Anti-Money Laundering (AML) Policy

1. Policy Statement

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy sets out the framework used by CYPHALET INC, a cross-border payment and settlement platform serving African importers, to detect, prevent, and report money laundering, terrorist financing, fraud, and other financial crimes.

We recognize our responsibilities under applicable laws and regulations in the jurisdictions where we operate, including but not limited to the Bank Secrecy Act (BSA) and USA PATRIOT Act, and are committed to preventing our platform from being used for money laundering, terrorist financing, or other financial crimes.

Our platform facilitates:

• International supplier payments
• Crypto-to-fiat settlements (e.g., USDT/USDC → USD, NGN, ZAR, KES, GHS)
• B2B cross-border trade payments
• Multi-currency wallets and merchant onboarding

2. Objectives

• Prevent, detect, contain, and report any suspicious activities that may indicate money laundering or terrorist financing.
• Identify and verify all customers (KYC/KYB) using a risk-based approach.
• Comply with all applicable AML/CTF laws and regulatory frameworks in the United States and across Africa where our users operate.
• Monitor customer behaviours, transactions, and anomalies.
• File Suspicious Activity Reports (SARs) with competent authorities.
• Follow international best practices for crypto-related transactions.
• Maintain transparent and auditable records for regulatory and compliance reviews.
• Provide adequate training and tools to team members responsible for AML compliance.

3. Scope of Application

This policy applies to:

• All users of the CYPHALET INC platform, both individuals and businesses.
• All CYPHALET INC employees, agents, partners, and stakeholders involved in onboarding, transaction monitoring, and compliance.
• All activities on the platform, including funding in local currencies, conversion to USD, and cross-border disbursements to suppliers, auction houses, and shippers.

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

CYPHALET INC requires all users to complete full KYC before conducting any financial transactions. This includes:

• Individuals: Government-issued ID, proof of address, selfie verification, source of funds, purpose of transactions.
• Businesses: Certificate of Incorporation, business registration documents, shareholder and beneficial ownership (UBO) verification, board resolution (for financial authorization), company tax certificate, trade documents (proforma invoice, bill of lading), source of funds / transaction justification, and authorization to transact.

KYC and verification are powered by third-party services that meet global compliance standards. All user data is encrypted and stored securely.

5. Monitoring and Risk Assessment

CYPHALET INC implements a risk-based approach to monitor user activities:

• Real-time monitoring of all transactions to detect suspicious patterns (e.g., unusually high frequency, rapid movement of funds without business justification, repetitive small transactions (structuring), mismatched customer profile vs. activity, or blacklisted destinations).
• Flagging and manual review of transactions that exceed predefined limits or match suspicious behaviour profiles.

6. Record Keeping

We maintain comprehensive records of all user verifications, transactions, and AML reviews for a minimum of 5 years, as required by law. These may be shared with regulators upon request or in compliance with legal obligations.

7. Reporting Suspicious Activities

All suspicious activities will be reported to the appropriate regulatory bodies, such as:

• FinCEN in the United States
• ICPC and EFCC in Nigeria
• Nigerian Financial Intelligence Unit (NFIU)
• Local financial intelligence units (FIUs) in African jurisdictions where users operate.

The Compliance Officer is responsible for reviewing internal reports and determining whether to escalate or file a Suspicious Activity Report (SAR).

8. Compliance

Our compliance team is responsible for overseeing the implementation of the AML program.

• They are responsible for enforcing KYC/AML procedures across all levels of the organization and for ensuring that every employee applies them consistently.
• Monitoring transactions and reviewing red flags.
• Conducting compliance training for staff.
• Acting as a liaison with regulatory authorities.

9. Staff Training

All team members involved in compliance, onboarding, or payment processing receive regular training to:

• Identify and escalate suspicious activity.
• Stay current with regulatory updates and emerging risks.
• When major policy/regulatory changes occur.
• Understand and follow internal AML compliance procedures.

10. Policy Review

This AML Policy is reviewed at least once annually or whenever there are changes in applicable laws or the nature of CYPHALET INC operations.