AML/CTF Policy

Introduction

Mimoni Technologies Limited (“Mimoni,” “we,” “our,” or “us”) is committed to preventing the use of its Services for money laundering, terrorist financing, or any other illegal activity.

This AML/CTF Policy outlines the framework, procedures, and controls we have implemented to ensure compliance with applicable laws and regulations, including:

• Money Laundering (Prevention and Prohibition) Act 2022 (Nigeria)

• CBN AML/CFT Regulations 2022

• Terrorism (Prevention & Prohibition) Act 2022 (Nigeria)

• FATF Recommendations (International)

Purpose

The objectives of this Policy are to:

• Protect Mimoni from being exploited for money laundering or terrorist financing.

• Ensure compliance with all regulatory requirements.

• Establish a robust Know Your Customer (KYC) and Customer Due Diligence (CDD) process.

• Detect and report suspicious activities to the Nigerian Financial Intelligence Unit (NFIU).

Scope

This Policy applies to:

• All employees, directors, and contractors of Mimoni.

• All customers (individual and business).

• All Mimoni Services, including escrow transactions, fiat/crypto payments, virtual accounts, and APIs.

Key Principles

1. Risk-Based Approach (RBA)

• Customers and transactions are assessed based on their risk profile (low, medium, high).

• Enhanced due diligence applies to high-risk customers.

2. Customer Identification (KYC/CDD)

• Verification of identity using BVN, NIN, passport, or other government-issued ID.

• Collection of proof of address and contact details.

• Verification against sanctions lists (UN, OFAC, EFCC, CBN watchlists).

3. Enhanced Due Diligence (EDD)

• Applied to Politically Exposed Persons (PEPs), cross-border transactions, and high-value crypto payments.

• Source of funds and wealth must be established.

4. Ongoing Monitoring

• Continuous monitoring of customer transactions for unusual or suspicious activity.

• Use of automated fraud detection tools and manual review.

5. Suspicious Transaction Reporting (STRs)

• All suspicious activities must be reported to the Nigerian Financial Intelligence Unit (NFIU) without tipping off the customer.

6. Record Keeping

• Customer and transaction records must be retained for a minimum of 5 years after the end of the business relationship, in line with Nigerian law.

Roles & Responsibilities

• Board of Directors – Ensures oversight and approval of AML/CTF framework.

• Compliance Officer (MLRO) – A designated Money Laundering Reporting Officer responsible for day-to-day compliance, suspicious activity reporting, and staff training.

• Employees – Must follow this Policy and immediately escalate any suspicious activity.

Prohibited Activities

Mimoni strictly prohibits:

• Anonymous or fictitious accounts.

• Transactions with sanctioned individuals, entities, or countries.

• Use of the platform for gambling, darknet activities, fraud, terrorism financing, or illegal goods.

• Structuring transactions to evade reporting thresholds.

Training & Awareness

• All employees must undergo regular AML/CTF training.

• Training covers red flag detection, reporting obligations, and customer interaction protocols.

Reporting Obligations

• Mimoni will submit Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs) to the NFIU as required.

• Reports will be filed promptly and in compliance with confidentiality rules.

Penalties for Non-Compliance

We implement industry-standard measures, including:

• Internal disciplinary action.

• Reporting to regulators.

• Civil or criminal penalties under Nigerian law.

Review & Updates

This Policy will be reviewed at least annually, or earlier if required by law, regulatory updates, or changes in Mimoni’s business model.

Contact

For questions or concerns about this Privacy Policy or to exercise your rights, please contact:

Mimoni Technologies Limited
Email: support@mimoni.africa
Phone: +234 803 223 7727