1.1. Framework Establishment

1.1.1. This Policy establishes Skye Wallet's framework for ensuring strict compliance with applicable Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and sanctions obligations. It applies to all customers, employees, business partners, products, and services, including Skye's custodial wallet operations and peer-to-peer (P2P) escrow platform.

1.2. Objective

1.2.1. The objective is to safeguard Skye Wallet against being exploited for financial crime, while maintaining compliance with Nigerian law and international standards.

2.1. Legal Foundation

2.1.1. This Policy is anchored on the following laws, regulations, and standards:

• 2.1.1.1. Money Laundering (Prevention and Prohibition) Act, 2022;
• 2.1.1.2. Terrorism (Prevention and Prohibition) Act, 2022;
• 2.1.1.3. Nigeria Data Protection Act, 2023;
• 2.1.1.4. Central Bank of Nigeria (CBN) Customer Due Diligence Regulations, 2023;
• 2.1.1.5. CBN Guidelines for Virtual Asset Service Providers (VASPs), 2023;
• 2.1.1.6. SEC Rules on Digital Assets Issuance, Offering Platforms and Custody, 2022;
• 2.1.1.7. Relevant Financial Action Task Force (FATF) Recommendations.

3.1. The Board of Directors has ultimate responsibility for the approval, oversight, and enforcement of this Policy.

3.2. A Money Laundering Reporting Officer (MLRO) shall be designated to administer the AML/CFT framework, ensure compliance with reporting obligations, and serve as the liaison with the Nigerian Financial Intelligence Unit (NFIU).

3.3. An Independent Audit Function shall periodically review the adequacy and effectiveness of this Policy.

4.1. Skye Wallet adopts a risk-based approach, consistent with FATF and CBN guidelines. An Enterprise-Wide Risk Assessment (EWRA) shall be conducted at least annually to assess inherent and residual risks across the following dimensions:

4.2. Products and services offered;

• 4.2.1. Customer categories and profiles;
• 4.2.2. Geographic exposure;
• 4.2.3. Delivery channels, including digital onboarding and P2P escrow.

4.3. Findings from the EWRA shall guide control measures and risk mitigation strategies.

5.1. Tiered KYC Structure

5.1.1. Skye Wallet shall operate a structured KYC framework, calibrated to customer risk and consistent with CBN's tiered approach.

5.2. Tier 1 – Basic KYC (Entry-Level Wallet)

5.2.1. Information: Full name, date of birth, phone number, email address, and at least one government-issued ID.

5.2.2. Verification: OTP verification and biometric liveness check.

5.3. Tier 2 – Standard KYC

5.3.1. Information: All Tier 1 data plus BVN, residential address, and valid proof of address.

5.3.2. Verification: BVN validation and address confirmation.

5.3.3. Access: Full access to P2P escrow.

5.4. Politically Exposed Persons (PEPs) and High-Risk Customers

5.4.1. Enhanced Due Diligence (EDD) shall apply.

5.4.2. Senior management approval required before onboarding.

5.4.3. Adverse media checks and continuous monitoring are mandatory.

5.5. Periodic KYC Refresh

5.5.1. Tier 1: Every 12 months.

5.5.2. Tier 2: Every 24 months.

5.5.3. Tier 3 / PEPs: Every 12 months or upon material change.

5.6. Non-Compliance

5.6.1. Failure to provide complete or verifiable KYC documentation shall result in account suspension, freezing of funds, or termination.

5.6.2. Transactions may be declined where CDD obligations are unmet.

6.1. In line with the CBN AML/CFT Regulations 2022 and the CBN Guidance Notes on PEPs (May 2023), a Politically Exposed Person (PEP) refers to any individual who is, or has been, entrusted with a prominent public function. This includes:

6.1.1. Domestic PEPs (Nigeria)

• 6.1.1.1. The President, Vice President, State Governors, Deputy Governors.
• 6.1.1.2. Members of the National Assembly and State Houses of Assembly.
• 6.1.1.3. Local Government Chairpersons, Vice Chairpersons and Councillors.
• 6.1.1.4. Ministers, State Commissioners, Special Advisers, and Senior Political Appointees.
• 6.1.1.5. Heads, Directors-General, and Senior Executives of Government Ministries, Departments, Agencies (MDAs), and Parastatals.
• 6.1.1.6. Senior members of the Judiciary, Armed Forces, Police, and other uniformed services.

