AML & CFT Policy 

1. Commitment

Pickpadi Global Ltd has zero tolerance for money laundering, terrorist financing, proliferation financing and sanctions evasion. This policy is designed with reference to the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, CBN AML/CFT regulations and FATF recommendations.

2. Governance

A designated compliance officer oversees the AML/CFT programme, reports to senior management and maintains this policy, which is reviewed at least annually.

3. Risk-based approach

We assess risk across customer type, geography, product, delivery channel and transaction behaviour, applying enhanced measures where risk is higher.

4. Customer due diligence

• Verify the identity of businesses, directors and beneficial owners (25%+).
• Understand the nature and purpose of the business relationship.
• Apply enhanced due diligence to high-risk customers and PEPs.
• Refresh due diligence periodically and on trigger events.

5. Sanctions and PEP screening

Customers, beneficial owners and counterparties are screened against UN, OFAC, UK, EU and Nigerian sanctions lists and PEP databases at onboarding and on an ongoing basis.

6. Transaction monitoring

Transactions are monitored with rules and behavioural analytics to identify unusual patterns, structuring, rapid movement of funds and activity inconsistent with a customer's profile.

7. Reporting

Suspicious transactions are reported to the Nigerian Financial Intelligence Unit (NFIU) as required by law. We file currency transaction reports where applicable. Tipping off is prohibited.

8. Record keeping

Identification and transaction records are retained for at least five years after the end of the relationship or transaction.

9. Training

Staff receive AML/CFT training at onboarding and at least annually.

10. Customer obligations

Businesses using Paddle must maintain their own AML/CFT controls proportionate to their activity, cooperate with information requests, and must not use the platform to facilitate prohibited activity.