Anti-Money Laundering (AML) Policy

1. Introduction and Commitment

Bridgenetic Modern Payment Infrastructure ("Bridgenetic," "we," or "the Company") is firmly committed to preventing the use of our payment infrastructure for money laundering, terrorist financing, proliferation financing, and other financial crimes. This Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Policy outlines our comprehensive framework for detecting, preventing, and reporting suspicious activities in compliance with Nigerian law and international standards.

As a payment service provider operating within Nigeria's financial ecosystem, we recognize our critical role as a gatekeeper against financial crime and accept our obligations under applicable legislation and regulatory directives.

2. Regulatory Framework

This AML/CFT Policy is developed in compliance with the following laws, regulations, and guidelines:

Money Laundering (Prohibition) Act 2011 (as amended 2022): The primary legislation criminalizing money laundering in Nigeria.
Terrorism (Prevention and Prohibition) Act 2022: Legislation addressing terrorist financing and related offences.
Central Bank of Nigeria (CBN) AML/CFT Regulations 2013: Regulatory framework for financial institutions and payment service providers.
CBN Guidelines on Electronic Banking 2003 (as amended): Requirements for electronic payment platforms.
Economic and Financial Crimes Commission (EFCC) Act 2004: Establishing the primary enforcement agency for financial crimes.
Nigeria Financial Intelligence Unit (NFIU) Act 2018: Establishing the national centre for financial intelligence.
Financial Action Task Force (FATF) Recommendations: International standards for combating money laundering and terrorist financing.
CBN Regulatory Framework for Payment Service Providers: Specific requirements for licensed payment platforms.

3. Scope and Application

This policy applies to:

All merchants, users, and customers who access or use the Bridgenetic platform.
All employees, contractors, and agents of Bridgenetic.
All transactions processed through our payment infrastructure, including virtual account deposits, wallet transfers, and fund disbursements.
All business relationships established through the platform.
All third-party service providers and banking partners engaged by Bridgenetic.

4. Customer Due Diligence (CDD)

4.1 Standard Due Diligence

Before establishing a business relationship, we conduct Customer Due Diligence on all merchants, which includes:

Verification of the identity of the merchant and beneficial owners using reliable, independent source documents.
Verification of business registration with the Corporate Affairs Commission (CAC).
Collection and verification of Bank Verification Number (BVN) for individual merchants.
Understanding the nature and purpose of the business relationship.
Assessment of the expected transaction patterns and volumes.
Verification of the source of funds where applicable.

4.2 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied in higher-risk situations, including:

Merchants operating in high-risk business categories (as defined by CBN guidelines).
Politically Exposed Persons (PEPs) and their associates or family members.
Merchants with complex ownership structures or unusual business models.
Transactions involving jurisdictions identified as high-risk by FATF or CBN.
Merchants whose transaction patterns significantly deviate from their stated business profile.
Any situation where there is a higher risk of money laundering or terrorist financing.

4.3 Ongoing Due Diligence

We conduct ongoing monitoring of all business relationships to ensure that:

Transactions are consistent with our knowledge of the merchant's business and risk profile.
Merchant information remains current and accurate.
Changes in business patterns or ownership are identified and assessed.
Periodic reviews are conducted based on the merchant's risk classification.

5. Risk-Based Approach

Bridgenetic employs a risk-based approach to AML/CFT compliance, which involves:

Risk Assessment: Regular assessment of money laundering and terrorist financing risks associated with our products, services, customers, and geographic exposure.
Risk Classification: Categorizing merchants into low, medium, and high-risk categories based on multiple factors including business type, transaction volumes, geographic location, and ownership structure.
Proportionate Controls: Applying controls and monitoring measures proportionate to the identified risk level.
Regular Review: Periodic reassessment of risk classifications and updating controls as necessary.

6. Transaction Monitoring

We maintain robust transaction monitoring systems designed to detect suspicious activities:

Automated Monitoring: Real-time and batch monitoring of all transactions against predefined rules and thresholds.
Pattern Analysis: Detection of unusual transaction patterns, including structuring (smurfing), rapid movement of funds, and circular transactions.
Threshold Monitoring: Flagging transactions that exceed specified monetary thresholds for manual review.
Velocity Checks: Monitoring the frequency and speed of transactions to identify potential layering activities.
Behavioral Analytics: Comparing actual transaction behavior against expected patterns based on the merchant's profile.
Cross-Reference Checks: Matching transaction parties against sanctions lists, PEP databases, and adverse media sources.

