2. REGULATORY FRAMEWORK

FrameLaPay's compliance framework is designed to operate in accordance with applicable Nigerian law and regulatory requirements and, where applicable, relevant international standards.

Depending on the services provided and the regulatory structure under which those services are offered, the framework may take account of requirements and guidance issued by relevant authorities, including:

• Central Bank of Nigeria ("CBN");
• Nigeria Financial Intelligence Unit ("NFIU");
• Nigeria Data Protection Commission ("NDPC");
• Securities and Exchange Commission ("SEC"), where applicable;
• relevant law-enforcement authorities;
• applicable sanctions authorities; and
• other competent regulatory authorities.

Where FrameLaPay operates through a licensed financial institution or regulated partner, the applicable partner's regulatory obligations and compliance procedures may also apply.

3. PURPOSE OF THIS POLICY

The purposes of this Policy are to:

1. establish customer identification procedures;
2. verify customer identities;
3. identify beneficial owners;
4. understand customer relationships and expected activity;
5. assess money-laundering and terrorist-financing risks;
6. conduct ongoing transaction monitoring;
7. identify suspicious activity;
8. conduct sanctions screening;
9. apply enhanced due diligence where appropriate;
10. maintain appropriate records;
11. report suspicious activity where legally required;
12. prevent the misuse of FrameLaPay's services; and
13. protect the integrity of the financial system.

4. RISK-BASED APPROACH

FrameLaPay applies a risk-based approach to KYC, AML and CFT.

Not every customer presents the same level of risk.

We may consider factors including:

Higher-risk customers and transactions may be subject to enhanced controls.

5. CUSTOMER IDENTIFICATION

FrameLaPay may require customers to provide information necessary to establish their identity.

Depending on the customer and service, this may include:

6. IDENTITY VERIFICATION

Providing information does not automatically establish identity.

FrameLaPay may verify customer information using:

• government-issued identification;
• identity databases;
• electronic verification services;
• biometric verification;
• address verification;
• financial-institution information;
• corporate registries;
• public databases;
• trusted third-party verification providers; and
• other lawful sources.

7. CUSTOMER DUE DILIGENCE

FrameLaPay may conduct Customer Due Diligence ("CDD") before establishing or continuing a customer relationship.

CDD may include:

• identifying the customer;
• verifying identity;
• understanding the purpose of the relationship;
• identifying beneficial owners;
• assessing risk;
• understanding expected transaction activity; and
• conducting ongoing monitoring.

8. TIERED KYC

Where applicable to a regulated product, FrameLaPay may apply tiered KYC requirements.

Different account levels may have different:

• transaction limits;
• balance limits;
• withdrawal limits;
• verification requirements; and
• product access.

9. ULTIMATE BENEFICIAL OWNERS

FrameLaPay may identify the Ultimate Beneficial Owner ("UBO") of a business or legal arrangement.

A beneficial owner may be an individual who ultimately:

• owns;
• controls; or
• exercises effective control over

a customer or legal entity.

We may request documentation necessary to establish ownership and control structures.

10. PURPOSE AND NATURE OF THE RELATIONSHIP

FrameLaPay may ask customers why they intend to use our Services.

For individuals, this may include:

• expected transaction volume;
• countries involved;
• types of customers;
• expected payment sources;
• expected beneficiaries;
• expected use of FrameLaPay products.

11. SOURCE OF FUNDS

FrameLaPay may request information regarding the source of funds involved in a transaction.

Examples of supporting evidence may include:

• bank statements;
• invoices;
• employment records;
• salary documentation;
• business records;
• investment statements;
• property-sale documentation;
• loan documentation; or
• other appropriate evidence.

12. ENHANCED DUE DILIGENCE

Enhanced Due Diligence ("EDD") may be applied where a customer, product, transaction or jurisdiction presents higher risk.

EDD may include:

• additional identification;
• source-of-funds verification;
• source-of-wealth verification;
• additional beneficial-owner information;
• adverse-media review;
• enhanced transaction monitoring;
• additional documentation;
• senior-management approval where applicable; and
• more frequent KYC updates.

