Conzo Africa — Crypto, Gift Cards & Bill Payments

1. Glossary of Terms

The following abbreviations and terms are used throughout this Policy:

AML: Anti-Money Laundering
AI: Artificial Intelligence
API: Application Programming Interface
BVN: Bank Verification Number
CBN: Central Bank of Nigeria
CDD: Customer Due Diligence
CFT / CTF: Counter-Terrorist Financing / Combating Terrorist Financing
Company: Conzo Africa Technology Ltd and its subsidiaries
Customer: Any user, vendor, beneficiary, partner, or third party using the Conzo Africa Platform
EDD: Enhanced Due Diligence
EFCC: Economic and Financial Crimes Commission
FATF: Financial Action Task Force
KYC: Know Your Customer
Key Personnel: Any employee of the Company in a position that involves contact with Customers or review of Transactions
LOB: Line of Business
ML: Money Laundering
MLCO: Money Laundering Compliance Officer
MLRO: Money Laundering Reporting Officer — the sole decision-maker and only person authorized to file a SAR
MLR: Money Laundering Report
NFIU: Nigerian Financial Intelligence Unit
PEP: Politically Exposed Person
SAR: Suspicious Activity Report
SMB: Small and Medium-Sized Businesses
STR: Suspicious Transaction Report
UBO: Ultimate Beneficial Owner — the natural person on whose behalf a transaction is executed by a Customer

2. Introduction

Conzo Africa ("Conzo Africa," "we," "us," or "our") is dedicated to establishing and upholding effective internal controls to prevent money laundering, terrorist financing, proliferation financing, fraud, and all other forms of financial crime. The Company operates a zero-tolerance policy for these behaviors and is fully committed to complying with all applicable AML/CFT laws and regulations.

This AML/CFT Policy ("Policy") outlines the Company's obligations regarding complying with and upholding Anti-Money Laundering and Counter-Terrorist Financing laws. It also provides information and guidance to all Conzo Africa employees, contractors, vendors, users, beneficiaries, and business partners on how to identify, prevent, and report any potential money laundering or terrorist financing issues that may arise.

Conzo Africa offers cryptocurrency trading (including Bitcoin (BTC), Ethereum (ETH), Tether (USDT), USD Coin (USDC), BNB, and other digital assets), a gift card marketplace, and bill payment services. Given the nature of these services, the Company recognizes the inherent financial crime risks and has implemented a comprehensive, risk-based AML/CFT framework to mitigate those risks.

This Policy may be modified periodically to reflect changes to the laws, regulations, and guidelines on which it is based. All amendments will be communicated to relevant personnel and made effective from the date of publication.

3. Objectives

The primary objectives of this Policy are as follows:

To guarantee that every reasonable precaution is taken to prevent money laundering and terrorist financing activities on the Conzo Africa Platform.
To ensure that Know Your Customer (KYC) data is gathered, verified, and regularly updated for all users.
To ensure strict adherence to the guidelines set out by the Nigerian Financial Intelligence Unit (NFIU), the Central Bank of Nigeria (CBN), and all other applicable regulatory authorities.
To ensure that all digital assets transacted on the Platform are used only for legitimate and lawful purposes.
To prevent users, vendors, and business partners from using the Platform to launder money, fund terrorism, or engage in any other form of financial crime.
To maintain robust transaction monitoring, reporting, and record-keeping systems that support law enforcement and regulatory oversight.
To foster a strong culture of compliance across the entire Conzo Africa organization and among all business partners.

All users, account holders, vendors, businesses, beneficiaries, partners, third parties, and anyone working with Conzo Africa on a paid or unpaid basis are subject to the terms of this Policy. Any violation of this Policy will result in termination of the customer relationship.

4. Scope and Application

4.1 What is Money Laundering?

Money laundering is the process of converting money or other assets obtained through criminal activity into funds or assets that appear to be of legitimate origin, concealing their illicit source. Any type of asset can constitute criminal property, including cash, cash equivalents, securities, physical products, and intangible assets. Money laundering typically occurs in three stages:

Placement: Introducing illicit funds into the financial system. This may involve splitting funds into smaller amounts or using foreign intermediaries to avoid detection.
Layering: Concealing the illicit origin of funds through a series of transactions designed to break traceability, such as converting funds to digital assets or conducting multiple transfers across jurisdictions.
Integration: Reintroducing the laundered funds into the legitimate financial system as apparently lawful income or assets.

