Anti-Money Laundering Policy

1. INTRODUCTION

Manilla Finance (“Manilla”, “we”, “us” or “our”) is committed to maintaining a secure, transparent and responsible financial ecosystem.

We recognise the importance of preventing the use of our platform and services for money laundering, terrorist financing, proliferation financing, fraud, sanctions violations and other financial crimes.

Our Anti Money Laundering, Counter Terrorist Financing and Counter Proliferation Financing (AML/CFT/CPF) framework incorporates customer identification, Know Your Customer (KYC) procedures, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), sanctions screening, transaction monitoring, suspicious activity reporting, record keeping and ongoing risk assessments.

We adopt a risk based approach to compliance and work with regulated financial institutions, payment service providers and technology partners, where applicable, to support the integrity and security of our services.

2. PURPOSE AND SCOPE

This Policy establishes the principles and procedures adopted by Manilla to prevent its products, services, infrastructure and business relationships from being used for unlawful financial activities.

This Policy applies to:

A. Individuals and businesses using Manilla’s products and services.

B. Customers engaging in digital asset transactions, transfers, conversions and payments.

C. Customers using cross border payment and remittance services, where available.

D. Employees, management, contractors and authorised representatives.

E. Third party service providers and business partners, where relevant to their roles and responsibilities.

This Policy applies throughout the customer relationship, from onboarding and identity verification to transaction processing, ongoing monitoring and account closure.

3. REGULATORY AND LEGAL FRAMEWORK

Manilla’s AML/CFT/CPF framework is informed by applicable Nigerian legislation, regulatory requirements and internationally recognised financial crime prevention standards.

These include, where applicable:

A. Money Laundering (Prevention and Prohibition) Act, 2022.

B. Terrorism (Prevention and Prohibition) Act, 2022.

C. Nigerian Financial Intelligence Unit Act, 2018.

D. Nigeria Data Protection Act, 2023.

E. Applicable Securities and Exchange Commission rules and AML/CFT/CPF requirements.

F. Applicable regulations, directives and guidance issued by competent Nigerian authorities.

G. Financial Action Task Force (FATF) Recommendations concerning money laundering, terrorist financing and virtual assets.

Manilla periodically reviews developments in applicable laws, regulatory guidance and industry standards to support the continued effectiveness of its compliance framework.

4. KNOW YOUR CUSTOMER (KYC)

Manilla maintains customer identification and verification procedures designed to establish the identity of individuals and businesses accessing its services.

A. Individual Customers

Depending on the service and assessed risk, customers may be required to provide:

1. Full legal name.

2. Date of birth.

3. Residential address.

4. Nationality and country of residence.

5. Valid government issued identification.

6. Bank Verification Number (BVN) or National Identification Number (NIN), where applicable.

7. Verified telephone number and email address.

8. Additional information or supporting documentation reasonably required for identity verification.

B. Business Customers

Business customers may be required to provide:

1. Registered business name and registration details.

2. Corporate Affairs Commission (CAC) registration documents, where applicable.

3. Registered business address and nature of business activities.

4. Details of directors and authorised representatives.

5. Information identifying ultimate beneficial owners.

6. Information concerning the source of funds and expected transaction activities.

7. Additional corporate, financial and compliance documentation where required.

Manilla may use authorised third party verification providers and reliable independent sources to validate customer information.

Customers who fail to complete required verification may be denied access to certain services, subjected to transaction restrictions or prevented from establishing or continuing a business relationship, as appropriate.

5. CUSTOMER DUE DILIGENCE (CDD)

Manilla applies Customer Due Diligence procedures to establish the identity, ownership, nature and risk profile of its customers.

Our CDD procedures include:

A. Identifying customers and verifying their identities using reliable, independent sources.

B. Identifying and verifying beneficial owners, where applicable.

C. Understanding the purpose and intended nature of business relationships.

D. Assessing customer risk based on relevant factors.

E. Establishing expected transaction patterns and activities where appropriate.

F. Monitoring customer relationships and transactions on an ongoing basis.

G. Updating customer information when necessary.

Customer due diligence is conducted before or during the establishment of a business relationship where permitted by applicable law, and whenever additional verification becomes necessary.

