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Anti-Money Laundering & Counter-Terrorism Financing Policy

Effective date: 1 March 2026 · Last updated: 1 March 2026

1. Purpose and Scope

This Anti-Money Laundering and Counter-Terrorism Financing Policy (“AML/CTF Policy”) sets out the measures Merx Africa Limited (“Merx”) takes to prevent the use of its platform for money laundering, terrorist financing, proliferation financing, or other financial crimes. This policy applies to all users of the Merx platform, including Sellers, Buyers, and any other persons who transact through or interact with the Platform.

This policy is established in compliance with the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, the Central Bank of Nigeria (CBN) AML/CFT Regulations, the Nigeria Financial Intelligence Unit (NFIU) Act, and all other applicable Nigerian and international anti-money laundering laws and directives.

2. Regulatory Framework

Merx adheres to the following regulatory framework:

  • Money Laundering (Prevention and Prohibition) Act 2022
  • Terrorism (Prevention and Prohibition) Act 2022
  • CBN AML/CFT Regulations for Financial Institutions
  • NFIU Guidelines on Filing of Returns
  • Financial Action Task Force (FATF) Recommendations
  • Economic and Financial Crimes Commission (EFCC) Establishment Act

3. Know Your Customer (KYC)

3.1 Customer Identification

To ensure a seamless experience, Merx allows users to transact as freely as possible. Before a user can conduct escrow transactions on the Platform, Merx only requires identity verification through a valid Bank Verification Number (BVN).

3.2 Customer Due Diligence (CDD)

Merx performs ongoing customer due diligence, including monitoring transaction patterns for unusual activity, periodic review and refresh of KYC documentation, screening against sanctions lists (UN, OFAC, EU, and Nigerian sanctions lists), and Politically Exposed Persons (PEP) screening.

3.3 Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to high-risk customers, including PEPs and their associates, customers from high-risk jurisdictions, customers with complex or unusual transaction patterns, business accounts with opaque ownership structures, and any customer flagged through internal risk assessment.

4. Transaction Monitoring

Merx implements automated and manual transaction monitoring systems to detect suspicious activity. The following triggers prompt further investigation:

  • Transactions that are unusually large relative to the customer’s profile or history
  • Rapid, repeated transactions with no clear commercial purpose
  • Transactions involving high-risk jurisdictions
  • Structuring of transactions to avoid KYC thresholds (smurfing)
  • Multiple accounts linked to the same identity or device
  • Sudden changes in transaction volume or patterns
  • Transactions where the stated purpose does not match the observed activity
  • Attempts to circumvent the escrow process or manipulate dispute outcomes

5. Suspicious Transaction Reporting (STR)

Where Merx identifies or suspects money laundering, terrorist financing, or other financial crime, we are obligated to file a Suspicious Transaction Report (STR) with the Nigeria Financial Intelligence Unit (NFIU) within 24 hours. Merx will also comply with any Currency Transaction Report (CTR) requirements for cash or cash-equivalent transactions meeting the prescribed thresholds.

In accordance with Nigerian law, Merx will not inform the customer that an STR has been filed (tipping-off prohibition). Internal escalation of suspicious activity follows a defined reporting chain from compliance staff to the Chief Compliance Officer and, where required, to the Board of Directors.

6. Record Keeping

Merx maintains comprehensive records of all customer identification documents, transaction data, risk assessments, and STRs for a minimum of ten (10) years from the date of the transaction or the date the business relationship ends, whichever is later. Records are stored securely with appropriate access controls and are made available to regulatory authorities upon lawful request.

7. Sanctions Compliance

Merx screens all users and transactions against applicable sanctions lists, including the United Nations Security Council Consolidated List, OFAC Specially Designated Nationals List, European Union Consolidated List, and any sanctions lists issued by the Nigerian government. Transactions involving sanctioned persons, entities, or jurisdictions are blocked immediately and reported to the relevant authorities.

8. Staff Training

All Merx employees and contractors with access to customer data or involvement in transaction processing receive AML/CTF training upon onboarding and at least annually thereafter. Training covers recognition of suspicious activity, internal reporting procedures, legal obligations, and updates to relevant laws and regulations.

9. Internal Controls and Governance

Merx maintains the following internal controls:

  • A designated Chief Compliance Officer with direct reporting to the Board of Directors
  • Independent audit of AML/CTF procedures at least annually
  • Regular risk assessments of the platform, customer base, and product offerings
  • Documented policies and procedures accessible to all relevant staff
  • Whistleblower protections for employees who report suspicious activity

10. Account Suspension and Termination

Merx reserves the right to immediately suspend or terminate any account where there is a reasonable suspicion of money laundering, terrorist financing, or other financial crime. Escrowed funds associated with suspended accounts will be frozen pending investigation. Merx may be required to remit frozen funds to the relevant Nigerian authority pursuant to a court order or regulatory directive.

11. Cooperation with Authorities

Merx cooperates fully with Nigerian law enforcement and regulatory authorities, including the EFCC, NFIU, CBN, and the Nigeria Police Force. We respond to lawful requests for information in a timely manner and participate in inter-agency coordination as required.

12. Policy Review

This AML/CTF Policy is reviewed at least annually, or more frequently in response to changes in applicable laws, regulatory guidance, or identified risks. Updates are communicated to all relevant staff and reflected in training materials.

13. Contact

For questions or concerns related to this policy, contact:
Merx Africa Limited — Compliance Department
Email: compliance@merx.com.ng
Lagos, Nigeria