Anti-Money Laundering Policy

Effective Date: November 7, 2025

1. Introduction

Purpose

This Anti-Money Laundering (AML) Policy outlines Jophab's commitment to preventing, detecting, and reporting money laundering and terrorist financing activities. As a platform facilitating the trading of gift cards for cash (e.g., Amazon, Apple, Steam, iTunes) and bill payments in Naira, Jophab recognizes the risks associated with financial transactions. This policy ensures compliance with applicable laws, including Nigeria's Money Laundering (Prevention and Prohibition) Act 2022, and international standards such as those from the Financial Action Task Force (FATF).

Objectives

  • Identify and mitigate AML risks in user onboarding, transactions, and operations.
  • Promote a culture of compliance among employees and users.
  • Protect Jophab's reputation and ensure sustainable business growth.

2. Scope

This policy applies to all Jophab employees, contractors, agents, and affiliates involved in platform operations. It covers all user interactions, including account creation, gift card trading, and cash withdrawals via the Jophab mobile app (available on iOS and Android).

3. Definitions

Money Laundering: The process of disguising the origins of illegally obtained money to make it appear legitimate.

Customer Due Diligence (CDD): Procedures to identify and verify customer identities and assess risks.

Enhanced Due Diligence (EDD): Additional checks for high-risk customers or transactions.

Suspicious Activity: Any transaction or behavior inconsistent with a user's profile, such as rapid high-volume gift card trades.

Know Your Customer (KYC): Jophab's process for verifying user identities during onboarding.

4. Policy Statement

Jophab prohibits all forms of money laundering and terrorist financing. All users must comply with this policy, and Jophab reserves the right to suspend or terminate accounts involved in suspicious activities. The company will cooperate fully with law enforcement and regulatory authorities.

5. Risk-Based Approach

Jophab adopts a risk-based AML framework to allocate resources effectively:

Risk Assessment

Conduct annual reviews of AML risks, considering factors like user location (e.g., high-risk jurisdictions), transaction volume, and gift card types.

Risk Categories

Risk Level Description Examples
Low Standard users with verified low-volume trades Individual selling occasional personal gift cards
Medium Frequent traders or users from moderate-risk areas Users trading 5-10 cards monthly
High Bulk trades, politically exposed persons (PEPs), or sanctions-listed entities High-volume sellers or users linked to high-risk countries

Mitigation: Low-risk activities receive basic monitoring; high-risk triggers EDD.

6. Customer Identification and Verification (KYC/CDD)

All users must complete KYC during account creation to access trading features.

Onboarding Process

1. Collect basic information: Full name, email, phone number, date of birth, and residential address.

2. Verify identity: Using government-issued ID (e.g., National ID, passport, driver's license) via app upload and third-party verification tools.

3. Screen against sanctions lists: E.g., UN, OFAC, Nigeria's NSCDC.

4. For business accounts: Verify beneficial owners (individuals owning >25% stake).

Document Requirements

  • Proof of address (utility bill or bank statement, <3 months old).
  • Selfie or video verification for biometric matching.

Note: Accounts without complete KYC are limited to viewing only; full trading requires verification within 48 hours.

7. Enhanced Due Diligence (EDD)

Applied to high-risk users or transactions:

  • Source of funds verification (e.g., bank statements for large deposits).
  • Additional screening for PEPs, including senior government officials or their relatives.
  • Manual review for transactions exceeding NGN 1,500,000 (or equivalent) in a 30-day period.
  • Geographic risk checks: Extra scrutiny for users in FATF-identified high-risk jurisdictions.

8. Ongoing Monitoring and Transaction Review

Jophab uses automated systems and manual oversight to monitor activities:

Transaction Monitoring Rules

  • Alerts for unusual patterns: e.g., multiple gift cards from the same source, rapid buy-sell cycles, or trades below market value.
  • Velocity checks: Limit new users to NGN 100,000 daily trades.
  • Integration with blockchain or API tools for gift card authenticity verification.

Reviews

  • Daily automated scans; weekly manual reviews for flagged items.
  • User profile updates required annually or upon risk changes.

9. Suspicious Activity Reporting

Internal Reporting

Employees must report suspicions to the AML Compliance Officer within 24 hours via a secure internal portal.

External Reporting

File Suspicious Transaction Reports (STRs) to the Nigerian Financial Intelligence Unit (NFIU) within 24 hours of detection. No tipping off users.

Examples of Suspicious Indicators

  • Inconsistent user information.
  • Evasive responses to verification requests.
  • Structuring transactions to avoid thresholds.

10. Record Keeping

  • Retain all KYC documents, transaction records, and monitoring logs for at least 5 years (or as required by law).
  • Secure storage: Encrypted databases compliant with GDPR and NDPR (Nigeria Data Protection Regulation).
  • Access limited to authorized personnel; audit trails for all views.

11. Training and Awareness

Employee Training: Mandatory annual AML training for all staff, plus onboarding sessions. Covers policy details, red flags, and reporting.

User Education: In-app notifications and FAQs on AML compliance, emphasizing legitimate use of the platform.

Effectiveness Testing: Quarterly quizzes and scenario-based drills.

12. Roles and Responsibilities

Role Key Responsibilities
CEO/Board Approve policy; oversee overall compliance.
AML Compliance Officer Lead risk assessments; handle STRs; report to regulators.
Operations Team Implement KYC/EDD; monitor transactions.
All Employees Vigilance for red flags; immediate reporting.
Users Provide accurate information; use platform ethically.

13. Policy Review and Enforcement

Review

Annual review or upon regulatory changes; led by the AML Officer.

Enforcement

Violations by employees result in disciplinary action, up to termination. User breaches lead to account suspension and potential legal referral.

Contact Us

For questions regarding this AML Policy, please contact us at: compliance@jophab.com

This policy is effective as of November 7, 2025, and supersedes prior versions. Jophab is committed to fostering a transparent and secure trading environment.