4.2 What is Terrorist Financing?

Terrorist financing is the provision, deposit, distribution, or collection of money or other assets, directly or indirectly, with the knowledge or intention that they will be used — in whole or in part — to finance terrorist acts, terrorist organizations, or individual terrorists.

4.3 Application of This Policy

This AML/CFT Policy applies to all services provided by Conzo Africa, including cryptocurrency trading, gift card marketplace, and bill payment services. It applies to all Customers of these services and all persons working for or on behalf of the Company. The Policy defines the Company's identification and surveillance procedures, customer onboarding and monitoring procedures, CDD tools, risk assessment methods, transaction monitoring, suspicious activity reporting, asset freezing procedures, document archiving, ongoing training, and internal control systems.

4.4 Vulnerable Activities and Predicate Offences

The following activities and persons are considered particularly vulnerable to money laundering and terrorist financing risks on our Platform:

Politically Exposed Persons (PEPs) and their close associates
Persons who participate in organized criminal groups or racketeering
Persons linked to terrorism or terrorist financing activities
Human trafficking and migrant smuggling
Sexual exploitation, including exploitation of children
Illicit trafficking in narcotic drugs and psychotropic substances
Illicit arms trafficking
Trafficking in stolen and other goods
Corruption and bribery
Fraud and identity theft
Counterfeiting of currency
Counterfeiting and piracy of products
Environmental crime
Murder, grievous bodily injury, kidnapping, illegal restraint, and hostage-taking
Robbery, theft, smuggling, and extortion
Forgery, piracy, insider trading, and market manipulation

5. Our Policy and ML/TF Mitigating Measures

Conzo Africa has implemented a comprehensive set of measures specifically designed to reduce the Platform's exposure to money laundering and terrorist financing risks. These mitigating measures include:

Limited, Traceable Digital Assets: The Company supports only a carefully selected range of digital assets, all of which benefit from a high level of blockchain traceability, reducing the risk of untraceable illicit transactions.
Blockchain Analysis Tools: The Company does not support digital assets not covered by our blockchain analysis tools, which limits the risk of the Platform being used for smurfing or structuring purposes.
No Cash Payments: The Company only accepts payments from or to verified bank accounts. Cash payments and prepaid credit card payments are not supported, which significantly limits the risk of illicit funds being introduced from fraudulent sources.
Gift Card Controls: All gift card transactions are subject to identity verification and monitoring to detect and prevent the use of fraudulently obtained gift cards for money laundering purposes.
Real-Time Monitoring: All transactions are monitored in real time by our AI-powered transaction monitoring system, which applies predefined risk rules and scenarios to detect suspicious activity as it occurs.

Despite these measures, the Platform remains vulnerable to certain ML/TF attempts. The Company remains vigilant and continuously reviews and strengthens its controls to address evolving threats.

6. Risk Assessment and Risk-Based Approach

Conzo Africa has conducted a comprehensive risk assessment of its business and operations and identified the following key risk areas relevant to AML/CFT compliance:

Cryptocurrency transactions that may be used for money laundering or terrorist financing
Gift card transactions that may be exploited for layering or integration of illicit funds
Bill payment services used to transfer the proceeds of crime
Transactions involving high-risk countries or jurisdictions designated by the FATF
Transactions involving Politically Exposed Persons (PEPs)
Transactions involving unusually large sums of money inconsistent with the customer's profile

Compliance with AML/CFT obligations is modulated according to a risk-based approach, based on the Risk Assessment and Risk Scoring of each Customer. A customer's country of residence and the nature of their activities directly influence their risk classification.

Conzo Africa groups its customers according to risk level using its established compliance procedures. Risk classification is assigned as Low, Medium, or High, and directly determines the level of due diligence applied, available transaction limits, and the frequency of ongoing monitoring.

