AML and CFT Policy

Copaly Technologies (individually and collectively, the “Company”), incorporated under the laws of Nigeria offers services through an internet-enabled application marketplace for the purchase and sale of digital assets.

The Company Anti-Money Laundering (“AML”) policies and procedures are designed to deter illicit activities on the platform and protect the users, the business, and the digital currencies and financial services communities from exploitation by criminals. The Company is compliant with the requirements of the Bank Secrecy Act and related FinCEN/SEC regulations and guidance.

As part of the Company’s compliance policies, Know Your Customer (“KYC”) policies and procedures for individual customers have been designed to enable the Company to form a reasonable belief that it knows the true identity of those of its customers for which such review has been performed. The policy applies to all users on the platform and is followed by all of the Company’s employees, consultants, officers, owners, and directors.

Using a risk-based approach as part of KYC & AML Compliance, Copaly has taken the following measures:

• Appointment of a Chief Compliance Officer who has a sufficient level of expertise and independence has responsibility for the oversight of compliance with the relevant legislation, regulations, rules, and industry guidance;
• Establishing and maintaining risk-based KYC, Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) Policy;
• Establishing risk-based tiers for verification of the Company’s users;
• Cooperation with law enforcement requests and local regulatory requirements;
• Filing of Suspicious Activity Reports (“SARs”);
• Company-wide BSA/AML/OFAC training;
• Use of various anti-fraud systems;
• Ongoing rule-based transaction monitoring;
• Investigations using blockchain analytics;

We file SARs if we know, suspect, or have reason to suspect suspicious activities have occurred on our platform. A suspicious transaction is often one that is inconsistent with a user’s known and legitimate business, personal activities, or personal means. Our Chief Compliance Officer reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR. Our Chief Compliance Officer maintains records and supporting documentation of all SARs that have been filed.

The Company has also adopted ongoing OFAC sanctions policies and procedures designed to protect the platform from being used for prohibited transactions, by sanctioned individuals, or for the purposes of evading, avoiding, or otherwise circumventing the U.S. and global sanctions.

Where Copaly has provided you with a translation of the English language version of this policy, then you agree that the translation is provided for your convenience only and that the English language versions of the policy will govern your relationship with Company. If there is any contradiction between what the English language version of the policy says and what a translation says, then the English language version shall control.