Anti-Money Laundering (AML) Policy

1. Regulatory Framework

Sogo operates in compliance with:

• Money Laundering (Prohibition) Act 2011 (as amended) of Nigeria
• Terrorism (Prevention) Act 2011 (as amended) of Nigeria
• Central Bank of Nigeria (CBN) Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Regulations
• Financial Action Task Force (FATF) Recommendations
• Nigerian Financial Intelligence Unit (NFIU) guidelines
• Special Control Unit Against Money Laundering (SCUML) regulations

2. Know Your Customer (KYC) Requirements

Tier 1 Verification (Email Verified)

Required Information:

• Full legal name (first name, middle name, last name)
• Valid email address (verified)
• Phone number

Allowed Operations: Sell Gift Cards, and Low-limit Bill Payments

Tier 2 Verification (Identity Verified)

Required Information:

• All Tier 1 requirements
• Bank Verification Number (BVN) or National Identification Number (NIN)
• Selfie image for identity confirmation (face comparison with identity record photo)
• Date of birth
• Gender

Verification Process: Instant and automatic verification

Allowed Operations: Everything in Tier 1, plus Virtual Account Assignment for Wallet Top-up, Low-limit RMB Purchases, Low-limit Crypto Sell, and High-limit Bill Payments

Tier 3 Verification (Document & Address Verified - Enhanced Due Diligence)

Required Information:

• All Tier 2 requirements
• Identity document (NIN/Passport/Drivers License with front/back images)
• Proof of address (utility bill, government letter, tenancy agreement, or bank statement, not older than 3 months)
• Selfie video for enhanced biometric verification
• Full residential address

Verification Process: May take 24-48 hours for review

Allowed Operations: Everything in Tier 2, plus High-limit Gift Card Sell, RMB Purchases, and Crypto Sell Transactions

Know Your Business (KYB) Verification (Corporate Entities)

Required Information:

• Corporate Affairs Commission (CAC) Registration Documents
• Identification and verification of all Company Directors
• Identification of Ultimate Beneficial Owners (UBOs) holding 5% or more equity
• Corporate AML/CFT Policy
• Proof of Business Address

Verification Process: Subject to strict manual review and enhanced due diligence

Allowed Operations: Live Partner API access, high-limit transactions, and business/B2B integration

3. Customer Due Diligence (CDD)

We conduct ongoing monitoring of customer transactions and activities to:

• Verify customer identity and ensure information remains current
• Assess and monitor transaction patterns
• Identify unusual or suspicious activities
• Update risk assessments periodically
• Maintain accurate and up-to-date records

4. Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence measures for:

• High-risk customers or transactions
• Politically Exposed Persons (PEPs) and their close associates
• Customers from high-risk jurisdictions
• Complex or unusually large transactions
• Transactions that deviate from expected patterns
• Cryptocurrency buy (Tier 3); cryptocurrency sell with tiered limits (Tier 1/2 lower, Tier 3 higher)

5. Transaction Monitoring

Our automated systems continuously monitor transactions for:

• Unusual transaction patterns or volumes
• Structuring or smurfing activities (breaking large transactions into smaller ones)
• Rapid movement of funds
• Transactions with high-risk jurisdictions
• Transactions inconsistent with customer profile
• Use of multiple accounts or identities

6. Suspicious Activity Reporting

We are obligated to report suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) when:

• A transaction exceeds ₦5,000,000 (or equivalent in cryptocurrency)
• Activities suggest money laundering or terrorist financing
• Customer provides false or misleading information
• Customer refuses to provide required documentation
• Transactions appear designed to evade reporting requirements
• Customer exhibits unusual concern about AML/CFT procedures

7. Prohibited Transactions

We strictly prohibit transactions involving:

• Proceeds of criminal activity or illegal sources of funds
• Financing of terrorism or terrorist organisations
• Sanctioned individuals, entities, or countries
• Fraudulent gift cards or stolen payment instruments
• Cryptocurrency obtained through illicit means
• Anonymous transactions or unverified accounts
• Transactions designed to evade tax obligations