6.1 Suspicious Circumstance Indicators

The following changes in a user's circumstances or behavior may be treated as suspicious and will trigger further review:

Unusual transactions that are inconsistent with the customer's known business activities or profile
A sudden, unexplained rise in transaction volume or value from an existing customer
Peak periods of activity at unusual times or from unusual locations
Unfamiliar or atypical transaction types or customer behavior
Situations where the source of funds cannot be easily verified
Complex transactions and unusual transactional patterns with no discernible economic or legal rationale
Funds sent or received from regions with a history of terrorism, high crime rates, or FATF-designated high-risk jurisdictions
Inconsistency between the IP address and the characteristics of the customer
Customer expressing support for a terrorist organization or showing signs of radicalization or violent extremism

The risk assessment will be periodically reviewed and updated to ensure it remains current, accurate, and reflective of the evolving risk landscape.

7. Customer Due Diligence (CDD) and Know Your Customer (KYC)

Preventing financial fraud, money laundering, terrorist financing, and identity theft is central to the operation of Conzo Africa. We have implemented a stringent, internationally aligned Know Your Customer (KYC) procedure that is maintained on an ongoing basis throughout the customer lifecycle.

7.1 Customer Identification and Verification

As part of the account registration process and in compliance with applicable AML/CFT regulations, all customers are required to complete identity verification. The following information and documentation may be required:

Full legal name
Date of birth
Age and nationality
Residential address
Occupation and source of funds
Valid government-issued photo identification (national identity card, international passport, or driver's license)
Bank Verification Number (BVN) — for Nigerian users
Proof of address (utility bill, bank statement, or official government correspondence — dated within the last 3 months)
Selfie or live photo for biometric verification, where required
Source of funds documentation and any other information deemed necessary based on risk assessment

All identity documents are verified using our third-party identity verification partners and cross-checked against relevant sanctions lists, PEP databases, watchlists, and adverse media databases.

7.2 Verification Tiers and Transaction Limits

Conzo Africa operates a tiered verification system that grants progressively higher transaction limits proportionate to the level of identity verification completed. Users who have not completed the verification tier required for a particular transaction type will be restricted from accessing that feature until the required verification is complete.

7.3 Ongoing KYC

Conzo Africa maintains the KYC procedure with its customers on an ongoing basis throughout the business relationship. Customers are expected to update their contact and identification details whenever changes occur. The Company conducts periodic re-verification of user identity, particularly where documents have expired or where a material change in user behavior or profile is detected.

7.4 Customer Due Diligence for Business Customers

Customers classified as Listed Companies or Public Authorities, which by virtue of their regulated activities present a lower risk of money laundering or terrorist financing, may benefit from a streamlined due diligence process. Customers classified as Small and Medium-Sized Businesses (SMBs) and individual users will be subject to full standard due diligence checks, and in higher-risk cases, Enhanced Due Diligence.

8. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied by appropriately authorized compliance personnel in the following circumstances:

Transactions that are unusually large, particularly complex, or lack a discernible economic or legal purpose
Transactions inconsistent with the information provided by the customer or their known profile
Customers identified as Politically Exposed Persons (PEPs) or their close family members and associates
Customers from or transacting with FATF-designated high-risk or non-cooperative jurisdictions
Customers with complex beneficial ownership structures
Any transaction or customer relationship that gives rise to a reasonable suspicion

Where EDD is triggered, the Company shall obtain information from the Customer on the origin of the funds and the purpose of the Transaction by:

Sending the Customer a formal request for further information and documentation.
Collecting any information and documents that justify and explain the nature, origin, and destination of the funds and the purpose of the transaction.

Outcome A — Cleared: If the information and documents provided by the Customer are sufficiently accurate and reliable to dispel any doubt as to the origin and destination of the funds, the Company shall proceed to execute the transaction.

Outcome B — Suspicious: If the Customer fails to provide satisfactory information or documentation, or if suspicion persists, a Suspicious Activity Report (SAR) shall be filed with the NFIU, and the Customer's Risk Score shall be updated accordingly.

In all cases, the nature of the transaction, documents collected, analysis conducted, and any SAR filed shall be recorded in the Customer's EDD file.