Manilla reserves the right to request further information or documentation at any stage of a customer relationship.

6. RISK BASED APPROACH

Manilla adopts a risk based approach to identifying, assessing and mitigating financial crime risks.

Customer relationships and transactions may be assessed using factors including:

A. Customer identity, occupation and business activities.

B. Geographic location and jurisdictional exposure.

C. Source of funds and source of wealth.

D. Transaction frequency, volume and value.

E. Types of financial services and digital assets used.

F. Exposure to politically exposed persons.

G. Connections to high risk jurisdictions.

H. Unusual or inconsistent transaction behaviour.

Customers and transactions may be assigned different risk classifications based on the results of these assessments.

The level of due diligence, monitoring and verification applied may vary according to the assessed risk and applicable legal requirements.

7. ENHANCED DUE DILIGENCE (EDD)

Manilla applies Enhanced Due Diligence measures to customers, transactions and business relationships presenting elevated financial crime risks.

Enhanced due diligence may be required for:

A. Politically Exposed Persons (PEPs), their family members and close associates, where applicable.

B. Customers connected to high risk jurisdictions.

C. Complex or unusually large transactions.

D. Customers with unclear or unverifiable sources of funds.

E. Business structures with complex or opaque ownership arrangements.

F. Transactions inconsistent with a customer’s established financial profile.

G. Other relationships or activities identified as presenting heightened risks.

Enhanced due diligence measures may include:

1. Additional identity verification.

2. Requests for supporting financial documentation.

3. Verification of source of funds or source of wealth.

4. Additional verification of beneficial ownership.

5. Senior management approval where required.

6. Increased transaction monitoring.

7. More frequent customer information reviews.

Manilla may decline, restrict or terminate business relationships where identified risks cannot be adequately mitigated, subject to applicable law.

8. POLITICALLY EXPOSED PERSONS (PEPs)

Manilla recognises that relationships involving politically exposed persons may require additional scrutiny because of potential exposure to bribery, corruption or the misuse of public funds.

Our compliance procedures include screening customers and relevant beneficial owners for PEP status.

Where a customer is identified as a PEP, Manilla conducts an appropriate risk assessment and applies enhanced due diligence where required.

PEP status does not automatically prohibit a customer from accessing Manilla’s services. However, additional verification, senior management approval and ongoing monitoring may be required depending on the assessed risk and applicable legal requirements.

9. SANCTIONS SCREENING AND COMPLIANCE

Manilla maintains sanctions screening procedures designed to identify individuals, entities and transactions subject to applicable financial sanctions and restrictions.

Screening may include relevant sanctions lists issued or recognised by:

A. The United Nations Security Council.

B. The Nigeria Sanctions Committee and other competent Nigerian authorities.

C. Other applicable sanctions authorities where legally relevant to the transaction, customer or business relationship.

Customers and relevant counterparties may be screened during onboarding and periodically throughout the business relationship.

Where a potential sanctions match is identified, Manilla may conduct further verification, restrict transactions or take other appropriate measures.

Where legally required, Manilla will implement applicable asset freezing measures and make the necessary notifications or reports to competent authorities.

10. TRANSACTION MONITORING

Manilla maintains transaction monitoring procedures designed to identify unusual, suspicious or potentially unlawful financial activities.

Our monitoring framework considers transaction patterns, customer risk profiles and other relevant indicators.

Activities that may require additional investigation include:

A. Transactions inconsistent with a customer’s known financial profile.

B. Unusually large or frequent transactions without an apparent legitimate purpose.

C. Attempts to divide transactions to evade reporting or verification requirements.

D. Rapid movement of funds through multiple accounts or digital asset wallets.

E. Transactions involving high risk jurisdictions or counterparties.

F. Activities involving potentially fraudulent or illicit digital asset addresses.

G. Unexplained changes in transaction behaviour.

H. Attempts to conceal the origin, ownership or destination of funds.

Transactions identified as potentially suspicious may be referred for additional compliance review.

Manilla may request supporting documentation, temporarily restrict transactions or take other measures consistent with applicable laws and contractual obligations.

