Anti-Money Laundering, Countering Financial Terrorism, and Countering Proliferation Financing Policy

Introduction

PLUG DOT NG LIMITED, a leading provider of Mobile Money Operating Services and Payment Service Solution Services in Nigeria, is committed to preventing and detecting money laundering, financial terrorism, and proliferation financing. This policy outlines our approach to identifying, assessing, and mitigating these risks.

Scope

This policy applies to all PLUG DOT NG LIMITED’s employees, agents, and third-party service providers involved in the provision of Mobile Money Operating Services and Payment Service Solution Services.

Definitions

• Money Laundering: the process of disguising the source of illegally obtained funds to make them appear legitimate.
• Financial Terrorism: the financing of terrorist activities or organizations.
• Proliferation Financing: the financing of activities related to the proliferation of weapons of mass destruction.
• Customer Due Diligence (CDD): the process of identifying and verifying the identity of customers.
• Know Your Customer (KYC): the process of understanding a customer's business and risk profile.
• Mobile Money: a financial service that allows users to store, send, and receive money using their mobile phones.
• Payment Service Solution Services: services that enable merchants to accept payments from customers.

Anti-Money Laundering (AML) Program

Our AML program consists of the following components:

• Customer Due Diligence (CDD): We will identify and verify the identity of all customers, including beneficial owners, using reliable and independent sources.
• Know Your Customer (KYC): We will understand each customer's business and risk profile, including their source of funds and purpose of transactions.
• Transaction Monitoring: We will monitor all transactions, including mobile money transactions and payment service solution transactions, for suspicious activity.
• Reporting: We will report all suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) and other relevant authorities
• Training: We will provide regular training to all employees on AML/CFT/CPF policies and procedures.

Countering Financial Terrorism (CFT) Program

Our CFT program consists of the following components:

• Sanctions Screening: We will screen all customers and transactions against relevant sanctions lists, including the United Nations Security Council Resolutions and the Nigerian government's sanctions list.
• Transaction Monitoring: We will monitor all transactions for suspicious activity related to terrorism financing
• Reporting: We will report all suspicious transactions to the NFIU and other relevant authorities.
• Training: We will provide regular training to all employees on CFT policies and procedures.

Countering Proliferation Financing (CPF) Program

Our CPF program consists of the following components:

• Sanctions Screening: We will screen all customers and transactions against relevant sanctions lists related to proliferation financing.
• Transaction Monitoring: We will monitor all transactions for suspicious activity related to proliferation financing.
• Reporting: We will report all suspicious transactions to the NFIU and other relevant authorities.
• Training: We will provide regular training to all employees on CPF policies and procedures.

Risk Assessment

We will conduct regular risk assessments to identify and mitigate AML/CFT/CPF risks associated with our Mobile Money Operating Services and Payment Service Solution Services.

Compliance

The AML/CFT/CPF policies of PLUG DOT NG LIMITED are formulated in compliance with the applicable and relevant laws and regulations outlined below;

• Money Laundering (Prohibition) Act 2022.
• Terrorism (Prevention) Act 2022.
• Central Bank of Nigeria (CBN) AML/CFT Regulations 2022 and other extant laws.
• CBN Anti-Money Laundering and Combating the Financing of Terrorism (administrative sanctions) regulations, 2024
• Nigerian Financial Intelligence Unit (NFIU) Act, 2018.
• Proceeds of Crime (Recovery and Management) Act, 2022
• Banks and Other Financial Institutions Act 2020
• Security and Exchange Commission Code of Corporate Governance
• CBN Customer Due Diligence Regulations 2023

Monitoring and Reporting

We will monitor all transactions and report any suspicious activity to the NFIU and other relevant authorities.

Training and Awareness

We will provide regular training and awareness programs to all employees on AML/CFT/CPF policies and procedures.

Review and Update

We will review and update this policy regularly to ensure it remains effective and compliant with relevant laws and regulations.

Approval

This policy has been approved PLUG DOT NG LIMITED’s management.

Effective Date

This policy is effective as of March 2025.

Review Date

This policy will be reviewed and updated incessantly and notice will be put on the portal