Anti–Money Laundering (AML) Policy

1. Purpose and Scope

This Policy applies to all users, employees, contractors, affiliates, and partners of Peer Capital and covers all products, services, and operations where Peer Capital is engaged.

2. Legal and Regulatory Framework

Peer Capital adheres to relevant AML/CTF frameworks and guidance applicable to our operations, including Know Your Customer (KYC) and Customer Due Diligence (CDD) obligations, sanctions screening, and suspicious activity reporting requirements.

3. Customer Due Diligence (CDD) and KYC

• Collect and verify identity information (e.g., full name, date of birth, address, phone, email).
• Obtain and verify government–issued IDs and biometrics, where required.
• Verify BVN/NIN or equivalent identifiers through approved verification providers.
• Identify and verify beneficial owners and control persons where applicable.
• Assess risk profiles using a risk–based approach and apply appropriate diligence levels.

4. Enhanced Due Diligence (EDD)

For higher–risk customers, geographies, products, or transactions, Peer Capital implements EDD, which may include additional documentation, source of funds/wealth verification, senior management approval, and heightened ongoing monitoring.

5. Ongoing Monitoring

• Monitor transactions to identify unusual patterns, structuring, or suspicious behavior.
• Review alerts generated by screening and monitoring tools and take appropriate action.
• Maintain up–to–date customer information and re–verify when risk triggers are met.

6. Sanctions and Watchlist Screening

Users and transactions are screened against applicable sanctions, watchlists, PEP, and adverse media lists. Matches or potential matches are escalated and handled in accordance with regulatory expectations.

7. Prohibited Activities

• Money laundering, terrorist financing, or evasion of sanctions.
• Fraud, bribery, corruption, tax evasion, or other financial crimes.
• Use of false or stolen identities, or forged documentation.
• Transactions with shell banks or anonymous accounts.

8. Suspicious Activity Reporting

Peer Capital investigates suspicious activity and, where required, reports to competent authorities. Users may be asked to provide additional information and should cooperate fully.

9. Record Keeping

Records relating to customer identification, verification, transactions, and investigations are retained for the period required by law and maintained securely to preserve integrity and confidentiality.

10. Risk–Based Approach

Controls are commensurate with identified risks. Peer Capital periodically reviews its risk assessments and updates controls, tools, and procedures accordingly.

11. Training and Awareness

Personnel receive periodic AML/CTF training appropriate to their roles, including red flags, reporting obligations, and data protection responsibilities.

12. Third–Party Relationships

Peer Capital conducts due diligence on partners, vendors, and payment providers and requires appropriate contractual assurances and controls to meet AML/CTF obligations.

13. Governance and Oversight

AML compliance is overseen by designated compliance personnel and management. Material issues are escalated to senior leadership, and our program is reviewed periodically for effectiveness.

14. Data Protection

Customer information collected for AML/CTF compliance is processed in line with our Privacy Policy and applicable data protection laws. Access is limited to authorized personnel.

15. Violations and Enforcement

Violations of this Policy may result in account restrictions, suspension, termination, or reporting to authorities, as appropriate.

16. Updates

This Policy may be updated periodically. Material changes will be reflected on this page.