Document Control & Approval

Policy Owner	Board Audit & Compliance Committee
Prepared By	Compliance Department
Approved By	Board of Directors
Approval Date	February 07, 2025
Effective Date	February 07, 2025
Last Review Date	May 26, 2026
Next Review Date	March 28, 2027
Version Number	1.2
Classification	Confidential – Internal & Regulatory Use

Table of Contents

1.0 Introduction and Scope

This Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) Policy (hereinafter referred to as "the Policy") is issued by E-TALK LTD (hereinafter referred to as "the Company", "E-TALK") to establish the minimum standards and controls for the prevention, detection, and reporting of money laundering, terrorist financing, and other predicate offenses.

The Policy applies to all directors, officers, employees, contractors, agents, and third-party service providers acting on behalf of E-TALK LTD. All persons covered by this Policy are required to read, understand, and comply with its provisions.

2.0 Definitions and Interpretations

Money Laundering: The process by which proceeds of criminal activity are disguised to conceal their illicit origin, including the placement, layering, and integration stages as defined under the Money Laundering (Prevention and Prohibition) Act 2022.

Terrorist Financing: The provision or collection of funds, by any means, directly or indirectly, with the intention or knowledge that they are to be used to carry out terrorist acts.

MLRO: Money Laundering Reporting Officer – The designated officer responsible for receiving internal suspicious activity reports and making external disclosures to the Nigerian Financial Intelligence Unit (NFIU).

3.0 Statement of Commitment

E-TALK LTD maintains a zero-tolerance policy towards money laundering and terrorist financing. The Company is fully committed to:

• Complying with all applicable AML/CFT laws and regulations in all jurisdictions where we operate
• Implementing and maintaining robust AML/CFT controls, systems, and procedures
• Conducting thorough customer due diligence and ongoing monitoring
• Reporting suspicious activities to the appropriate authorities
• Training all employees to recognize and respond to money laundering red flags
• Cooperating fully with law enforcement and regulatory investigations

4.0 Legal and Regulatory Framework

This Policy is governed by and complies with the following Nigerian and international laws, regulations, and standards:

• Money Laundering (Prevention and Prohibition) Act, 2022 (as amended)
• Terrorism (Prevention) Act, 2013 (as amended)
• Central Bank of Nigeria (CBN) AML/CFT Regulations for Other Financial Institutions
• Nigerian Financial Intelligence Unit (NFIU) Guidelines and Directives
• Companies and Allied Matters Act (CAMA) 2020
• Nigeria Data Protection Regulation (NDPR) 2019
• Financial Action Task Force (FATF) 40 Recommendations
• United Nations Security Council Resolutions on Counter-Terrorism
• Economic Community of West African States (ECOWAS) AML/CFT Directives

5.0 Money Laundering and Terrorist Financing Risk Assessment

E-TALK LTD maintains a comprehensive, documented risk assessment framework to identify, assess, understand, and mitigate AML/CFT risks associated with:

• Customer Risk: Customer type, geographic location, occupation, transaction behavior
• Product/Service Risk: Digital payment services, e-wallet features, cross-border transactions
• Geographic Risk: High-risk jurisdictions, sanctions countries, FATF-identified high-risk regions
• Delivery Channel Risk: Digital onboarding, agent networks, third-party integrations

The risk assessment is reviewed annually and updated as necessary to reflect emerging threats, new products, and changes in the regulatory environment.

6.0 Customer Due Diligence (CDD) and KYC

E-TALK LTD shall apply Customer Due Diligence measures in the following circumstances:

• Establishing a business relationship with any customer
• Carrying out occasional transactions above the prescribed threshold (₦1,000,000 or equivalent)
• When there is a suspicion of money laundering or terrorist financing
• When there are doubts about the veracity of previously obtained customer identification data

The standard CDD measures include:

• Identifying the customer using reliable, independent source documents
• Verifying the customer's identity using official government-issued identification
• Identifying the beneficial owner(s) of legal entities
• Understanding the purpose and intended nature of the business relationship
• Conducting ongoing monitoring of transactions throughout the business relationship

7.0 Simplified and Enhanced Due Diligence

Simplified Due Diligence (SDD): May be applied for low-risk customers such as publicly listed companies, government entities, or regulated financial institutions.