9. High-Risk Customers and Politically Exposed Persons (PEPs)

9.1 Categories of High-Risk Customers

Conzo Africa will not onboard or continue to do business with the following categories of customers:

Persons included on any official sanctions list (UN, OFAC, EU, UK, or Nigerian sanctions lists)
Persons with known or suspected involvement in criminal activities based on available information
Persons whose source of funds or legitimacy of business activity cannot be reasonably verified
Persons who refuse to provide the required identity information or documentation
Entities whose shareholder or control structure cannot be adequately determined
Persons or entities designated as Politically Exposed Persons (PEPs) who cannot satisfy Enhanced Due Diligence requirements

9.2 Politically Exposed Persons (PEPs)

PEPs are individuals designated by their governments to perform a public function on their behalf. Due to their access to public funds and positions of authority, PEPs represent a higher risk of involvement in corruption, money laundering, and terrorist financing. PEPs include but are not limited to:

Heads of state, government ministers, and senior government officials
Parliamentarians and senior politicians
Senior judicial officials and military officials
Senior executives of state-owned enterprises
Senior officials of international organizations
Close family members of any of the above (spouses, children, parents, siblings)
Close associates and business partners of any of the above

If any suspicious transactions are detected that are linked to a PEP, Conzo Africa will immediately coordinate with our banking service providers to freeze the associated funds pending further investigation and reporting to the NFIU. The following measures are applied to all PEP relationships:

Enhanced Due Diligence (EDD) applied at onboarding and on an ongoing basis
Senior management approval required before establishing or continuing a PEP relationship
Setting of appropriate transaction limits
Rigorous record keeping of all PEP-related transactions
Continuous KYC review and re-verification
Flagging and investigation of inconsistent IP addresses and unusual transaction patterns

10. Sanctions Screening

Conzo Africa screens all customers and transactions against applicable international and domestic sanctions lists at onboarding and on an ongoing basis, including:

UN Security Council Consolidated Sanctions List
OFAC Specially Designated Nationals (SDN) List
European Union (EU) Consolidated Sanctions List
United Kingdom (UK) Financial Sanctions List
Nigerian Sanctions List issued by the Office of the National Security Adviser (ONSA)
NFIU watchlists and other relevant domestic and international databases

Any match against a sanctions list will result in the immediate blocking of the account or transaction, freezing of associated assets, and reporting to the relevant authorities.

Conzo Africa does not onboard, maintain accounts for, or facilitate transactions on behalf of sanctioned individuals, entities, countries, or regimes under any circumstances.

11. Transaction Monitoring

Conzo Africa actively monitors all transactions conducted on the Platform in real time to detect suspicious or unusual activity. Our transaction monitoring framework combines automated AI-powered systems and manual compliance review procedures.

11.1 Automated Monitoring System

Our centralized Real-Time AI Monitoring System employs advanced Artificial Intelligence and Machine Learning algorithms to continuously analyze all transactions. The system identifies high-risk and potentially suspicious transactions using predefined criteria and rule-based scenarios. Triggers include:

Transactions unusually large or frequent relative to the customer's established profile
Rapid succession of small transactions designed to avoid reporting thresholds (structuring/smurfing)
Transactions involving FATF-designated high-risk jurisdictions or sanctioned entities
Cryptocurrency wallet addresses flagged on blockchain analysis blacklists or associated with known illicit activity
Unusual patterns of gift card purchases, sales, or bill payments inconsistent with normal user behavior
Multiple failed transaction attempts or repeated small transactions suggesting testing of system controls
Transactions with no apparent legitimate business or personal purpose
IP address anomalies, including use of VPN or anonymizing tools, inconsistency between IP location and stated residence, or shared IP addresses across multiple accounts

11.2 Alert Management

As soon as a suspicious transaction is identified, automated alerts and emails are forwarded to the MLRO and the compliance management team. Each alert is examined in accordance with the AML/CFT rule or scenario under which it was generated. Depending on the outcome of the review:

The transaction may be cleared and processed if the review reveals a legitimate explanation
The transaction may be temporarily restricted or suspended pending further investigation
A SAR or STR may be filed with the NFIU where reasonable suspicion is confirmed
The issue may be escalated to include other relevant internal and external parties

11.3 Manual Review

In addition to automated monitoring, the compliance team conducts manual reviews of flagged accounts and transactions. Manual review takes into account customer profile, transaction history, IP address analysis, publicly available information, and any additional information provided by the customer.

