KYC / AML / CFT Policy

Effective Date: June 23, 2026 | Version v1.1

AML, CFT, and CPF Basics

Money laundering involves taking funds obtained through criminal activity and disguising their origin so they appear legitimate. Counter-terrorist financing (CFT) focuses on preventing funds, whether lawful or unlawful in origin, from being used to support terrorism or terrorist activity. Counter-proliferation financing (CPF) focuses on preventing financial support for the proliferation of weapons of mass destruction and related sanctioned activity.

Jadegate Tech Limited ("Jadegate", "we", "our", or "us") is committed to preventing, detecting, and deterring money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion, and other forms of illicit financial activity. We operate risk-based controls designed to protect users, partners, payment systems, and the wider financial ecosystem.

Jadegate's Commitment

Jadegate maintains a compliance program aligned with applicable Nigerian AML/CFT/CPF laws, regulatory expectations, and guidance from competent authorities, including the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU), and other relevant agencies.

Our AML/CFT/CPF and anti-fraud controls include:

• Customer identification and verification procedures (KYC)
• Account tiers and transaction limits based on verification status and risk
• Ongoing transaction monitoring and suspicious activity review
• Fraud prevention, secure webhook validation, audit logging, and reconciliation checks
• Record-keeping standards for financial, KYC, audit, security, and compliance records
• Internal controls, staff awareness, escalation procedures, and periodic policy review
• Cooperation with lawful requests from regulators, law enforcement, and competent authorities

KYC Policy

Jadegate must identify and verify users before allowing access to certain services, including wallet setup, dedicated virtual accounts, currency conversion, bill payments, higher transaction limits, and marketplace-related activity.

Verification may include BVN verification, NIN verification, proof of address, liveness checks, document uploads, email verification, phone number checks, and other information needed for compliance or risk review. Jadegate may reject, suspend, limit, or require re-verification where information is incomplete, inconsistent, expired, suspicious, or required by law.

Information Jadegate May Collect and Record

Depending on the service used and the risk level, Jadegate may collect and record:

• Full legal name, username, email address, phone number, and profile details
• BVN, NIN, proof of address, liveness status, document type, and verification metadata
• Date and result of verification checks, account tier, KYC status, and re-verification flags
• Wallet, dedicated virtual account, deposit, transaction, ledger, conversion, and refund records
• Alipay contacts, Chinese bank beneficiary details, bill payment details, and provider responses
• Device, login, session, notification, audit, and security event records
• Marketplace request details, supplier or agent notes, support chat records, and attachments

Transaction Monitoring and Anti-Fraud Initiative

In addition to KYC and AML/CFT/CPF controls, Jadegate actively monitors for suspicious or fraudulent activity across wallet funding, deposits, NGN to RMB conversions, beneficiaries, bill payments, marketplace requests, and support interactions.

Examples of activity that may be reviewed include:

• Unusual transaction volumes or frequency
• Transactions inconsistent with user profile
• Rapid movement of funds, repeated failed payments, refunds, reversals, or reconciliation issues
• Multiple accounts linked to the same user, identity, device, BVN, NIN, or payment details
• Unusual beneficiary, Alipay, Chinese bank, biller, supplier, or marketplace patterns
• Use of forged documents, mule accounts, stolen payment methods, or unauthorized identity details

If suspicious or fraudulent behavior is detected, Jadegate may contact the user for clarification, request additional verification, delay or decline a transaction, restrict an account, reverse or refund a transaction where appropriate, file required reports, or cooperate with competent authorities.

Restricted and Prohibited Activities

Users must not use Jadegate for:

• Money laundering, terrorist financing, proliferation financing, fraud, or sanctions evasion
• Illegal cross-border transfers, trade-based money laundering, or suspicious supplier payments
• Purchase, sourcing, shipping, or payment for prohibited, restricted, counterfeit, or illegal goods
• Use of another person's BVN, NIN, bank account, card, Alipay account, documents, or identity
• Attempts to bypass limits, hide source of funds, split transactions, or interfere with controls

Record Keeping and Reporting

Jadegate maintains records needed to support KYC, AML/CFT/CPF, fraud prevention, transaction monitoring, account deletion, tax, accounting, dispute resolution, and security obligations. These may include customer identification records, transaction history, ledger entries, bill payment records, conversion records, audit logs, security events, support records, and marketplace records.

Financial and compliance records may be retained for up to 5 years or any longer period required by law, regulators, payment partners, investigations, disputes, or legal proceedings.

Where required, Jadegate may file suspicious transaction or activity reports, respond to lawful requests, and provide relevant records to the NFIU, CBN, EFCC, law enforcement, courts, payment partners, or other competent authorities.

China Marketplace and Cross-Border Risk Controls

Jadegate's China marketplace and RMB-related services may involve additional risks, including supplier fraud, trade-based money laundering, restricted goods, false invoices, misleading product descriptions, and unusual payment patterns. To manage these risks, Jadegate may:

• Review supplier, product, invoice, shipping, and source-of-funds information
• Request additional documentation before approving or continuing a marketplace request
• Decline suspicious sourcing, supplier, logistics, or payment requests
• Monitor agent, admin, supplier, and marketplace activity for fraud and compliance risk

Commitment to Regulatory Compliance

Jadegate is committed to maintaining a strong, transparent, and compliant operating environment. We continuously review and enhance our KYC, AML/CFT/CPF, anti-fraud, sanctions, transaction monitoring, and record-keeping controls to reflect evolving regulatory expectations, product risks, and industry best practices.

Our employees, contractors, agents, and partners are expected to comply with this policy, applicable law, internal controls, and escalation requirements.

Contact Information

For AML, KYC, fraud, or compliance-related inquiries: