Anti-Money Laundering & Counter-Terrorism Financing Compliance

Effective Date: August 1, 2025

Last Reviewed: August 1, 2025

QASHR Technologies Ltd (“QASHR”, “we”, “us”, or “our”) is fully committed to the prevention of money laundering, terrorist financing, and other forms of financial crime. As a fintech operating in Nigeria, we maintain a robust compliance framework designed to detect, prevent, and report suspicious activity in accordance with the Money Laundering (Prohibition) Act, 2011 (as amended), the Terrorism (Prevention) Act, 2011, the CBN AML/CFT Guidelines, and directives of the Nigerian Financial Intelligence Unit (NFIU).

1. Our Commitment

We uphold a zero-tolerance policy for money laundering, terrorist financing, fraud, and any illicit use of our services. Our policies are designed to:

• Detect and deter suspicious financial activities
• Comply with all legal and regulatory obligations
• Protect the integrity of Nigeria’s financial system
• Build trust across our user and partner ecosystem

2. Regulatory Compliance

We operate in compliance with:

• Money Laundering (Prohibition) Act, 2011 (as amended)
• Terrorism (Prevention) Act, 2011 (as amended)
• Central Bank of Nigeria AML/CFT Regulations
• NFIU Reporting Guidelines
• NDPR (Nigeria Data Protection Regulation)
• FATF Recommendations (as applicable)

3. Know Your Customer (KYC)

We apply a risk-based KYC process for all users and liquidity agents:

• Tiered account verification based on volume and activity
• Government-issued ID validation (NIN, BVN, Voter’s Card, etc.)
• Selfie or liveness detection for face match
• Address verification when required
• Continuous monitoring for unusual activity

4. Transaction Monitoring

We implement real-time and post-transaction monitoring to identify:

• Structuring or layering patterns
• Abnormal volume or frequency
• High-risk geographical areas
• Rapid movement of funds between users
• Suspicious behavioral changes

5. Suspicious Activity Reporting (SAR)

We maintain procedures to file SARs with the NFIU confidentially and diligently when appropriate.

6. Record Keeping

In line with regulatory guidelines, we retain:

• Customer identification records: minimum of 5 years after account closure
• Transaction and communication logs: 5–7 years
• All SAR filings and investigations as required by law

7. Employee Training & Internal Controls

All QASHR employees and partners with access to sensitive data are:

• Trained regularly on AML/CTF laws and responsibilities
• Required to follow strict data handling and escalation policies
• Bound by confidentiality and anti-corruption clauses
• Subject to periodic internal audits and compliance reviews

8. Sanctions & PEP Screening

We screen all users and counterparties against:

• Local and international sanctions lists (OFAC, UN, EU)
• PEP watchlists
• Terrorist financing databases

Engagements with flagged individuals or entities are restricted or prohibited.

9. Reporting Obligations

We comply with:

• Currency Transaction Reports (CTR) where applicable
• SARs/STRs to the NFIU
• Prompt cooperation with law enforcement or judicial orders

10. Contact Our Compliance Officer

• Email: compliance@qashr.com
• Address: 8 Providence Street, Lekki Phase 1, Lagos, Nigeria
• Website: www.qashr.com

Disclaimer: This AML/CTF Compliance Statement may be reviewed and updated periodically to reflect regulatory changes or improvements in our risk management approach.