12. Transaction Recording and Limits

For every successful transaction processed through the Conzo Africa Platform, the following information is recorded and retained:

Transaction Identification Number / Transaction Hash
The equivalent transaction value in Naira, US Dollars, or other applicable currency
Recipient wallet address or payment destination
Transaction date and time
Alphanumeric unique transaction identification token
Success or failure response code for the transaction
IP address of the originating device
Identity of the customer initiating the transaction

Transaction limits are applied on a tiered basis in accordance with the customer's verified identity level and assigned risk classification. Customers who have not completed higher verification tiers are subject to lower transaction limits until the required verification is completed.

13. Suspicious Activity Reports (SAR) and Reporting Procedures

13.1 When to File a SAR

A Suspicious Activity Report (SAR) must be sent to the NFIU where a transaction:

Involves a frequency that is unjustifiable or unreasonable
Is surrounded by conditions of unusual or unjustified complexity
Appears to have no economic justification or lawful objective
Is inconsistent with the known transaction pattern of the account or business relationship
In the opinion of the Company, involves the proceeds of criminal activity, unlawful act, money laundering, or terrorist financing

13.2 Who Can File a SAR

The Money Laundering Reporting Officer (MLRO) is the sole decision-maker and the only person authorized to file a SAR with the NFIU on behalf of the Company. In urgent cases where the MLRO is unavailable, any trained Officer or employee who has undergone the relevant emergency procedure training may take the initiative to report suspicions where the analysis of the alert justifies it.

13.3 Internal Reporting Procedure

Any employee, contractor, or business partner who becomes aware of any suspicion or knowledge of possible AML/CFT activity must report this without undue delay to the MLRO at support@conzo.africa. The internal report must include, at a minimum:

Identity of the person raising the suspicion
Date of the report
Identity of the person or entity suspected of money laundering or terrorist financing
Other individuals or entities involved
Full delivery of the relevant facts and circumstances
The nature of the suspicion and the reasons for it
Any possible involvement of the Company and steps to limit such involvement

Details of all internal reports will be held separately from customer files to prevent inadvertent or inappropriate disclosure.

13.4 Content of the SAR Filed with NFIU

Where the MLRO determines that a SAR is warranted, the SAR submitted to the NFIU shall include the following:

The profession exercised by the reporting person, i.e. provider of crypto and gift card services
Identification details and professional contact details of the MLRO
Identification details of the Customer and, where applicable, the Ultimate Beneficial Owner (UBO)
The purpose and nature of the business relationship
The reason for reporting
A description of the transaction and the elements of analysis that led to the report
Where the transaction has not yet been executed, the expected execution deadline
Any other documents or information that may be useful to the NFIU

13.5 Tipping-Off Prohibition

No employee, officer, contractor, or user of the Conzo Africa Platform shall disclose to a suspect, customer, or any other unauthorized person that a SAR has been filed, that a money laundering investigation is underway, or that an account or transaction has been reported to the NFIU or any other authority. This tipping-off prohibition is a strict legal obligation, and violation constitutes a serious criminal offence.

13.6 Protection for Good Faith Reporting

No civil or criminal liability shall be imposed on Conzo Africa or any of its employees for any SAR made in good faith. In the event of damage resulting directly from such a report or disclosure, the relevant National Authority or Agency shall bear liability for the damage suffered. These protections apply even where the SAR has not been acted upon or where the reported transaction has already been executed.

14. Freezing Measures

Upon publication of the UN Consolidated List of persons and entities designated under UN Security Council Resolutions (UNSCRs) relating to the prevention and disruption of the financing of proliferation of weapons of mass destruction, Conzo Africa — in compliance with applicable Nigerian law — shall immediately identify and freeze all funds, assets, and economic resources belonging to a designated person or entity in its possession and report same to the Nigeria Sanctions Committee.

The freezing obligation extends to:

All funds or assets owned or controlled by the designated person or entity, not just those tied to a specific act or threat
Funds or assets wholly or jointly owned or controlled — directly or indirectly — by designated persons or entities
Funds or assets derived or generated from funds owned or controlled by designated persons or entities
Funds or assets of persons or entities acting on behalf of or at the direction of designated persons or entities

Where the Company holds funds or digital assets on behalf of a customer at the time a SAR is filed, the Company shall suspend execution of the relevant transaction to allow the NFIU to exercise its right of opposition until the execution deadline. Following this:

If the NFIU does not object, the customer's transaction may proceed
If the NFIU notifies its opposition, the funds or digital assets are blocked for a further period of ten (10) days from the date of the NFIU's notification, or until receipt of a No-Objection notice

15. Record Keeping

Conzo Africa maintains comprehensive and accurate records of all AML/CFT compliance activities. All customer information is stored electronically. In accordance with Section 8 of the Money Laundering (Prevention and Prohibition) Act 2022, records are kept for the duration of the relationship with the customer and for a minimum of five (5) years after the relationship ends.