11. DIGITAL ASSET COMPLIANCE AND BLOCKCHAIN MONITORING

Given the nature of digital asset transactions, Manilla incorporates digital asset specific risk controls into its compliance framework.

These controls are designed to address risks associated with virtual asset transfers, digital wallets, blockchain transactions and the movement of digital assets between counterparties.

Our compliance approach includes, where applicable:

A. Screening digital asset wallet addresses for identified risk indicators.

B. Monitoring transactions for exposure to potentially illicit activities.

C. Assessing risks associated with digital asset counterparties.

D. Identifying unusual digital asset transaction patterns.

E. Applying enhanced scrutiny to transactions involving elevated risk wallets or services.

F. Maintaining relevant transaction information for compliance and investigation purposes.

Manilla may restrict transactions involving digital assets, wallet addresses or counterparties that present unacceptable financial crime risks.

12. SUSPICIOUS TRANSACTION REPORTING

Manilla maintains internal procedures for identifying, reviewing, escalating and reporting suspicious financial activities.

Where suspicious activity is identified, the matter is referred to the designated compliance function for assessment.

Where a reporting obligation arises, suspicious transactions or activities will be reported to the Nigerian Financial Intelligence Unit (NFIU) or other competent authorities, as required by applicable law.

Manilla may also cooperate with lawful requests for information from relevant regulatory, supervisory and law enforcement authorities.

To protect the integrity of investigations and comply with applicable confidentiality requirements, Manilla will not disclose suspicious transaction reports or related confidential information to unauthorised persons.

13. PROHIBITED ACTIVITIES

Manilla prohibits the use of its services for unlawful activities, including:

A. Money laundering and terrorist financing.

B. Financing the proliferation of weapons of mass destruction.

C. Fraud, scams and identity theft.

D. Transactions involving proceeds of crime.

E. Sanctions evasion.

F. Unauthorised use of another person’s identity or account.

G. Deliberate concealment of beneficial ownership.

H. Transactions designed to evade applicable compliance requirements.

I. Other activities prohibited by applicable laws or Manilla’s Terms of Service.

Manilla may investigate suspected violations and take appropriate action, including account restrictions, transaction suspension, termination of services or reporting to competent authorities.

14. ACCOUNT RESTRICTIONS AND SUSPENSION

Manilla reserves the right, subject to applicable laws and contractual obligations, to restrict, suspend or terminate access to its services where:

A. A customer fails to complete required identity verification.

B. Submitted information is materially false, misleading or unverifiable.

C. A transaction raises significant financial crime concerns.

D. A customer or transaction is subject to applicable financial sanctions.

E. A customer violates this Policy or other applicable platform terms.

F. Continued service would expose Manilla or its partners to unacceptable legal or compliance risks.

G. Restrictions are required by a competent authority or applicable law.

Where appropriate and legally permitted, affected customers may be requested to provide additional information or documentation.

Account restrictions may remain in place while compliance reviews or legally required procedures are completed.

Nothing in this Policy authorises Manilla to freeze or retain customer assets beyond its lawful authority.

15. RECORD KEEPING AND RETENTION

Manilla maintains records necessary to support compliance, transaction traceability, regulatory reporting and lawful investigations.

These may include:

A. Customer identification and verification records.

B. Customer due diligence documentation.

C. Transaction histories and supporting information.

D. Beneficial ownership records.

E. Risk assessments and compliance reviews.

F. Relevant communications and investigation records.

G. Records of regulatory reports and lawful information requests.

Records are retained for the minimum periods required by applicable Nigerian law, including applicable five year retention requirements, or for longer where legally required.

Manilla implements appropriate administrative, technical and organisational measures to protect retained information against unauthorised access, alteration, disclosure or loss.

16. DATA PROTECTION AND CONFIDENTIALITY

Manilla recognises the importance of protecting personal and financial information collected during compliance processes.

Personal data is processed in accordance with applicable data protection laws, including the Nigeria Data Protection Act, 2023.

Information collected for KYC, customer due diligence, transaction monitoring and regulatory compliance is used for legitimate and lawful purposes.

