Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF) Policy

FrenzPay (“Company,” “we,” “us,” or “our”) is committed to the highest standards of Anti-Money Laundering (AML) compliance and Counter-Terrorism Financing (CTF) prevention. This policy establishes a comprehensive framework to detect, prevent, and report suspicious financial activity in accordance with applicable laws and regulations.

FrenzPay strictly prohibits the use of its platform for money laundering, terrorist financing, fraud, sanctions evasion, or any other financial crime. All users, employees, contractors, and partners are expected to adhere to this policy.

This policy is informed by and consistent with:

• The Financial Action Task Force (FATF) 40 Recommendations
• The Nigerian Money Laundering (Prevention and Prohibition) Act 2022
• The Proceeds of Crime (Money Laundering) and Terrorist Financing Act
• The United States Bank Secrecy Act (BSA)
• The UK Proceeds of Crime Act 2002 and Terrorism Act 2000
• EU Anti-Money Laundering Directives (AMLD4, AMLD5, AMLD6)
• OFAC, UN, EU, and UK sanctions lists
• Virtual Asset Service Provider (VASP) regulations in applicable jurisdictions

FrenzPay requires all users to complete identity verification before accessing core services. Our KYC process includes:

3.1 Individual Verification

• Government-issued photo ID (National ID, Passport, or Driver's License)
• Live selfie / liveness check matched against the ID document
• Proof of residential address (utility bill or bank statement not older than 3 months)
• Date of birth verification
• Phone number and email verification with OTP

3.2 Enhanced Due Diligence (EDD)

Enhanced verification is required for users who:

• Process transactions above $10,000 USD per month
• Are classified as Politically Exposed Persons (PEPs)
• Operate from high-risk jurisdictions as defined by FATF
• Exhibit unusual transaction patterns or behaviors

3.3 Ongoing KYC Monitoring

We continuously monitor user activity and may request updated documentation if circumstances change or risk indicators emerge.

4.1 Automated Monitoring

All transactions on FrenzPay are subject to real-time automated monitoring systems that flag:

• Structuring or smurfing (breaking large transactions into smaller ones to evade reporting thresholds)
• Rapid deposits followed by immediate withdrawals
• Transactions inconsistent with the user's stated source of funds
• Unusually high transaction volumes for account profile
• Transactions involving sanctioned countries or entities
• Round-dollar or unusual transaction patterns

4.2 Suspicious Activity Reports (SARs)

Where we identify potentially suspicious activity, we will file a Suspicious Activity Report (SAR) with the appropriate financial intelligence unit (FIU) in the relevant jurisdiction. SAR filings are confidential — we are legally prohibited from disclosing to users that a SAR has been filed.

4.3 Currency Transaction Reports (CTRs)

Transactions meeting or exceeding applicable thresholds (e.g., $10,000 USD or equivalent) are reported to relevant regulatory authorities as required by law.

FrenzPay screens all users and transactions against:

• OFAC Specially Designated Nationals (SDN) list
• UN Security Council Consolidated List
• EU Consolidated Sanctions List
• UK Office of Financial Sanctions Implementation (OFSI) list
• Nigerian NFIU and CBN watchlists

Any match against a sanctions list will result in immediate account suspension, funds freeze, and mandatory reporting to the relevant authorities. We do not accept users from or facilitate transactions involving OFAC-sanctioned countries including Iran, North Korea, Cuba, Syria, and the Crimea region.

The following activities are strictly prohibited on FrenzPay:

• Money laundering in any form
• Terrorist financing or support of designated terrorist organizations
• Tax evasion or facilitation of tax fraud
• Fraud, identity theft, or impersonation
• Use of FrenzPay for unlawful gambling proceeds
• Processing payments for illegal goods, services, or darknet markets
• Sanctions evasion or circumvention of financial controls
• Use of stolen, unauthorized, or fictitious financial credentials
• Ponzi schemes, pyramid schemes, or fraudulent investment platforms

FrenzPay retains the following records for a minimum of 5 years (or longer where required by law):

• All KYC documentation and verification records
• Complete transaction histories with timestamps
• Correspondence related to compliance decisions
• SAR and CTR filings and related evidence
• Risk assessments and due diligence reviews

FrenzPay applies a risk-based approach to AML compliance, classifying users and transactions into risk categories:

• Low Risk: Verified individuals from low-risk jurisdictions with consistent, low-volume transaction patterns
• Medium Risk: Users with moderate transaction volumes or operating from medium-risk countries
• High Risk: PEPs, users from high-risk jurisdictions, high-volume accounts, or those with unusual patterns — subject to EDD

All FrenzPay employees and contractors with access to financial data are required to:

• Complete AML/CTF training upon onboarding and annually thereafter
• Report any suspicious activity to the designated AML Compliance Officer
• Never tip off customers under investigation
• Maintain strict confidentiality about compliance-related matters

If you have concerns about potential money laundering, fraud, or financial crime on our platform, please contact us immediately:

• AML Compliance: aml@frenzpay.co
• General Compliance: compliance@frenzpay.co
• Security Incidents: security@frenzpay.co

All reports are treated confidentially and investigated promptly.

This AML/CTF Policy is reviewed at least annually, and updated as necessary to reflect changes in regulation, business operations, or risk environment. The current version is always available on our website at frenzpay.co/aml-policy.