The following records are maintained:

Customer identification and KYC documents: minimum 5 years after the end of the relationship
Transaction records: minimum 5 years from the date of the transaction
Suspicious Activity Reports (SARs) and all supporting EDD documentation: minimum 5 years from date of filing
Correspondence with the NFIU, CBN, EFCC, and other regulatory authorities: minimum 5 years
AML/CFT training records: minimum 5 years
Internal audit and compliance review reports: minimum 5 years

Where a country's local legal requirements prescribe a longer retention period than five years, the legally required timeframe shall apply. All records are stored securely with access restricted to authorized personnel on a strict need-to-know basis.

Conzo Africa shall, within 24 hours, forward reports of suspicious transactions relating to terrorism, terrorist financing, or proliferation financing to the NFIU.

16. Real-Time Transaction Monitoring

All transactions on the Conzo Africa Platform are monitored by a centralized Real-Time Artificial Intelligence Monitoring System, which employs advanced AI and Machine Learning algorithms to analyze transactions as they occur.

The system recognizes high-risk and potentially suspicious transactions using predefined criteria, risk rules, and scenarios calibrated to our specific product and customer risk profile. As soon as a suspicious transaction is identified:

Automated email alerts are sent to the MLRO and senior compliance management
The alert is examined in accordance with the AML rule or scenario under which it was generated
The transaction is investigated using applicable AML standards
The issue is resolved at the compliance level or escalated to include other relevant internal and external parties as necessary

17. Compliance Monitoring and Management

The MLRO routinely monitors the following processes to ensure they are carried out in full compliance with the Company's AML/CFT policies and procedures:

Customer identity verification and KYC completion
Suspicious transaction detection and reporting
Record keeping and document archiving
Sanctions screening and PEP identification
Transaction monitoring alert review and resolution

Senior Management and the compliance team also monitor all adjustments and requirements issued by the supervisory authority overseeing AML/CFT compliance. The Company's AML/CFT policies and procedures are modified as needed to maintain full regulatory compliance.

Conzo Africa has designated a Chief Compliance Officer (CCO) / MLRO with the authority, independence, and resources necessary to implement and maintain the AML/CFT compliance program. The CCO reports directly to senior management and the Board of Directors on all material compliance matters.

18. AML/CFT Training and Awareness

Conzo Africa provides comprehensive, mandatory AML/CFT training to all employees, contractors, and relevant business partners to ensure they are aware of their obligations and equipped to identify and manage potential financial crime risks.

Training is provided on an ongoing basis and includes:

Induction training for all new employees covering AML/CFT fundamentals, red flags, internal reporting procedures, and the tipping-off prohibition
Annual AML/CFT refresher training tailored to each employee's specific organizational function and risk exposure
Specialized training for Key Personnel — employees in roles involving direct customer contact or transaction review
Training on recognizing suspicious activity indicators and escalation procedures
Updates on regulatory developments, emerging financial crime typologies, and changes to internal policies

The Company also raises awareness among its customers about the risks of money laundering and terrorist financing through educational content on the Platform.

Training records are maintained by the Compliance Officer and are available for regulatory inspection upon request.

19. Policy Review and Audits

The effectiveness of this Policy is continually assessed. This Policy is reviewed at least annually, or more frequently where required by material changes in the regulatory environment, business operations, risk landscape, or guidance from regulatory authorities.

Policy reviews provide senior executive management with the assurance and information necessary to assess the efficiency of the Company's AML/CFT controls and processes. All amendments are documented, approved by senior management, communicated to relevant personnel, and made effective from the date of publication.

Conzo Africa also conducts regular independent internal audits of its AML/CFT compliance program. Audit findings are reported to the Board of Directors and used to continuously improve the Program.