Enhanced Due Diligence (EDD): Shall be applied for:

• High-risk customers based on risk assessment
• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Complex or unusually large transactions
• Non-face-to-face business relationships

EDD measures include additional verification of identity, source of funds/wealth, senior management approval, and enhanced ongoing monitoring.

8.0 Politically Exposed Persons (PEPs)

E-TALK LTD defines PEPs as individuals entrusted with prominent public functions, including their family members and close associates. The Company shall:

• Maintain automated PEP screening systems integrated into the customer onboarding process
• Apply enhanced due diligence measures for all PEP relationships
• Obtain senior management approval before establishing or continuing PEP relationships
• Conduct enhanced ongoing monitoring of PEP accounts
• Maintain updated lists of domestic and foreign PEPs from reliable sources

9.0 Identity Verification Procedures

All customers shall be verified using at least one of the following:

• National Identity Number (NIN) with National Identity Card
• International Passport (data page) – Biometric verification required
• Driver's License with verifiable license number
• Voter's Card (for Nigerian citizens only)
• For legal entities: Certificate of Incorporation, Form CAC 2, Form CAC 7, and identification of directors/beneficial owners

Liveness detection and biometric verification shall be conducted for all digital onboarding processes. Copies of identification documents shall be retained in secure, encrypted storage.

10.0 Transaction Monitoring Framework

E-TALK LTD maintains an automated transaction monitoring system (TMS) that continuously analyzes customer transactions in real-time. The system is configured to detect, among others:

• Transactions exceeding established thresholds (₦5,000,000 or foreign equivalent)
• Structuring/smurfing – multiple transactions just below reporting thresholds
• Rapid movement of funds through accounts
• Unusual geographic patterns or transactions involving high-risk jurisdictions
• Significant increases in transaction volume or value without reasonable explanation
• Transactions involving known high-risk entities or individuals
• Inconsistent customer profile activity

All system-generated alerts are investigated within 24 hours by the Compliance Team. Alerts deemed suspicious after investigation are escalated to the MLRO.

11.0 Suspicious Transaction Reporting (STR)

Internal Reporting Process:

• Any employee who suspects or has reasonable grounds to suspect money laundering or terrorist financing shall immediately report their suspicion to the Money Laundering Reporting Officer (MLRO).
• Internal reports must be made as soon as practicable, preferably within 24 hours of forming the suspicion.
• Employees are prohibited from disclosing or "tipping off" the subject of the suspicion.
• Internal reports are protected under whistleblower provisions.

External Reporting:

• The MLRO shall evaluate all internal reports and determine whether to file a Suspicious Transaction Report (STR) with the Nigerian Financial Intelligence Unit (NFIU).
• STRs shall be filed within 48 hours of forming suspicion.
• Where urgency is required, verbal notification shall be made immediately, followed by a written report.
• Copies of all STRs shall be retained for a minimum of 7 years.

12.0 Record Keeping Requirements

E-TALK LTD shall maintain the following records for a minimum period of seven (7) years after the business relationship has ended or the transaction has been completed:

• Customer identification and verification documents
• Account opening documents and due diligence records
• Transaction records and correspondence
• Reports of suspicious transactions (internal and external)
• Training records for employees
• Audit reports and compliance review findings
• Risk assessments and policy versions

All records shall be stored in secure, access-controlled environments with encryption for digital records. Access logs shall be maintained and reviewed periodically.

