Anti-Money Laundering (AML) Policy

1. Introduction

SmartAza, a feature of Owoche by Transingenium Innovations Ltd ("Transingenium"), is committed to the highest standards of compliance with applicable Anti-Money Laundering (AML) laws and regulations in Nigeria and other jurisdictions where we operate. This AML Policy outlines the framework and measures SmartAza has implemented to detect, prevent, and report money laundering and terrorism financing activities.

2. Scope of the Policy

This policy applies to all employees, agents, and representatives of SmartAza, as well as to all users of the SmartAza platform. It governs the management, monitoring, and reporting of money laundering and terrorist financing risks in connection with SmartAza's services.

3. Key Definitions

• Money Laundering: The process of disguising the origins of illegally obtained money to make it appear legitimate.
• Suspicious Activity: Any transaction or behavior that raises reasonable doubt about the legitimacy of the source or purpose of funds.
• Know Your Customer (KYC): Procedures to verify the identity of users and assess their risk level.

4. AML Measures and Procedures

SmartAza has implemented the following measures to ensure compliance with AML regulations:

• Know Your Customer (KYC): All users are required to provide valid identification and complete a verification process before accessing certain services on SmartAza.
• Transaction Monitoring: Regular monitoring of user transactions to identify and flag suspicious patterns or activities.
• Record Keeping: Retention of records related to user identification, transactions, and communications for a minimum of 5 years, as required by law.
• Risk Assessment: Periodic risk assessments of the platform to identify vulnerabilities and implement mitigating measures.
• Reporting Obligations: Submission of suspicious activity reports (SARs) to the relevant authorities when necessary.

5. User Responsibilities

All users of SmartAza are required to:

• Provide accurate and truthful information during the registration and KYC process.
• Use the platform for legitimate purposes only.
• Report any suspicious activity or behavior encountered on the platform to SmartAza’s support team.

6. Employee Training

SmartAza provides regular AML training to its employees and agents to ensure they understand their responsibilities and are equipped to identify and report suspicious activities. Training covers the following areas:

• Recognizing money laundering and terrorism financing risks.
• Understanding KYC procedures and the importance of due diligence.
• Steps for reporting suspicious activities to relevant authorities.

7. Monitoring and Auditing

SmartAza conducts regular audits of its AML policies and procedures to ensure they remain effective and compliant with applicable laws and regulations. Internal monitoring systems are also in place to track and assess compliance.

8. Reporting Suspicious Activities

If suspicious activity is detected, SmartAza will promptly file a Suspicious Activity Report (SAR) with the appropriate regulatory authority, such as the Nigerian Financial Intelligence Unit (NFIU). Users can report suspicious activities to SmartAza’s support team at aml@owoche.com.

9. Penalties for Non-Compliance

Non-compliance with this policy or applicable AML laws may result in disciplinary action for employees, account suspension or termination for users, and legal consequences for all parties involved. SmartAza will fully cooperate with law enforcement and regulatory authorities in such cases.

10. Policy Review and Updates

This AML Policy is reviewed periodically to ensure its effectiveness and alignment with current laws and best practices. Updates to the policy will be communicated to all stakeholders and posted on our platform.

11. Contact Us

For questions or concerns regarding this AML Policy, please contact us: