1. Introduction

SwiftXchange is committed to maintaining the highest standards of compliance with Anti-Money Laundering (AML) regulations and combating the financing of terrorism (CFT).

As a digital asset and gift card trading company operating in Nigeria and other jurisdictions, SwiftXchange recognizes the importance of implementing robust AML measures to prevent illicit activities such as money laundering, terrorist financing, fraud, and other financial crimes.

This AML Policy outlines the procedures, controls, and responsibilities that SwiftXchange has established to ensure compliance with applicable laws, regulations, and industry best practices. The policy is designed to protect SwiftXchange, its customers, and the broader financial ecosystem from being exploited for illegal purposes.

2. Purpose and Scope

The purpose of this AML Policy is to:

• Prevent SwiftXchange from being used for money laundering, terrorist financing, or other financial crimes.
• Ensure compliance with Nigerian AML/CFT laws, including the Money Laundering (Prohibition) Act 2022, the Economic and Financial Crimes Commission (EFCC) Act, and the Central Bank of Nigeria (CBN) guidelines.
• Establish a framework for identifying, assessing, and mitigating AML/CFT risks.
• Promote a culture of compliance and ethical behavior among employees, customers, and partners.

This policy applies to all SwiftXchange employees, contractors, agents, and third-party service providers involved in the company’s operations. It covers all products and services offered by SwiftXchange, including digital asset trading, gift card exchanges, and fiat currency transactions.

3. Regulatory Framework

SwiftXchange operates in compliance with the following regulatory frameworks:

• Money Laundering (Prohibition) Act 2022: This act provides the legal basis for AML/CFT measures in Nigeria, including customer due diligence, reporting obligations, and penalties for non-compliance.
• Central Bank of Nigeria (CBN) Guidelines: The CBN issues guidelines for financial institutions, including digital asset service providers, to ensure compliance with AML/CFT requirements.
• Economic and Financial Crimes Commission (EFCC) Act: The EFCC is responsible for investigating and prosecuting financial crimes in Nigeria.
• Financial Action Task Force (FATF) Recommendations: SwiftXchange adheres to the international standards set by FATF for combating money laundering and terrorist financing.

4. Risk Assessment

SwiftXchange conducts regular risk assessments to identify and mitigate potential AML/CFT risks.

The risk assessment process considers factors such as:

• The nature of SwiftXchange’s products and services.
• The geographic locations of customers and partners.
• The types of transactions conducted on the platform.
• Emerging trends in money laundering and terrorist financing.

Based on the risk assessment, SwiftXchange categorizes customers and transactions into low, medium, and high-risk categories. This categorization informs the level of due diligence required for each customer and transaction.

5. Customer Due Diligence (CDD)

SwiftXchange implements a robust CDD process to verify the identity of its customers and assess their risk profiles.

The CDD process includes:

• Identity Verification: Customers are required to provide valid government-issued identification documents, such as a national ID card, international passport, or driver’s license.
• Address Verification: Customers must provide proof of address, such as a utility bill or bank statement, dated within the last three months.
• Biometric Verification: In some cases, SwiftXchange may require customers to undergo biometric verification to enhance identity authentication.
• Screening: Customers are screened against global sanctions lists, PEP databases, and adverse media reports.

For Nigerian customers, SwiftXchange leverages the Bank Verification Number (BVN) system to enhance identity verification and reduce fraud risks.

6. Enhanced Due Diligence (EDD)

SwiftXchange applies EDD measures to high-risk customers and transactions. EDD measures include:

• Obtaining additional information about the customer’s source of funds and wealth.
• Conducting ongoing monitoring of the customer’s transactions.
• Requiring senior management approval for onboarding high-risk customers.
• Limiting transaction amounts or imposing additional restrictions on high-risk accounts.

7. Record Keeping

SwiftXchange maintains accurate and up-to-date records of all customer transactions and due diligence documents. Records are retained for a minimum of five years, as required by Nigerian law. These records are stored securely and are accessible only to authorized personnel.

8. Transaction Monitoring

SwiftXchange employs advanced transaction monitoring systems to detect and report suspicious activities. The monitoring system analyzes transaction patterns, amounts, frequencies, and other relevant factors to identify potential red flags, such as:

• Unusually large transactions.
• Frequent transactions just below reporting thresholds.
• Transactions involving high-risk jurisdictions.
• Inconsistent customer behavior.

9. Reporting Obligations

SwiftXchange complies with all reporting obligations under Nigerian law, including:

• Suspicious Activity Reports (SARs): SwiftXchange files SARs with the Nigerian Financial Intelligence Unit (NFIU) for any transactions suspected of involving money laundering or terrorist financing.
• Currency Transaction Reports (CTRs): SwiftXchange reports cash transactions exceeding the threshold set by the CBN.

10. Employee Training and Awareness

SwiftXchange provides regular AML/CFT training to all employees to ensure they understand their roles and responsibilities.

Training topics include:

• Recognizing red flags and suspicious activities.
• Conducting CDD and EDD.
• Reporting obligations and procedures.
• Ethical behavior and compliance culture.

11. Sanctions Compliance

SwiftXchange screens all customers and transactions against global sanctions lists, including those maintained by the United Nations, European Union, and Office of Foreign Assets Control (OFAC). Any matches are escalated for further investigation and reported to the relevant authorities.

12. Politically Exposed Persons (PEPs)

SwiftXchange identifies and applies EDD measures to customers who are PEPs or have close associations with PEPs. PEPs are individuals who hold or have held prominent public positions, such as government officials, judges, and military officers.

13. Third-Party Relationships

SwiftXchange conducts due diligence on all third-party service providers, including payment processors, technology vendors, and marketing partners. Third-party relationships are governed by contracts that include AML/CFT compliance requirements.

14. Whistleblowing and Reporting Mechanisms

SwiftXchange encourages employees, customers, and partners to report any suspected AML/CFT violations through its whistleblowing channels. Reports can be made anonymously and are investigated promptly and confidentially.

15. Internal Controls and Audits

SwiftXchange has established internal controls to ensure compliance with this AML Policy. These controls include:

• Regular internal audits of AML/CFT processes.
• Independent reviews by external auditors.
• A dedicated compliance team is responsible for overseeing AML/CFT activities.

16. Penalties for Non-Compliance

Non-compliance with this AML Policy may result in disciplinary action, including termination of employment or contract. SwiftXchange may also face legal penalties, fines, or reputational damage for failing to comply with AML/CFT regulations.

17. Policy Review and Updates

This AML Policy is reviewed annually or as needed to reflect changes in regulatory requirements, industry standards, or SwiftXchange’s business operations.

Updates are communicated to all relevant stakeholders.

18. Conclusion

SwiftXchange is committed to maintaining a strong AML/CFT framework to protect its business, customers, and the broader financial system. By adhering to this policy, SwiftXchange aims to foster trust, transparency, and integrity in its operations while contributing to the global fight against financial crime.

For any questions or concerns regarding this AML Policy, please contact SwiftXchange’s Compliance Team at help@swiftxchange.ng