions are screened against global sanctions lists (e.g., OFAC,

UN, EU).

Blocked entities are prevented from account creation or transaction processing.

6. Review

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Policy reviewed annually or as required by regulatory ch