13. POLITICALLY EXPOSED PERSONS

FrameLaPay may identify customers who qualify as Politically Exposed Persons ("PEPs"), as well as relevant family members and close associates, where required by applicable law.

PEP status does not automatically mean that a customer cannot use FrameLaPay.

However, PEP relationships may require enhanced due diligence and monitoring.

14. SANCTIONS SCREENING

FrameLaPay may screen customers and transactions against applicable sanctions lists.

Screening may include:

• customers;
• beneficial owners;
• counterparties;
• recipients;
• transaction parties; and
• relevant jurisdictions.

Where a potential sanctions match is identified, the transaction or account may be reviewed or restricted.

15. SANCTIONS EVASION

Customers must not use FrameLaPay to circumvent sanctions.

Prohibited activity includes:

• disguising the identity of a transaction party;
• using intermediaries to circumvent restrictions;
• falsifying transaction information;
• routing funds through third parties to avoid restrictions; or
• otherwise attempting to evade applicable sanctions.

16. MONEY LAUNDERING

FrameLaPay prohibits the use of its Services to facilitate money laundering.

Money laundering may involve:

FrameLaPay may monitor for indicators associated with these activities.

17. TERRORIST FINANCING

FrameLaPay prohibits the use of its Services to finance terrorism or terrorist organisations.

We may monitor transactions for indicators of terrorist financing and take appropriate action where concerns arise.

18. PROLIFERATION FINANCING

Where applicable, FrameLaPay may implement controls to prevent its Services from being used to finance the proliferation of weapons of mass destruction.

This may include sanctions screening and transaction monitoring.

19. TRANSACTION MONITORING

FrameLaPay may monitor transactions on an ongoing basis.

Monitoring may consider:

20. SUSPICIOUS ACTIVITY

Examples of potentially suspicious activity may include:

• transactions inconsistent with a customer's profile;
• rapid movement of funds;
• unexplained large transactions;
• repeated transfers to unrelated persons;
• unusual international activity;
• suspicious cryptocurrency activity;
• use of multiple accounts;
• unusual cash-equivalent activity;
• unexplained third-party payments;
• transactions involving high-risk jurisdictions; or
• attempts to circumvent transaction controls.

21. TRANSACTION SCREENING

Transactions may be screened before or after processing.

Screening may include:

• sanctions screening;
• fraud screening;
• transaction-risk assessment;
• counterparty screening;
• jurisdictional screening; and
• other compliance controls.

22. AUTOMATED MONITORING

FrameLaPay may use technology, artificial intelligence and machine-learning systems to identify potential risks.

These systems may analyse:

• transaction patterns;
• account behaviour;
• device information;
• geographic signals;
• blockchain activity;
• identity information; and
• other legally permissible information.

Automated alerts may result in additional review.

23. HUMAN REVIEW

Automated systems may generate alerts that require human investigation.

Where appropriate, trained compliance personnel may review:

• customer information;
• transaction history;
• risk indicators;
• supporting documents; and
• other relevant information.

24. ACCOUNT RESTRICTIONS

Where appropriate, FrameLaPay may:

• delay a transaction;
• reject a transaction;
• restrict withdrawals;
• restrict deposits;
• restrict transfers;
• suspend an account;
• require additional verification;
• restrict particular services; or
• terminate an account.

These measures may be necessary to comply with law or protect FrameLaPay and its customers.

25. INABILITY TO COMPLETE KYC

If FrameLaPay cannot satisfactorily complete required customer due diligence, we may be unable to:

• open an account;
• provide certain services;
• process a transaction;
• maintain an existing relationship; or
• permit particular activities.

26. SUSPICIOUS TRANSACTION REPORTING

Where required by applicable law, FrameLaPay may submit reports concerning suspicious transactions or activities to the appropriate authorities, including the Nigeria Financial Intelligence Unit (NFIU).

27. CONFIDENTIALITY OF REPORTING

Where applicable law prohibits disclosure, FrameLaPay will not disclose:

• whether a suspicious transaction report has been filed;
• whether an investigation is underway;
• the contents of a regulatory report; or
• information concerning a law-enforcement request.