13.0 Sanctions Screening and Watchlist Management

The Company implements sanctions screening and transaction monitoring controls, including automated processes where applicable that screen all customers, beneficial owners, and transaction counterparties against:

• UN Security Council Sanctions Lists
• OFAC Specially Designated Nationals (SDN) List
• EU Consolidated Sanctions List
• UK HM Treasury Sanctions List
• Nigeria Sanctions Committee List
• Interpol Wanted Lists

Screening occurs at onboarding, before processing transactions, and ongoing daily for existing customers. Any positive match triggers immediate investigation and transaction blocking pending resolution.

14.0 Employee Vetting and Training

Pre-Employment Vetting: All prospective employees shall undergo background checks including:

• Identity verification
• Criminal record check
• Credit/Financial history review
• Previous employment verification
• Sanctions and watchlist screening

Training Requirements:

• All employees must complete mandatory AML/CFT training within 30 days of employment
• Annual refresher training for all employees
• Specialized training for Compliance, Customer Service, and Operations teams
• Training records shall be maintained for a minimum of 5 years
• Testing shall be conducted to verify understanding

15.0 Internal Reporting and Whistleblower Protection

E-TALK LTD has established secure internal reporting channels for employees to report concerns about AML/CFT compliance, including:

• Direct reporting to the MLRO via phone or encrypted email
• Anonymous reporting via secure compliance hotline
• Reporting to the Chairman of the Audit Committee

The Company strictly prohibits retaliation against any employee who reports a suspicion in good faith. Whistleblower protection extends to confidentiality, anonymity where requested, and protection from adverse employment actions.

16.0 Compliance Officer Responsibilities

The Money Laundering Reporting Officer (MLRO) / Compliance Officer is responsible for:

• Overseeing the implementation and maintenance of this Policy
• Receiving and evaluating all internal suspicious activity reports
• Filing Suspicious Transaction Reports (STRs) with the NFIU
• Liaising with law enforcement and regulatory authorities
• Conducting internal AML/CFT investigations
• Managing sanctions screening and watchlist processes
• Developing and delivering employee training programs
• Conducting periodic AML/CFT risk assessments
• Reporting to the Board on AML/CFT matters

Current MLRO / Compliance Officer:
Solomon Johnson, ACAMS
Chief Compliance Officer & MLRO
Email: compliance@e-talk.xyz
Phone: +905527378474

Deputy MLRO:
Veronica Arya, CAMS
Deputy Compliance Officer

17.0 Data Protection and Confidentiality

E-TALK LTD processes personal data in accordance with the Nigeria Data Protection Regulation (NDPR) 2019. Specific safeguards include:

• Data minimization – collecting only necessary information for AML purposes
• Purpose limitation – using data only for legitimate AML/CFT purposes
• Storage limitation – retaining data only for required periods
• Integrity and confidentiality – implementing appropriate security measures
• Lawful processing – maintaining legal basis for all data processing
• Data subject rights – honoring rights to access, rectification, and erasure

All AML/CFT data is treated as strictly confidential and is only disclosed as required by law or with appropriate legal authority.

18.0 Independent Audit and Review

The Company shall engage an independent, qualified external auditor to conduct periodic AML/CFT audits. Audit scope includes:

• Review of policy adequacy and implementation
• Testing of CDD and monitoring systems
• Sample testing of customer files and transactions
• Review of training effectiveness
• Assessment of internal controls
• Evaluation of STR filing quality and timeliness

Audit findings are reported directly to the Board Audit & Compliance Committee. Corrective action plans are tracked to completion.

19.0 Consequences of Non-Compliance

Failure to comply with this Policy may result in:

• Disciplinary action up to and including termination of employment
• Civil and criminal liability under applicable laws
• Regulatory penalties against the Company and individuals
• Reputational damage to the Company
• Revocation of operating licenses or regulatory approvals

Individual employees who knowingly or recklessly participate in money laundering or terrorist financing may face criminal prosecution, including imprisonment and significant fines.

20.0 Contact Information and Reporting Channels