6.1.2. Foreign PEPs

Individuals who hold or have held prominent public functions in other countries, such as Heads of State, senior politicians, senior government officials, military leaders, judicial officials, and executives of state-owned enterprises.

6.1.3. International Organization PEPs

Persons who hold or have held prominent functions in international organizations, such as directors, deputy directors, or members of boards of international bodies (e.g., United Nations, African Union, ECOWAS).

6.1.4. Family Members of PEPs

• 6.1.4.1. Spouse,
• 6.1.4.2. children,
• 6.1.4.3. parents,
• 6.1.4.4. siblings,
• 6.1.4.5. in-laws,
• 6.1.4.6. and other dependents.

6.1.5. Close Associates of PEPs

Persons known to maintain close business or personal relationships with a PEP, including joint ownership of entities, joint financial arrangements, or relationships which may pose AML/CFT risks.

6.2. Declaration Requirement

6.2.1. In compliance with applicable Nigerian AML/CFT laws and regulations, Skye Wallet Users may be required to declare whether they are a PEP, a family member of a PEP, or a close associate of a PEP.

6.2.2. Such declaration shall be made truthfully at the point of registration or at any other stage if requested, in line with legal and regulatory requirements.

6.2.3. Users acknowledge that this obligation arises from Nigerian law and international AML/CFT standards.

6.3. Enhanced Due Diligence (EDD) for PEPs

6.3.1. Where a User is identified as a PEP, Skye Wallet shall apply enhanced due diligence measures, including:

6.3.2. Obtaining approval from senior management prior to establishing or continuing the business relationship.

6.3.3. Taking reasonable measures to establish the source of wealth and source of funds.

6.3.4. Conducting enhanced, ongoing monitoring of transactions to detect unusual or suspicious activity.

6.4. Ongoing Monitoring

6.4.1. PEP status is not time-bound; Users who cease to hold public office may still be treated as PEPs for a reasonable period, in line with regulatory expectations.

6.4.2. Users must promptly update their profile to reflect any change in their PEP status.

6.4.3. Skye Wallet reserves the right to review, suspend, or terminate accounts where a User's PEP status presents heightened money laundering or terrorism financing risks.

7.1. Skye Wallet shall monitor transactions on a continuous basis to detect anomalies, structuring, or suspicious activities. This includes:

7.2. Real-time transaction screening;

7.3. Daily sanctions/PEP/adverse media checks;

7.4. Risk-based transaction pattern analysis.

8.1. All P2P buyers and sellers must be KYC-verified.

8.2. Assets shall remain locked in escrow until confirmed settlement.

8.3. Skye Wallet reserves the right to freeze transactions pending investigation.

8.4. Disputes shall be resolved under Skye Wallet's internal dispute resolution framework, subject to escalation to regulators where required.

9.1. Suspicious Transaction Reports (STRs): To be filed with the NFIU within twenty-four (24) hours of suspicion.

9.2. Cash Transaction Reports are required for cash transactions that exceed the threshold prescribed under applicable laws and regulations, as may be amended or updated from time to time.

10.1. All KYC, transactional, and reporting records shall be securely maintained for not less than five (5) years following the date of transaction or account closure, whichever is later.

11.1. AML/CFT training shall be mandatory for all staff upon onboarding and annually thereafter. Specialized training shall be provided for staff in high-risk roles.

12.1. All personal data obtained under this Policy shall be processed strictly in compliance with the Nigeria Data Protection Act, 2023, and relevant NDPC directives. Skye Wallet shall ensure confidentiality, integrity, and security of data, and report material breaches to the NDPC within seventy-two (72) hours.