This is commonly referred to as tipping off.

28. CASH AND CASH-LIKE TRANSACTIONS

Where relevant to our products and regulatory obligations, FrameLaPay may monitor cash or cash-equivalent activity for unusual or suspicious patterns.

29. THIRD-PARTY AND CORRESPONDENT RELATIONSHIPS

Where FrameLaPay works with:

• banks;
• payment processors;
• financial institutions;
• cryptocurrency providers;
• remittance providers; or
• other regulated partners,

we may conduct appropriate due diligence on those relationships.

Partners may also apply their own KYC and AML requirements.

30. HIGH-RISK JURISDICTIONS

FrameLaPay may apply additional controls to customers or transactions involving jurisdictions that present elevated:

• money-laundering risk;
• terrorist-financing risk;
• sanctions risk;
• corruption risk; or
• regulatory risk.

31. ADVERSE MEDIA

Where appropriate, FrameLaPay may review reliable public information concerning customers or counterparties for information relevant to financial crime risk.

This may include information relating to:

• fraud;
• corruption;
• money laundering;
• terrorist financing;
• sanctions;
• organised crime; or
• other serious financial misconduct.

An adverse-media result does not automatically establish wrongdoing.

32. FRAUD AND AML

Fraud prevention forms part of FrameLaPay's broader financial-crime controls.

We may combine:

• fraud detection;
• KYC;
• AML monitoring;
• sanctions screening; and
• cybersecurity controls

to identify suspicious behaviour.

33. DIGITAL-ASSET AML CONTROLS

Where FrameLaPay provides digital-asset services, additional controls may include:

• blockchain analytics;
• wallet screening;
• transaction tracing;
• sanctions screening;
• wallet-risk assessment;
• source-of-funds analysis; and
• monitoring of blockchain transactions.

34. HIGH-RISK DIGITAL-ASSET ACTIVITY

FrameLaPay may restrict or investigate digital-asset activity associated with:

• ransomware;
• stolen assets;
• sanctions;
• illicit marketplaces;
• fraud;
• terrorist financing;
• money laundering; or
• other unlawful activity.

35. CUSTOMER RISK CLASSIFICATION

Customers may be classified according to risk levels, such as:

Risk classifications may change as new information becomes available.

36. ONGOING DUE DILIGENCE

KYC is not necessarily a one-time process.

FrameLaPay may periodically update customer information.

We may also request updated information when:

• your circumstances change;
• your transaction activity changes;
• your documents expire;
• risk increases;
• suspicious activity is identified; or
• applicable law requires an update.

37. PERIODIC KYC REVIEW

The frequency of KYC reviews may depend on customer risk.

Higher-risk customers may be reviewed more frequently.

38. FAILURE TO UPDATE INFORMATION

If you fail to provide required updated information, FrameLaPay may:

• restrict account functionality;
• prevent transactions;
• suspend the account; or
• terminate the relationship where permitted by law.

39. RECORD KEEPING

FrameLaPay may retain:

• identification information;
• verification results;
• transaction records;
• beneficial ownership information;
• risk assessments;
• source-of-funds information;
• source-of-wealth information;
• compliance reviews;
• suspicious activity records; and
• other information required by applicable law.

40. DATA PROTECTION

KYC and AML processes require the processing of sensitive financial and identity information.

FrameLaPay will process such information in accordance with applicable data-protection requirements and its Privacy Policy.

41. DATA SECURITY

FrameLaPay may use appropriate technical and organisational safeguards to protect KYC and AML information, including:

• encryption;
• access controls;
• authentication;
• monitoring;
• secure storage;
• audit logs;
• segregation of duties; and
• other security controls.

42. THIRD-PARTY VERIFICATION PROVIDERS

FrameLaPay may use specialist providers for:

• identity verification;
• biometric verification;
• sanctions screening;
• PEP screening;
• adverse-media screening;
• fraud detection;
• blockchain analytics; and
• other compliance functions.

Such providers may process information on FrameLaPay's behalf or independently, depending on the relationship.

43. CUSTOMER COOPERATION

Customers must cooperate with reasonable KYC and AML requests.

