KYC Policy

BorderFlo Technologies Limited is committed to maintaining the highest standards of customer due diligence, anti-money laundering (AML), and countering the financing of terrorism (CFT). The company holds a zero-tolerance policy for financial crime and operates in full compliance with the Central Bank of Nigeria's (CBN) Know Your Customer regulations, the Money Laundering (Prevention and Prohibition) Act 2022 (MLPPA 2022), the Terrorism (Prevention and Prohibition) Act 2022 (TPPA 2022), the Cybercrimes (Prohibition, Prevention, etc.) Act 2015, the Advance Fee Fraud Act, and all applicable circulars and guidelines issued by the CBN and the Nigerian Financial Intelligence Unit (NFIU).

This Know Your Customer and AML/CFT Policy ("Policy") sets out the comprehensive framework within which BorderFlo identifies and verifies the identity of its customers, assesses and monitors customer risk, maintains records of due diligence activities, and handles reporting. It applies to all customers of the BorderFlo consumer payment service, to all transactions processed through the Platform, and to all personnel, contractors, agents, payout partners, and institutional stakeholders involved in customer onboarding and transaction monitoring.

No customer relationship shall be established, and no transaction shall be processed, unless and until the applicable requirements of this Policy have been satisfied. Any relaxation of these requirements requires documented approval from the compliance function and, where applicable, from the relevant regulatory authority.

This KYC Policy is issued pursuant to and in compliance with the following legislative and regulatory instruments, as amended from time to time:

• Central Bank of Nigeria Regulations on Know Your Customer 2023.
• CBN Revised Standards on Know Your Customer Procedures, December 2023, including the mandatory BVN and NIN requirements for all financial accounts.
• Money Laundering Prevention and Prohibition Act 2022 ("MLPPA 2022").
• Terrorism Prevention and Prohibition Act 2022 ("TPPA 2022").
• Nigerian Financial Intelligence Unit AML/CFT/CPF Regulations.
• CBN Guidelines on Consumer Protection in the Nigerian Financial System.
• Nigeria Data Protection Act 2023 ("NDPA"), as applicable to the processing of personal data in the course of KYC activities.

In the event of any inconsistency between this KYC Policy and Applicable Law, Applicable Law shall prevail.

In this KYC Policy:

Beneficial Owner

A natural person who ultimately owns or controls a legal entity, or on whose behalf a transaction is being conducted, as defined in the MLPPA 2022.

BVN

Bank Verification Number, a unique eleven-digit identifier assigned to each individual registered with the CBN's biometric data capture programme, operated by NIBSS.

CDD

Customer Due Diligence, the process of identifying and verifying the identity of a customer and assessing the risk associated with the customer relationship.

EDD

Enhanced Due Diligence, a heightened level of customer due diligence applied to customers or transactions that present elevated risk.

NIN

National Identity Number, the unique identification number issued by the National Identity Management Commission to Nigerian citizens and legal residents.

PEP

Politically Exposed Person, an individual who is or has been entrusted with a prominent public function, and the immediate family members and close associates of such an individual.

STR

Suspicious Transaction Report, a mandatory report filed with the NFIU in respect of a transaction that gives rise to reasonable suspicion of money laundering, terrorist financing, or other financial crime.

CTR

Currency Transaction Report, a mandatory report filed with the NFIU in respect of a cash transaction exceeding the applicable threshold.

BorderFlo operates two live services, which dictate its operational risk exposure:

4.1 Educational Payments

Remittance of application, visa, and school-related fees to fixed institutional payees, including SEVIS (U.S. Department of Homeland Security), VISA application fees, WES (World Education Services) credential evaluation fees, and direct school/tuition fee payments.

4.2 Cross-Border Money Transfer

Person-to-person and person-to-business transfer of funds across supported African corridors, via BorderFlo's own rails and/or local payout agents and partner institutions in receiving markets.

BorderFlo maintains a uniform, standard verification framework for identity validation across all onboarding workflows.

5.1 Account Opening Requirements

BorderFlo collects the following information from all customers as part of the standard identification process:

• Full legal name, as it appears on government-issued identification.
• Date of birth.
• Nationality.
• Residential address.
• Nigerian telephone number.
• Email address.
• Bank Verification Number.
• National Identity Number.

5.2 Verification

The identity of every customer is verified through electronic means as the primary method, supplemented by documentary review where required. The verification process includes the following steps:

1. BVN Verification: The customer's BVN is submitted to NIBSS for verification. NIBSS returns the name, date of birth, and enrolled telephone number associated with the BVN. BorderFlo compares this data against the information provided by the customer.
2. NIN Verification: Where NIN is required, it is verified through the National Identity Management Commission's verification API, which returns the name and biometric data associated with the NIN.
3. Liveness Check: A liveness check is conducted using a facial biometric matching system to confirm that the applicant is a living person and to compare the applicant's live image against the photograph associated with their government-issued identification. The liveness check must be passed before account opening is permitted.
4. Sanctions Screening: All customers are screened against the United Nations Security Council consolidated sanctions list, the OFAC Specially Designated Nationals list, and any other applicable regulatory watchlists. Screening is conducted at onboarding and on an ongoing basis.

5.3 Beneficial Ownership

The Platform is designed for use by individual consumers transacting on their own behalf. The use of the Platform to transact on behalf of a third party without that party's knowledge and consent is prohibited. Where BorderFlo has reason to believe that a customer is acting on behalf of an undisclosed principal, it will apply enhanced due diligence procedures and may request a declaration of beneficial ownership.

5.4 Ongoing Monitoring

Customer due diligence is not a one-time process. BorderFlo maintains an ongoing monitoring programme that includes:

• Automated transaction monitoring against defined rules and thresholds for detecting unusual or suspicious patterns.
• Periodic review of customer information to ensure continued accuracy.
• Re-verification of customer identity where there is a material change in circumstances, such as a change of name, a significant change in transaction behaviour, or a trigger arising from enhanced due diligence.
• Continuous sanctions screening against updated watchlists.

5.5 Payee Verification (Education Payments)

Education payments utilize a whitelist model:

• Payments to SEVIS, WES, embassy portals, and schools are validated against a whitelisted directory of institutional payee accounts and standard reference code formats.
• Non-whitelisted or unverified format requests are held for manual compliance review before release.

6.1 When EDD Applies

BorderFlo applies Enhanced Due Diligence in the following circumstances:

• The customer is a Politically Exposed Person or a close associate or family member of a PEP.
• The customer or a transaction presents indicators of elevated risk as identified by BorderFlo's transaction monitoring system.
• The Transaction involves a jurisdiction classified as high risk by the Financial Action Task Force.
• The customer's transaction patterns are unusual relative to their stated occupation, source of funds, or prior transaction history.
• BorderFlo receives information that creates a suspicion of money laundering, terrorist financing, or fraud.

6.2 EDD Measures

Where Enhanced Due Diligence applies, BorderFlo may implement one or more of the following measures:

• Requesting additional identity documentation.
• Requiring a source of funds declaration.
• Requiring a source of wealth declaration.
• Applying transaction limits.
• Requiring senior compliance officer approval before processing a Transaction.
• Conducting additional verification of the beneficiary of a Cross-Border Transaction.
• Placing a temporary hold on a Transaction or Account pending the completion of enhanced checks.
• Requesting a face-to-face or video call verification in exceptional circumstances.

6.3 Politically Exposed Persons

Where a customer is identified as a PEP, or where a customer subsequently becomes a PEP, BorderFlo applies the following specific measures:

• Senior compliance officer approval is required before establishing or continuing the Account relationship.
• The source of wealth and source of funds of the PEP must be verified.
• Enhanced ongoing monitoring of all Transactions is applied for the duration of the Account relationship.
• The status and risk profile of the PEP is reviewed at least annually.

