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. Risk-based approach

• Client and partner risk is assessed at onboarding and reviewed periodically.
• Higher-risk relationships, including politically exposed persons, receive enhanced due diligence.
• We do not accept anonymous or third-party payments on behalf of another person.

4. Customer due diligence

Identification and verification requirements are described in our KYC Policy. Where due diligence cannot be completed, the relationship is declined or terminated.

5. Monitoring and reporting

• Transactions are monitored for unusual patterns, structuring and inconsistent source of funds.
• Suspicious activity is escalated internally to the designated compliance officer.
• Reports are filed with the relevant authorities where required, without tipping off the client.

6. Sanctions screening

We screen clients and partners against applicable sanctions and watch lists and refuse business with sanctioned individuals, entities or jurisdictions.

7. Record keeping

Identification data, transaction records and compliance decisions are retained for a minimum of five years after the end of the relationship, in line with our Privacy Policy.

8. Training and governance

Staff and partners receive AML awareness guidance appropriate to their role. This policy is reviewed at least annually and updated when regulation or our risk profile changes.

9. Contact

Compliance enquiries: info@instaswich.trade.