Anti-Money Laundering (AML) Policy

Pandascrow recognizes the importance of combatting money laundering and terrorism financing. We are committed to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance in Nigeria and any jurisdiction in which we operate.

As a Designated Non-Financial Institution (DNFI), Pandascrow complies with all applicable AML legislation, including but not limited to:

• Money Laundering (Prohibition) Act, 2011 (as amended)
• Terrorism Prevention Act, 2013
• Central Bank of Nigeria (CBN) Guidelines on AML/CTF

1. Scope

Money Laundering refers to the process of converting illegally obtained funds into seemingly legitimate assets. Terrorism Financing involves the collection or provision of funds for terrorist purposes, whether directly or indirectly.

This policy applies to all Pandascrow employees, contractors, and business partners, and aims to prevent misuse of the platform for illicit purposes.

2. Customer Due Diligence (CDD)

We follow rigorous Know Your Customer (KYC) practices, which include:

• Verifying customer identities through official documentation.
• Assessing beneficial ownership and control structures.
• Collecting reliable information from independent sources.
• Enforcing compliance with our Business Codes and Ethics.

Unusual activity or suspicious patterns are flagged and escalated to the Chief Compliance Officer immediately.

3. Risk-Based Approach

Pandascrow applies a risk-based framework to identify and mitigate AML risks. Customers and transactions are categorized into risk tiers based on:

• Geographic location
• Nature of the business
• Transaction size and frequency
• Complexity of ownership

Appropriate due diligence measures and controls are implemented accordingly.

4. High-Risk Customers

Pandascrow will not engage with the following categories of users:

• Individuals/entities on global or local sanctions lists.
• Persons with suspected links to criminal activities.
• Customers unwilling to provide full transparency.
• Entities with unverifiable ownership structures.
• Politically Exposed Persons (PEPs) without full disclosure.

5. Record Keeping

We maintain detailed records of customer information, CDD documents, and transaction histories for a minimum of five (5) years after the end of a business relationship. In jurisdictions requiring longer retention, we comply with local regulations.

6. Appointment of AML Compliance Officer

Pandascrow designates an Anti-Money Laundering Officer (AMLO) who is responsible for:

• Reviewing and escalating internal reports of suspicious activity.
• Filing Suspicious Activity Reports (SARs) with regulatory authorities.
• Acting as a liaison with enforcement agencies.
• Designing AML training and operational processes.
• Submitting reports to the Special Control Unit Against Money Laundering (SCUML).

7. Reporting Suspicious Activities

Employees, contractors, or partners who detect potential money laundering must report to the AMLO without delay. Reports should include:

1. Identity of the reporting person.
2. Description of the suspicious activity.
3. Details of involved parties.
4. Transaction records and evidence.
5. Rationale for suspicion.

All internal reports are treated with strict confidentiality.

8. Training and Awareness

Annual AML training is mandatory for all employees and contractors. Role-specific training is provided to relevant departments to identify red flags and execute CDD procedures.

9. Policy Review and Audit

This AML policy is reviewed at least annually. Pandascrow's Internal Audit team independently assesses policy effectiveness and reports directly to the Board Audit Committee.

10. Zero Tolerance

Pandascrow maintains a zero-tolerance policy toward non-compliance with AML laws. Violations may result in immediate account suspension, legal action, and disclosure to authorities.

For further details or to report a suspicious activity, contact our AML Compliance Officer at compliance@pandascrow.io.