Anti-Money Laundering Policy

1. Policy statement

INSTASWICH LIMITED has zero tolerance for money laundering, terrorist financing, sanctions evasion and fraud. We are committed to applying the standards expected of a responsible financial services business, including the principles of the Money Laundering (Prohibition) Act and the guidance of the Nigerian Financial Intelligence Unit (NFIU).

2. Scope

This policy applies to all directors, employees, contractors, Introducing Brokers and partners acting on behalf of InstaSwich, and to every subscription, education purchase, partner payout and broker introduction.

3. Legal and regulatory framework

We align our controls with the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, guidance issued by the Nigerian Financial Intelligence Unit (NFIU) and the Special Control Unit against Money Laundering (SCUML), and the Financial Action Task Force (FATF) Recommendations. Where a partner or client relationship touches another jurisdiction, we also observe the applicable local requirements.

4. Governance and responsibilities

• The board owns this policy and approves material changes at least annually.
• A designated Compliance Officer maintains the framework, receives internal escalations and files reports.
• Every member of staff, contractor and Introducing Broker must report suspicion immediately and must never warn the subject.
• Compliance decisions are documented, with reasons, in an auditable record.

5. Risk-based approach

We assess risk across four dimensions — client, geography, product and delivery channel — and score each relationship low, medium or high. Controls scale with the score.

• Client and partner risk is assessed at onboarding and reviewed periodically.
• Higher-risk relationships, including politically exposed persons (PEPs), their family members and close associates, receive enhanced due diligence and senior sign-off.
• Simplified due diligence is never applied where any higher-risk indicator is present.
• We do not accept anonymous payments, or payments made by a third party on someone else's behalf.

6. Customer due diligence

Identification and verification requirements are described in our KYC Policy. Due diligence includes identifying beneficial owners of corporate partners, understanding the purpose and intended nature of the relationship, and, for higher-risk cases, establishing source of funds and source of wealth. Where due diligence cannot be completed, the relationship is declined or terminated and the reason recorded.

7. Sanctions and watch-list screening

Clients, partners and beneficial owners are screened at onboarding and on an ongoing basis against applicable sanctions regimes, terrorist-financing designations, PEP databases and adverse-media sources. Positive matches are frozen pending review, and confirmed matches are refused and reported. We do not do business with sanctioned persons, entities or comprehensively sanctioned jurisdictions.

8. Transaction monitoring and red flags

Activity is monitored for indicators including, but not limited to:

• Payments structured just below reporting or verification thresholds.
• Payment instruments inconsistent with the stated identity, country or profile of the client.
• Rapid subscribe-and-refund cycles, or repeated chargebacks without contact.
• Reluctance to provide identification, or documents that appear altered.
• Requests to route funds to a party unrelated to the account holder.
• Unexplained use of multiple accounts, emails or payment cards by one person.

9. Suspicious activity reporting

Any employee or partner who identifies a red flag must escalate internally to the Compliance Officer without delay and must not discuss the matter with the client. The Compliance Officer decides whether to file a Suspicious Transaction Report with the NFIU or another competent authority. Tipping off is prohibited and may be a criminal offence.

10. Cash and cryptocurrency

We do not accept cash. Where digital-asset settlement is used in an assisted exchange, counterparties and wallet activity are subject to the same screening standards, and transactions with mixers, darknet services or sanctioned addresses are refused.

11. Record keeping

Identification data, transaction records, screening results and compliance decisions are retained for a minimum of five years after the end of the relationship, or longer where required, in line with our Privacy Policy. Records are stored securely with restricted, logged access.

12. Training

All staff receive AML and counter-terrorist-financing training on joining and refresher training at least annually, covering red flags, escalation routes, sanctions and the prohibition on tipping off. Attendance is recorded.

13. Independent review and testing

The framework is tested periodically through internal review and, where appropriate, external assessment. Findings are tracked to closure by the Compliance Officer and reported to the board.

14. Broker partners

Brokers we introduce clients to operate their own regulated AML programmes. Our checks are additional and do not replace theirs, and we cooperate with lawful information requests from regulated partners.

15. Contact

Compliance enquiries: support@instaswich.com · +234 201 330 6182. See also our KYC Policy and Terms & Conditions.