1. Introduction

Genesyswave Solutions LTD ("Genesyspay," "we," "our," or "us") is committed to preventing money laundering, terrorist financing, and other illegal activities through our financial services. This Anti-Money Laundering (AML) Policy outlines the measures we take to comply with applicable laws and regulations, including the Nigeria Money Laundering (Prohibition) Act and international AML standards.

2. Objectives

• Prevention: To prevent the use of our services for money laundering or terrorist financing.
• Compliance: To ensure compliance with all applicable AML laws and regulations.
• Risk Management: To identify, assess, and mitigate risks associated with money laundering and terrorist financing.
• Reporting: To establish procedures for reporting suspicious activities to relevant authorities.

3. Scope

This AML Policy applies to all customers, employees, and third-party service providers involved in the use of Genesyspay's services, including but not limited to:

• E-wallet users.
• Payment API users.
• Virtual card (Visa and Mastercard) holders.

4. Customer Due Diligence (CDD)

Genesyspay will implement Customer Due Diligence (CDD) measures to verify the identity of our customers and assess the risks associated with their activities. This includes:

• Identity Verification: Collecting and verifying customer identification documents (e.g., passport, national ID, driver’s license).
• Risk Assessment: Classifying customers into risk levels (low, medium, high) based on their profile and transaction behavior.
• Ongoing Monitoring: Continuously monitoring customer transactions for suspicious activities.

5. Enhanced Due Diligence (EDD)

For high-risk customers, Genesyspay will apply Enhanced Due Diligence (EDD) measures, including:

• Obtaining additional information about the customer’s source of funds and wealth.
• Conducting more frequent reviews of the customer’s transactions.
• Obtaining senior management approval before onboarding high-risk customers.

6. Suspicious Activity Reporting

Genesyspay is committed to reporting any suspicious activities to the relevant authorities. Our employees are trained to identify and report transactions that may indicate money laundering or terrorist financing, including:

• Unusual or large transactions with no clear economic purpose.
• Transactions involving high-risk jurisdictions.
• Attempts to evade reporting or record-keeping requirements.

7. Record Keeping

Genesyspay will maintain records of all customer identification documents, transaction records, and suspicious activity reports for a minimum period of 5 years, in compliance with applicable laws and regulations.

8. Employee Training

All employees of Genesyspay will receive regular training on AML laws, regulations, and internal procedures. This training will ensure that employees are aware of their responsibilities and can effectively identify and report suspicious activities.

9. Third-Party Relationships

Genesyspay will conduct due diligence on third-party service providers to ensure they comply with AML regulations. We will also monitor their activities to prevent any involvement in money laundering or terrorist financing.

10. Sanctions Compliance

Genesyspay will screen customers and transactions against the following global sanctions and Politically Exposed Persons (PEP) lists to ensure compliance with international sanctions regimes:

• The State Migration Service of Ukraine
• CURIA - Former Members - Court of Justice of the European Union
• CONSOLIDATED LIST OF FINANCIAL SANCTIONS TARGETS IN THE UK
• NAZK Sanctions
• CIA World Leaders
• Global PEP List
• United Nations Security Council Consolidated List
• Open Sanctions PEPs
• European Securities and Markets Authority
• United States Drug Enforcement Administration
• Interpol
• FBI
• EUROPOL

Any matches will be reported to the relevant authorities, and the account will be blocked pending further investigation.

11. Internal Controls and Audits

Genesyspay will implement internal controls to ensure compliance with this AML Policy. Regular audits will be conducted to assess the effectiveness of our AML program and identify areas for improvement.

12. Reporting Obligations

Genesyspay will report suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) and other relevant authorities as required by law. We will also cooperate with law enforcement agencies in investigations related to money laundering or terrorist financing.

13. Policy Review

This AML Policy will be reviewed annually or whenever there are significant changes in regulations or business operations. Updates will be communicated to all relevant stakeholders.

14. Contact Information

For any questions or concerns regarding this AML Policy, please contact us at:

• Email: [email protected]

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Genesyswave Solutions LTD is committed to maintaining the highest standards of compliance and preventing financial crime in accordance with applicable laws and regulations.