Manilla may share relevant information with authorised service providers, regulated partners, competent authorities and other parties where necessary and legally permitted.

Access to sensitive compliance information is restricted to authorised personnel and service providers with a legitimate need to access such information.

Additional information concerning personal data processing is provided in Manilla’s Privacy Policy.

17. THIRD PARTY AND REGULATED PARTNERS

Manilla works with regulated financial institutions, payment service providers, technology providers and other third parties to support the delivery of its services.

We apply risk based due diligence when selecting and maintaining relevant third party relationships.

Our partner compliance framework considers:

A. Applicable regulatory authorisations.

B. Reputation and business integrity.

C. Financial crime prevention controls.

D. Data security and privacy practices.

E. Operational capabilities.

F. Relevant contractual and compliance obligations.

Where compliance activities are performed by third parties, Manilla maintains appropriate oversight of its own responsibilities.

Working with regulated partners does not remove Manilla’s obligation to maintain applicable internal compliance controls.

18. INTERNAL CONTROLS AND COMPLIANCE GOVERNANCE

Manilla maintains internal compliance procedures designed to support the effective implementation of this Policy.

These include:

A. Defined responsibilities for financial crime prevention.

B. Designated compliance oversight.

C. Internal reporting and escalation procedures.

D. Customer and transaction risk assessment processes.

E. Periodic review of compliance controls.

F. Appropriate segregation of responsibilities.

G. Management oversight of material compliance risks.

H. Procedures for responding to regulatory enquiries and lawful requests.

Compliance issues are escalated through appropriate internal channels for assessment and resolution.

19. EMPLOYEE TRAINING AND AWARENESS

Manilla provides relevant compliance training and awareness programmes to employees and personnel whose responsibilities may expose them to financial crime risks.

Training may cover:

A. AML/CFT/CPF obligations.

B. Customer identification and verification.

C. Suspicious activity identification.

D. Sanctions and PEP screening.

E. Digital asset related financial crime risks.

F. Internal escalation and reporting procedures.

G. Confidentiality and information security.

Training requirements are reviewed periodically to reflect changes in legal obligations, emerging risks and operational requirements.

20. COOPERATION WITH REGULATORY AND LAW ENFORCEMENT AUTHORITIES

Manilla is committed to cooperating with competent regulatory, supervisory, financial intelligence and law enforcement authorities in accordance with applicable laws.

This cooperation may include responding to lawful requests for information, preserving relevant records, submitting required reports and implementing legally binding directives.

Manilla will maintain appropriate confidentiality and protect customer information while fulfilling its legal obligations.

21. CUSTOMER RESPONSIBILITIES

Customers are expected to use Manilla’s products and services lawfully and responsibly.

Customers are required to:

A. Provide accurate and complete information during registration and verification.

B. Keep relevant account information up to date.

C. Respond to reasonable compliance related requests.

D. Use their accounts only for lawful purposes.

E. Refrain from conducting transactions on behalf of undisclosed third parties.

F. Avoid activities intended to circumvent identity verification, transaction monitoring or other compliance controls.

G. Notify Manilla of suspected unauthorised account activity.

Failure to comply with these responsibilities may result in restrictions or other appropriate measures.

22. POLICY REVIEW AND UPDATES

Manilla periodically reviews this Policy to reflect changes in applicable laws, regulatory expectations, financial crime risks, operational practices and industry standards.

We reserve the right to amend or update this Policy when necessary.

The latest published version will be made available through our official website.

23. CONTACT AND COMPLIANCE ENQUIRIES

For questions relating to this Policy, identity verification or compliance requirements, customers may contact Manilla Finance through its official support and compliance channels.

Manilla Finance

Department: Compliance

Country: Nigeria

Email: [Insert official compliance email address]

24. OUR COMMITMENT

At Manilla Finance, financial integrity is fundamental to building a trusted digital financial ecosystem.

We are committed to maintaining effective compliance controls, protecting our platform against financial crime and promoting responsible access to digital financial services.

Through continuous monitoring, risk management, employee awareness and cooperation with relevant stakeholders, we aim to uphold high standards of transparency, accountability and operational integrity.