7.1 Indicators of Suspicious Activity

The following are examples of transaction patterns and behaviours that may indicate suspicious activity. This list is not exhaustive and is provided as guidance only:

• Transactions that appear to have no legitimate commercial purpose.
• Rapid succession of transactions that individually fall below reporting thresholds but collectively suggest structuring.
• Transactions inconsistent with the customer's stated purpose, occupation, or financial profile.
• Requests to transact on behalf of undisclosed third parties.
• Unexplained changes in transaction volume or frequency.
• Attempts to provide false or misleading information during the KYC process.
• Transactions to or from jurisdictions associated with financial crime or terrorist financing.
• Customers who exhibit unusual interest in record-keeping, reporting thresholds, or compliance procedures.

7.2 Internal Escalation

Any member of the BorderFlo team who becomes aware of a potential suspicious activity must report it immediately to the Compliance Officer. The Compliance Officer will review the report and determine whether it warrants the filing of a Suspicious Transaction Report with the NFIU. The Compliance Officer's determination and the reasoning supporting it will be documented and retained.

7.3 Suspicious Transaction Reports

BorderFlo will file a Suspicious Transaction Report with the NFIU within seven days of forming a suspicion, or within twenty-four hours in cases of urgency, as prescribed by the MLPPA 2022. The filing of a Suspicious Transaction Report is confidential. No employee of BorderFlo and no other person may "tip off" a customer or any third party that a report has been or may be filed.

7.4 Currency Transaction Reports

In accordance with the MLPPA 2022 and applicable CBN guidelines, BorderFlo will file a Currency Transaction Report with the NFIU in respect of any cash transaction or aggregate of related cash transactions exceeding the applicable regulatory threshold within a single business day.

BorderFlo retains all records generated in the course of its KYC and AML activities for a minimum of seven years from the date of the relevant Transaction or the date of Account closure, whichever is later, as required by the MLPPA 2022. These records include:

• All identity verification documents and verification results.
• Transaction records, including date, amount, currency, purpose, and beneficiary details.
• Communications with customers in connection with CDD or EDD queries.
• Records of suspicious activity decisions, whether or not an STR was filed.
• STR and CTR reports filed with the NFIU.
• Sanctions screening results.

Records are maintained in a secure manner and are accessible to authorised personnel and to regulatory authorities upon lawful request.

All personnel involved in customer onboarding, transaction processing, or compliance monitoring are required to complete AML and KYC training before commencing their duties and to complete refresher training at least annually thereafter. Training covers the requirements of the MLPPA 2022, the typologies of financial crime relevant to digital payment services, the indicators of suspicious activity, and the procedures for internal escalation and external reporting.

Where a person who does not hold a BorderFlo Account requests to transmit funds through a BorderFlo Agent, the Agent is required to collect and verify the identification of the sender before processing the Transaction, in accordance with this KYC Policy. Agents are prohibited from processing Transactions for senders who decline to provide adequate identification. The identification requirements applicable to non-account holders are set out in the BorderFlo Agent Policy, which supplements this KYC Policy.

11.1 Ownership

This KYC Policy is owned by the Compliance Officer of BorderFlo Technologies Limited. The Policy is reviewed at least annually and updated promptly to reflect changes in Applicable Law, regulatory guidance, or the risk profile of the Platform.

11.2 Breaches

Any breach of this KYC Policy must be reported to the Compliance Officer immediately. Material breaches will be reported to the Board and, where required, to the relevant regulatory authority. Disciplinary action may be taken against any personnel found to have knowingly breached this Policy.

11.3 Regulatory Cooperation

BorderFlo will cooperate fully with all lawful requests, inspections, and examinations from the CBN, NFIU, EFCC, NDLEA, and any other regulatory or law enforcement authority with jurisdiction over the Platform's activities. BorderFlo will designate a compliance liaison who is authorised to respond to regulatory inquiries on behalf of the organisation.