7. Suspicious Activity Reporting

When suspicious activity is identified, Bridgenetic follows a structured reporting process:

Internal Reporting: All employees are required to report suspicious activities to the designated Compliance Officer immediately upon detection.
Investigation: The Compliance team conducts a thorough investigation of flagged activities to determine whether a Suspicious Transaction Report (STR) is warranted.
Filing STRs: Where warranted, Suspicious Transaction Reports are filed with the Nigeria Financial Intelligence Unit (NFIU) within the prescribed timeframe.
Currency Transaction Reports (CTRs): Reports are filed for transactions meeting the mandatory reporting thresholds as specified by the CBN and NFIU.
Tipping Off Prohibition: Under no circumstances will we inform the subject of a report that a suspicious activity report has been or will be filed.

8. Sanctions Screening

Bridgenetic maintains comprehensive sanctions screening procedures:

Screening all merchants and transaction parties against applicable sanctions lists including UN Security Council sanctions, OFAC SDN list, EU sanctions, and Nigerian domestic sanctions.
Real-time screening of transactions to prevent processing of payments involving sanctioned individuals, entities, or jurisdictions.
Regular updates to sanctions databases to ensure current and accurate screening.
Immediate escalation and blocking of any matches or potential matches pending investigation.

9. Record Keeping

In compliance with regulatory requirements, Bridgenetic maintains comprehensive records:

CDD Records: All customer identification and verification documents are retained for a minimum of 5 years after the termination of the business relationship.
Transaction Records: Complete records of all transactions, including amounts, dates, parties involved, and nature of transactions, retained for a minimum of 6 years.
STR Records: All suspicious transaction reports and supporting documentation retained for a minimum of 5 years from the date of filing.
Correspondence: All AML/CFT-related correspondence with regulatory authorities retained indefinitely.
Training Records: Records of staff AML/CFT training, including dates, content, and attendance.

10. Staff Training and Awareness

Bridgenetic ensures all relevant personnel receive appropriate AML/CFT training:

Induction Training: All new employees receive AML/CFT awareness training as part of their onboarding process.
Regular Training: Annual refresher training for all staff on AML/CFT obligations, red flags, and reporting procedures.
Specialized Training: Enhanced training for compliance staff, customer-facing teams, and senior management on emerging risks and regulatory updates.
Awareness Programs: Ongoing communication of AML/CFT developments, typologies, and case studies.

11. Compliance Governance

Our AML/CFT compliance governance structure includes:

Chief Compliance Officer (CCO): A designated senior officer responsible for overseeing the AML/CFT program and reporting to the Board.
Compliance Team: Dedicated personnel responsible for day-to-day AML/CFT operations, monitoring, and investigations.
Board Oversight: Regular reporting to the Board of Directors on AML/CFT matters, including risk assessments, program effectiveness, and regulatory developments.
Independent Audit: Annual independent review of the AML/CFT program by qualified internal or external auditors.

12. Prohibited Activities

The following activities are strictly prohibited on the Bridgenetic platform:

Processing transactions known or suspected to involve proceeds of crime.
Facilitating transactions for the purpose of money laundering or terrorist financing.
Structuring transactions to avoid reporting thresholds.
Processing transactions involving sanctioned individuals, entities, or jurisdictions.
Operating shell companies or fictitious businesses through the platform.
Using the platform for Ponzi schemes, advance fee fraud (419), or other financial crimes.
Facilitating transactions related to corruption, bribery, or embezzlement of public funds.

13. Enforcement and Consequences

Violations of this AML/CFT Policy may result in:

Immediate suspension or termination of the merchant account.
Freezing of funds pending investigation.
Filing of Suspicious Transaction Reports with the NFIU.
Referral to law enforcement agencies including the EFCC, NFIU, or Nigeria Police Force.
Civil and criminal liability under applicable Nigerian law.

14. Cooperation with Authorities

Bridgenetic maintains full cooperation with regulatory and law enforcement authorities:

Prompt response to lawful requests for information from the CBN, NFIU, EFCC, and other competent authorities.
Participation in industry-wide AML/CFT initiatives and information-sharing arrangements.
Compliance with court orders, regulatory directives, and account freezing requests.
Proactive engagement with regulators on emerging risks and compliance challenges.

15. Policy Review and Updates

This AML/CFT Policy is reviewed and updated:

At least annually, or more frequently as required by regulatory changes.
Following significant changes to our products, services, or business model.
In response to identified deficiencies or audit findings.
When new money laundering or terrorist financing typologies are identified.

16. Contact Information

For questions or concerns regarding this AML/CFT Policy, or to report suspicious activity, please contact:

Compliance Officer: [email protected]
General Inquiries: [email protected]
Website: https://bridgenetic.com

Last updated: May 2026