AML Policy

ANTI-MONEY LAUNDERING (AML) & COUNTER-TERRORIST FINANCING (CFT) POLICY

Quchange Technologies Limited (Quickchain Platform)

1. INTRODUCTION

Quchange Technologies Limited (“the Company”), operating the Quickchain platform, is committed to preventing its systems from being used for:

  • Money laundering
  • Terrorist financing
  • Fraud and financial crime

This policy outlines the procedures and controls implemented to comply with:

  • Central Bank of Nigeria (CBN) AML/CFT Regulations
  • Money Laundering (Prevention and Prohibition) Act, 2022
  • Economic and Financial Crimes Commission (EFCC) Guidelines
  • Nigerian Financial Intelligence Unit (NFIU) requirements
  • FATF (Financial Action Task Force) Recommendations

2. BUSINESS OVERVIEW

Quickchain is a fintech platform that enables users in Nigeria to:s:

  • Sell cryptocurrencies (BTC, ETH, USDT, etc.)
  • Receive proceeds in Nigerian Naira (NGN)
  • Store value in a Naira wallet
  • Withdraw funds to Nigerian bank accounts
  • (Future scope) Use virtual debit cards funded from wallet balance

The Company operates as a digital asset intermediary, and therefore applies strict AML/CFT controls.

3. AML/CFT OBJECTIVES

The objectives of this policy are to:

  • Prevent onboarding of fraudulent or anonymous users
  • Detect and deter suspicious financial activity
  • Ensure full traceability of all transactions
  • Comply with Nigerian regulatory obligations
  • Protect the integrity of the financial system

4. RISK-BASED APPROACH (RBA)

Quchange Technologies Limited applies a risk-based approach, meaning controls are proportionate to the level of risk.

4.1 Risk Categories

a. Customer Risk

  • Low Risk: Verified individuals with consistent transaction patterns
  • Medium Risk: Users with moderate volume or inconsistent behavior
  • High Risk:
    • High-volume traders (VIP users)
    • Users with rapid inflow/outflow activity
    • Politically Exposed Persons (PEPs)

b. Product Risk

  • Crypto-to-Naira conversion → High Risk
  • Wallet storage → Medium Risk
  • Instant withdrawals → High Risk

c. Transaction Risk

  • Large-value transactions
  • Structuring (multiple small transactions)
  • Rapid buy/sell cycles
  • Third-party payments

5. CUSTOMER DUE DILIGENCE (CDD / KYC)

No user may transact more than $300 on Quickchain without completing KYC.

5.1 Minimum KYC Requirements

All users must provide:

  • Full legal name
  • Phone number
  • Email address
  • Bank account details (must match user identity)
  • Valid government-issued ID:
    • NIN
    • BVN
    • International Passport
    • Driver’s License

5.2 Identity Verification

Quickchain uses third-party verification providers “Youverify” to:

  • Validate BVN/NIN
  • Perform facial recognition (liveness check)
  • Match user identity with submitted documents

5.3 Enhanced Due Diligence (EDD)

Applied to high-risk users, including:

  • VIP traders
  • Large-volume users
  • Suspicious activity flags

EDD measures include:

  • Source of funds verification
  • Additional ID documentation
  • Manual review by compliance team
  • Transaction limits until cleared

6. PROHIBITED USERS & ACTIVITIES

Quickchain strictly prohibits:

  • Anonymous or fake identities
  • Use of stolen financial information
  • Transactions linked to:
    • Fraud/scams
    • Darknet markets
    • Terrorist financing
    • Sanctioned entities

Accounts will be immediately suspended if identified.

7. TRANSACTION MONITORING

Quickchain employs real-time and post-transaction monitoring systems.

7.1 Monitoring Triggers

The system flags:

  • Unusual transaction sizes
  • Rapid consecutive transactions
  • Structuring behavior
  • Wallets linked to flagged crypto addresses
  • Sudden spikes in activity

7.2 Blockchain Monitoring

Where applicable, Quickchain integrates tools to:

  • Analyze wallet risk scores
  • Detect links to illicit addresses
  • Flag high-risk crypto inflows

8. SUSPICIOUS ACTIVITY REPORTING (SAR)

If suspicious activity is detected:

8.1 Internal Process

  • Flag raised automatically or by staff
  • Escalation to Compliance Officer
  • Investigation conducted

8.2 External Reporting

Where necessary, Quickchain will report to:

  • Nigerian Financial Intelligence Unit (NFIU)

8.3 Reporting Thresholds

  • Suspicious transactions → Immediate reporting
  • Large transactions

9. RECORD KEEPING

Quickchain maintains records for a minimum of 5 years, including:

  • Customer identification data
  • Transaction history
  • Wallet addresses
  • KYC verification logs
  • Communication records

10. STAFF TRAINING & AWARENESS

All staff involved in operations must:

  • Undergo AML/CFT training
  • Understand fraud indicators
  • Follow escalation protocols

Training is conducted:

  • At onboarding
  • Periodically

INTERNAL CONTROLS & GOVERNANCE

11.1 Compliance Officer

A designated AML Compliance Officer is responsible for:

  • Policy enforcement
  • Monitoring compliance
  • Regulatory reporting
  • Risk assessments

11.2 Access Control

  • Restricted access to sensitive user data
  • Monitoring of staff actions
  • Audit trails for all transactions

11.3 Independent Review

Periodic internal audits will be conducted to ensure:

  • Policy effectiveness
  • Compliance adherence
  • Risk mitigation improvements

12. SANCTIONS COMPLIANCE

Quickchain screens users against:

  • Local Nigerian watchlists
  • International sanctions lists (where applicable)

Any match results in:

  • Immediate account freeze
  • Investigation and reporting

13. DATA PROTECTION & CONFIDENTIALITY

Quickchain ensures:

  • Secure storage of user data
  • Encryption of sensitive information
  • Restricted internal access

All AML investigations are treated as strictly confidential.

14. PENALTIES FOR NON-COMPLIANCE

Failure by staff or users to comply may result in:

  • Account suspension or termination
  • Reporting to authorities
  • Legal action

15. POLICY REVIEW

This AML/CFT Policy is reviewed:

  • Annually
  • Or upon regulatory changes
  • Or after major risk incidents