You must not:

• submit false information;
• provide forged documents;
• impersonate another person;
• conceal beneficial ownership;
• manipulate identity verification;
• provide misleading source-of-funds information; or
• attempt to circumvent compliance controls.

44. IDENTITY FRAUD

The use of:

• stolen identities;
• fake identities;
• synthetic identities;
• altered documents;
• fraudulent biometric information; or
• another person's identification

is strictly prohibited.

45. MULTIPLE ACCOUNTS

Customers must not create multiple accounts to:

• circumvent transaction limits;
• avoid KYC requirements;
• evade account restrictions;
• avoid sanctions controls;
• manipulate promotions; or
• conceal financial activity.

46. MONEY MULE ACTIVITY

FrameLaPay prohibits customers from using their accounts as money-mule accounts.

Examples include receiving funds from unknown persons and forwarding them elsewhere for a fee or commission.

47. PROHIBITED FINANCIAL ACTIVITY

FrameLaPay must not be used for:

• money laundering;
• terrorist financing;
• sanctions evasion;
• fraud;
• corruption;
• bribery;
• trafficking;
• illegal gambling;
• financing criminal activity;
• stolen funds; or
• other unlawful activity.

48. EMPLOYEE AND MANAGEMENT RESPONSIBILITIES

FrameLaPay will maintain appropriate internal responsibilities for financial-crime compliance.

Depending on its regulatory structure and applicable requirements, these may include:

• Board oversight;
• senior management;
• compliance personnel;
• AML/CFT officers;
• risk-management personnel;
• information-security personnel; and
• internal audit or independent review.

49. COMPLIANCE TRAINING

Relevant FrameLaPay personnel may receive training concerning:

• KYC;
• AML;
• CFT;
• sanctions;
• fraud;
• suspicious activity;
• transaction monitoring;
• customer risk;
• data protection; and
• regulatory reporting.

50. INDEPENDENT REVIEW

FrameLaPay may periodically review its AML/CFT framework to assess:

• effectiveness;
• regulatory compliance;
• transaction monitoring;
• customer-risk classification;
• sanctions screening;
• suspicious-activity procedures; and
• internal controls.

51. GOVERNANCE

FrameLaPay's AML/CFT programme may be subject to oversight by appropriate senior personnel and governance bodies.

Responsibilities may include:

• approving AML/CFT policies;
• reviewing material risks;
• monitoring compliance;
• allocating resources;
• reviewing significant compliance matters; and
• ensuring appropriate remediation.

52. RISK ASSESSMENT

FrameLaPay may conduct periodic financial-crime risk assessments covering:

The risk assessment should be updated as the business and threat environment change.

53. REGULATORY COOPERATION

FrameLaPay may cooperate with competent authorities where legally required.

This may include providing:

• customer information;
• transaction records;
• compliance documentation;
• suspicious-activity information;
• account information; and
• other legally required information.

54. LEGAL REQUESTS

Where legally required, FrameLaPay may respond to:

• court orders;
• regulatory requests;
• law-enforcement requests;
• subpoenas;
• warrants; and
• other legally valid requests.

55. NO GUARANTEE OF CONTINUED ACCESS

Completion of KYC does not guarantee continued access to every FrameLaPay product.

We may subsequently restrict services if:

• risk changes;
• new information becomes available;
• applicable law changes;
• sanctions apply;
• suspicious activity is detected; or
• regulatory requirements require action.

56. CHANGES TO THIS POLICY

FrameLaPay may update this Policy to reflect:

• changes in law;
• regulatory guidance;
• new financial products;
• emerging financial-crime risks;
• technological developments;
• changes to our business; or
• changes to our compliance framework.

The Last Updated date will indicate the latest revision.

57. CONTACT INFORMATION

58. RELATED POLICIES

This Policy should be read together with:

1. Terms of Service
2. Privacy Policy
3. Payment & Transaction Terms
4. Refund, Cancellation & Dispute Policy
5. Acceptable Use & Prohibited Activities Policy
6. Cookie Policy
7. Data Processing Agreement, where applicable.