Anti-Money Laundering & KYC Policy

Ajaro is committed to the highest standards of anti-money laundering (AML), counter-terrorism financing (CTF), and know your customer (KYC) compliance. This Policy establishes the controls, procedures, and obligations required to detect, prevent, and report financial crime in accordance with Nigerian law and international best practice, including the recommendations of the Financial Action Task Force (FATF).

This Policy applies to:

• All registered Vendors and their authorised Admins;
• All Ajaro directors, employees, contractors, and agents;
• All transactions processed through the Platform, including product sales, payouts, subscription payments, and promotional credits;
• Any third-party service provider engaged by Ajaro in connection with payment processing, identity verification, or financial services.

This Policy is owned and maintained by Ajaro's designated Money Laundering Reporting Officer (MLRO). The MLRO is responsible for overseeing AML/KYC compliance, receiving internal suspicious activity reports, and filing Suspicious Transaction Reports (STRs) with the Nigerian Financial Intelligence Unit (NFIU) as required. The MLRO can be reached at compliance@ajaro.com.ng.

We prevent financial crime by implementing robust KYC procedures at onboarding, applying risk-based due diligence to all Vendors, and restricting access to the Platform for individuals or entities that fail to meet our verification standards. No Vendor may go live on the Platform without completing the KYC process set out in Section 4.

We detect suspicious activity through automated transaction monitoring systems that flag unusual patterns, manual review by our compliance team, ongoing screening of Vendors against sanctions lists and PEP databases, and internal reporting channels that allow staff and Vendors to escalate concerns.

Where suspicious activity is identified, we report it to the relevant Nigerian authorities — primarily the NFIU and the EFCC — in accordance with the timelines and procedures set out in Section 7. We cooperate fully with all lawful requests from Nigerian regulatory and law enforcement authorities.

We maintain comprehensive records of all KYC documents, transaction data, due diligence assessments, and suspicious activity reports for the minimum periods required by Nigerian law. Full details are set out in Section 10.

KYC is not a one-time exercise. Ajaro conducts periodic KYC reviews of all active Vendors on the following schedule: standard-risk Vendors — every 24 months; medium-risk Vendors — every 12 months; high-risk Vendors and PEPs — every 6 months. Reviews are also triggered by material changes such as a change of ownership, business address, or bank account, or by a significant and unexplained change in transaction volume or patterns.

For corporate Vendors, we are required to identify and verify every person who ultimately owns or controls 25% or more of the shares or voting rights in the business ("Beneficial Owner"). Vendors must declare all Beneficial Owners and provide the same identity verification documents required for individual Vendors for each one. Any change in beneficial ownership must be notified to Ajaro within fourteen (14) days of the change occurring.

Under Nigerian law and FATF guidance, PEPs include current and former holders of prominent public functions, specifically:

• Heads of state, heads of government, ministers, and deputy ministers;
• Members of the National Assembly, State Houses of Assembly, and their equivalents;
• Senior judicial officers, including justices of the Supreme Court, Appeal Court, and Federal High Court;
• Ambassadors, high commissioners, and senior diplomats;
• Senior military officers above the rank of Colonel (Army/Air Force) or Captain (Navy);
• Chairmen and directors of state-owned enterprises and government bodies;
• Senior officials of international organisations;
• Immediate family members of any of the above (spouse, parents, children, siblings);
• Close associates who are known to have joint beneficial ownership or business interests with any of the above.

Where a Vendor or their beneficial owner is identified as a PEP, the following additional steps apply before account approval:

• Senior management approval is required before the account may be activated;
• Enhanced Due Diligence (Tier 3 KYC) is applied, including a source of funds and source of wealth declaration;
• The business relationship is subject to enhanced ongoing monitoring throughout its duration;
• The KYC review cycle is reduced to every six (6) months regardless of transaction volume;
• Any transaction by a PEP Vendor that exceeds ₦5 million requires additional manual review before the payout is processed.

Where a Vendor, beneficial owner, or Admin is matched against any of the above sanctions lists:

• The account is immediately frozen pending review;
• All pending payouts are suspended;
• The MLRO is notified within one (1) hour of the match being identified;
• The match is assessed to determine whether it is a true match or a false positive;
• If confirmed as a true match, the account is permanently terminated, all funds are frozen, and the matter is referred to the EFCC and NFIU without delay;
• Ajaro does not notify the Vendor of a confirmed sanctions match until advised by the relevant authority that it is lawful to do so.

All Ajaro employees involved in customer onboarding, transaction processing, or compliance functions receive mandatory AML/KYC training upon joining and at least annually thereafter. Training covers: the legal framework for AML/KYC in Nigeria; how to identify and report suspicious activity; the tipping-off prohibition; Ajaro's internal reporting procedures; and their personal criminal liability for AML failures. Training completion is recorded and forms part of each employee's performance record.

All Vendors are required to acknowledge this AML/KYC Policy at registration. By registering as a Vendor, you confirm that you have read and understood this Policy and agree to comply with its requirements. Ajaro provides guidance resources in the Vendor Center to help Vendors understand their compliance obligations. Vendors who have specific compliance questions may contact our MLRO at compliance@ajaro.com.ng.