20. Prohibited Activities

The following activities are strictly prohibited on the Conzo Africa Platform and will result in immediate account suspension, asset freezing, and reporting to the relevant authorities:

Using the Platform to launder the proceeds of any criminal activity
Using the Platform to finance or support terrorist activities, terrorist organizations, or individual terrorists
Providing false, misleading, or fraudulent information during KYC, account registration, or any due diligence process
Structuring transactions to avoid reporting thresholds or compliance controls (smurfing)
Using the Platform on behalf of a sanctioned individual, entity, country, or regime
Creating multiple accounts to circumvent compliance controls, transaction limits, or account bans
Transferring funds derived from fraud, theft, corruption, bribery, tax evasion, or any other predicate offence
Purchasing, selling, or transferring gift cards obtained through fraudulent or criminal means
Facilitating transactions for undisclosed third parties without appropriate authorization
Engaging in insider trading, market manipulation, or any activity designed to distort market integrity
Any other activity that violates applicable AML/CFT laws and regulations

21. User Responsibilities

All users of the Conzo Africa Platform are expected to play an active and cooperative role in supporting our AML/CFT compliance efforts. By using our Services, you agree to the following responsibilities:

Legal Compliance: You agree to comply with all applicable laws and regulations in your jurisdiction, including AML/CFT laws, financial regulations, and any restrictions on the use of cryptocurrency.
Truthful Information: You agree to provide accurate, complete, and up-to-date information at all times during the KYC process and throughout your use of the Platform.
Own Account Use Only: You agree to use the Platform solely for your own benefit and not on behalf of any undisclosed third party without appropriate authorization.
Legitimate Funds: You represent and warrant that all funds transacted through the Platform are derived from legitimate sources and are not the proceeds of any criminal activity.
Cooperation with Verification: You agree to cooperate promptly with any additional verification requests, EDD procedures, or due diligence reviews initiated by Conzo Africa.
Reporting Suspicious Activity: If you become aware of any suspicious, fraudulent, or illicit activity on or relating to the Platform, you agree to report it immediately to support@conzo.africa.

22. Consequences of Non-Compliance and Violations

Any breach of this Policy — whether deliberate or unintentional — must be reported to the Chief Executive Officer for escalation to the Board of Directors. Violations of the values, rules, and obligations set out in this Policy or any related policy will be treated as a serious breach of company policy.

22.1 For Users

Users found to be in violation of this Policy or applicable AML/CFT laws will be subject to one or more of the following:

Immediate suspension or permanent termination of their Account
Freezing of associated funds and digital assets pending investigation
Reporting to the NFIU, CBN, EFCC, ICPC, or other relevant regulatory and law enforcement authorities
Civil or criminal legal proceedings, where appropriate

22.2 For Employees and Contractors

Any employee, officer, or contractor of Conzo Africa who fails to comply with this Policy, fails to report suspicious activity, knowingly deceives or obstructs AML/CFT investigations, or assists in the facilitation of financial crime will be subject to disciplinary action up to and including immediate termination of employment or contract. Their conduct may also be referred to the relevant regulatory or law enforcement authorities and may result in personal criminal liability.

22.3 For Third-Party Agents and Partners

If third-party agents or business partners violate the terms of this Policy, knowingly conceal misconduct, fail to report to Conzo Africa, or purposefully distort investigations, their contract or partnership agreement with the Company is subject to immediate termination.

23. Statement of Intent

To fully comply with all applicable local and international laws — including the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, the CBN AML/CFT Regulations, anti-corruption laws, and all laws prohibiting terrorist financing — all Conzo Africa employees, contractors, and business partners are obligated to adhere to this Policy.

Conzo Africa is committed to maintaining the highest standards of AML/CFT compliance and to building a safe, trusted, and responsible financial platform. We view compliance not as a burden but as a cornerstone of our mission to empower Africa through legitimate and transparent financial services.

24. Contact and Reporting

If you have any questions about this AML/CFT Policy, wish to report a compliance concern, or need to report suspicious activity, please contact our Compliance Team immediately:

Conzo Africa Compliance / MLRO Team

Compliance Email: support@conzo.africa

General Support: support@conzo.africa

Legal & Regulatory: support@conzo.africa

Website: www.conzo.africa

All compliance reports and concerns are treated with the strictest confidentiality. Reports made in good faith will not expose the reporting person to any civil, criminal, or employment-related liability.

Anti-Money Laundering (AML) & Counter-Terrorist Financing (CFT) Policy