8. Sanctions Screening

All customers and transactions are screened against:

• United Nations Security Council sanctions lists
• Office of Foreign Assets Control (OFAC) SDN list
• European Union sanctions lists
• UK HM Treasury sanctions lists
• Nigerian sanctions and watch lists
• Interpol wanted persons lists

9. Record Keeping

We maintain comprehensive records for a minimum of 5 years after account closure or transaction completion:

• Customer identification documents and verification records
• Transaction records and supporting documentation
• Risk assessment reports
• Suspicious activity reports and investigations
• Communications with customers and regulators
• Account statements and audit trails

10. Employee Training

All Sogo staff receive regular AML/CFT training covering:

• Current AML/CFT regulations and requirements
• Red flags and suspicious activity indicators
• Customer due diligence procedures
• Reporting obligations and escalation procedures
• Data protection and confidentiality
• Sanctions compliance

11. Risk Assessment

We conduct regular risk assessments considering:

• Customer risk (based on profile, behaviour, and geography)
• Service risk (cryptocurrency, gift cards, bill payments)
• Delivery channel risk (mobile app, web platform)
• Geographic risk (high-risk jurisdictions)
• Transaction risk (size, frequency, complexity)

12. Third-Party Partnerships & B2B API Integrations

We ensure all third-party service providers, including cryptocurrency exchange partners and payment processors, maintain adequate AML/CFT controls and comply with applicable regulations. Furthermore, businesses integrating with our Partner API are subject to mandatory KYB checks, ongoing transaction monitoring, and must demonstrate their own robust AML/CFT frameworks to prevent the platform from being used to facilitate financial crime.

13. Virtual Bank Account Controls

For users assigned temporary or permanent virtual bank accounts, Sogo applies stringent monitoring to prevent misuse. Controls include:

• Monitoring for inward transfers that exhibit signs of fraud or scam proceeds
• Prohibiting the use of virtual accounts as informal money transfer services or "pass-through" accounts
• Enforcing daily and monthly inward/outward transfer limits based on KYC/KYB tier
• Immediate freezing of accounts flagged by our partner banks or algorithmic monitoring systems

14. Cryptocurrency-Specific Controls

For cryptocurrency transactions, we implement additional controls:

• Mandatory Tier 3 KYC for crypto buy; tiered limits for crypto sell (Tier 1/2/3)
• Blockchain analytics and transaction tracing
• Source of funds verification
• Enhanced monitoring for mixing services or privacy coins
• Travel Rule compliance for crypto transfers
• Regular wallet address screening

15. Account Freezing and Termination

We reserve the right to freeze or terminate accounts:

• Upon detection of suspicious activity
• If required by law enforcement or regulators
• If customer fails to provide required documentation
• If customer is found on sanctions lists
• If account is used for prohibited activities

16. Compliance Officer

Sogo has appointed a dedicated AML Compliance Officer responsible for:

• Overseeing AML/CFT program implementation
• Monitoring regulatory changes and updates
• Filing suspicious activity reports
• Liaising with regulatory authorities
• Conducting internal audits and reviews
• Managing staff training programs

17. Confidentiality

In accordance with tipping-off provisions, we do not disclose to customers or third parties when:

• A suspicious activity report has been filed
• An investigation is ongoing
• Enhanced due diligence is being conducted
• Information has been shared with law enforcement

18. Policy Review and Updates

This AML policy is reviewed and updated at least annually or when:

• Regulatory requirements change
• New risks are identified
• Business operations expand to new services or jurisdictions
• Regulatory feedback is received

19. Customer Obligations

As a customer, you agree to:

• Provide accurate and truthful information
• Update your information when it changes
• Respond promptly to verification requests
• Not use the platform for illegal purposes
• Report any suspicious activity you observe
• Comply with all applicable laws and regulations

20. Reporting Suspicious Activity

If you observe or suspect money laundering or terrorist financing activity, please report it to:

Email: [email protected]
Subject line: "AML Report - Confidential"

21. Contact Information

For questions about this AML Policy, please contact our Compliance Officer at:

Email: [email protected]