ANTI-MONEY LAUNDERING (AML) POLICY

1. Purpose and Scope

1.1 This Policy applies to all users of Obiex services, whether individuals or entities, including but not limited to API users, business customers, and partners.

1.2 The Policy establishes how Obiex implements Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) controls across all jurisdictions in which we operate.

1.3 Obiex adopts a risk-based approach (RBA) to compliance, ensuring that AML/CTF measures are proportionate to the risks presented by our customers, products, services, delivery channels, and geographic exposure.

2. Customer Due Diligence (CDD) and Know Your Customer (KYC)

2.1 All users must complete identity verification before accessing Obiex services. Verification may include collection of government-issued identification, proof of address, biometric verification, and—where applicable—corporate formation documents and ultimate beneficial ownership (UBO) information.

2.2 In Nigeria, Obiex prioritizes the National Identification Number (NIN) as the primary identifier for individuals.

2.3 Business users are required to provide “Know Your Customer’s Customer” (KYCC) information in line with Obiex’s Travel Rule Policy.

2.4 Enhanced Due Diligence (EDD) is applied to higher-risk customers, including but not limited to politically exposed persons (PEPs). While applicable regulations allow the onboarding of PEPs subject to EDD, Obiex reserves the right, as a business decision, not to provide services to PEPs.

2.5 Obiex reserves the right to reject, suspend, or terminate services where required information is not provided or where red flags are identified.

3. Prohibited Users and Activities

3.1 Obiex does not provide services to:

• Politically Exposed Persons (PEPs), in line with our business decision stated above.
• Users or entities located in, resident in, or transacting with sanctioned jurisdictions (see Section 4).
• Users engaged in activities illegal under applicable laws, including but not limited to: fraud, terrorism financing, human trafficking, arms dealing, narcotics trafficking, ransomware, cybercrime, money mules, mixers/tumblers, and any other unlawful activity identified under our General Terms of Use.
• Anonymous or shell accounts, or entities acting as unlicensed financial institutions or “shell banks.”

4. Sanctioned Jurisdictions

4.1 Obiex complies with all applicable global sanctions regimes. We do not provide services to, or permit transactions involving, individuals, entities, or jurisdictions listed under:

• United Nations Security Council (UNSC) Sanctions List
• Office of Foreign Assets Control (OFAC – U.S.)
• European Union (EU) Consolidated List
• UK HMT Sanctions List
• Nigeria Sanctions Committee (NigSAC)

4.2 Restricted jurisdictions currently include, but are not limited to: North Korea, Iran, Syria, Russia, Sudan, Myanmar (Burma), Cuba, Afghanistan, Belarus, Central African Republic, Democratic Republic of Congo, Libya, Mali, Somalia, South Sudan, Yemen, and Zimbabwe.

4.3 If Obiex identifies that a user has received funds from, or is transacting with, a sanctioned jurisdiction, individual, or entity, we may freeze, block, or return such funds and restrict the account.

5. Transaction Monitoring and Reporting

5.1 All transactions are subject to continuous monitoring using both automated and manual processes. Obiex employs advanced tools, including blockchain analytics solutions, to detect suspicious or unusual activity.

5.2 Obiex complies with reporting obligations in each jurisdiction where it operates. In Nigeria, this includes reporting:

• Transactions above ₦5,000,000 for individuals.
• Transactions above ₦10,000,000 for corporate entities.
• Transactions equivalent to or above USD $10,000 in other currencies.

5.3 Obiex also files Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) with the Nigerian Financial Intelligence Unit (NFIU) and other relevant regulators, as required by law.

5.4 For further information on how Obiex engages with regulators and competent authorities, see our Law Enforcement Request Guideline.

6. Record Keeping

6.1 Obiex retains customer identification, transaction records, and communications for a minimum period of five (5) years after the termination of the business relationship, or longer where required by applicable law.

6.2 Records are maintained in accordance with data protection and privacy standards as set out in our Privacy Policy.

7. Cooperation with Law Enforcement

7.1 Obiex cooperates fully with law enforcement agencies, regulators, and other competent authorities in accordance with applicable laws and procedures.

7.2 Requests for information are handled strictly in line with our Law Enforcement Request Guideline.

8. Travel Rule Compliance

8.1 In line with the Financial Action Task Force (FATF) Travel Rule, Obiex ensures that required originator and beneficiary information is collected, transmitted, and made available to competent authorities.

8.2 This obligation applies to all qualifying virtual asset transfers of USD/EUR 1,000 or more (or equivalent).

8.3 API and business users must comply with the Travel Rule requirements when using Obiex services.

9. Consequences of Non-Compliance

9.1 Failure to comply with this AML Policy may result in:

• Account restrictions or closure.
• Freezing, blocking, or return of funds.
• Reporting to regulators or law enforcement.
• Civil or criminal liability under applicable laws.
• Prohibition from future onboarding of related accounts or entities.

For any questions regarding this AML Policy, please contact our Compliance Team at: 📧 [email protected]