Introduction

Money laundering is the attempt to conceal or disguise the nature, location, source, ownership or control of illegally obtained money. Money laundering is most commonly associated with tax avoidance. However, other individuals may attempt to launder money in order to conceal their identity or finance their operations. 'Suspicious activity' is a very difficult concept to define because it can vary from one transaction to another based upon all the circumstances surrounding the transaction or group of transactions. For example, transactions by one customer may be normal based on our knowledge of that customer and their pattern of activity, while similar transactions by another customer may be suspicious. Many factors are involved in determining whether transactions are suspicious including the amount, the nature of the transaction and frequency of deposits/withdrawals from the system. BethPay Nigeria is committed to fighting money laundering and complying fully with anti-money laundering laws in the Nigeria. We understand that we have responsibilities to help fight the global battle against money laundering and our commitment will supersede all other privacy obligations contained in our policies. Accordingly, BethPay Nigeria will take all reasonable and appropriate steps to prevent persons engaged in money laundering, fraud, or other financial crimes from utilizing our products and services.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business. Key components of our AML and CTF framework include the following:

(I) COMPLIANCE OFFICER

Coordinating and monitoring day-to-day compliance with the relevant legislation, regulations, rules and industry guidance and applicable money laundering laws and regulationsMonitoring transactions to detect unusual suspicious activitiesPrompt preparation and delivery of all relevant returns to the regulatory bodies in line with SEC and FIU Rules and RegulationsCommunicating AML/CFT issues to all stakeholders

(II) RISK COMMITTEE

The appointment of an independent risk committee which reports to our board of directors regularly on all risk and compliance matters using a risk-based approach to the assessment and management of money laundering and terrorist financing risks and Comply with the requirements of the Money Laundering (Prohibition) Act, 2011 (as amended), Terrorism (Prevention) Act, 2011 (as amended) and Terrorism Prevention (Freezing of International Terrorists Funds and other Related Measures) Regulations 2013, including related laws and Regulations.

(III) INTERNAL CONTROL

Formulate and implement internal controls and other procedures that will deter criminals from using its facilities for money laundering and terrorist financing and to ensure that its obligations under subsisting laws and Regulations are met..