Anti-Money Laundering Policy and Procedure

1. Introduction

Tekparadise Ltd ("the Company"), operating the Eden platform, is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF). As a platform that facilitates global financial transactions on behalf of churches, ministries, and faith-based organizations, Eden recognizes its responsibility to prevent misuse of its services for illicit activities.

This policy aligns with applicable regulations, including:

• Money Laundering (Prohibition) Act, 2011 (as amended)
• Terrorism Prevention Act
• SCUML regulations
• GDPR / NDPR (for data handling)
• International best practices (FATF recommendations)

2. Scope of Work

This policy applies to all employees, contractors, partners, and users of the Eden platform. It covers all products, including donations, subscriptions, payments, and digital services.

3. Risk-Based AML Framework

Eden adopts a risk-based approach by assessing and categorizing risks across:

• Customer Risk (churches, pastors, NGOs, individuals)
• Geographic Risk (high-risk jurisdictions)
• Transaction Risk (volume, frequency, cross-border flows)
• Product Risk (donations, subscriptions, live payments)

Customers are classified as:

• Low Risk
• Medium Risk
• High Risk

4. Customer Due Diligence (CDD)

Eden performs identity verification using:

• Government-issued IDs
• NGO/Organization registration documents
• Independent data sources

CDD includes:

• Identity verification
• Ownership structure validation

5. Enhanced Due Diligence (EDD)

EDD is conducted for high-risk customers, including:

• Politically Exposed Persons (PEPs)
• High-volume accounts
• Cross-border entities

EDD measures include:

• Source of funds verification
• Source of wealth assessment
• Senior management approval

6. Sanctions & PEP Screening

All customers are screened against:

• UN & US Sanctions Lists
• OFAC Lists
• EU/UK Sanctions Lists

Screening occurs:

• At onboarding
• Periodically thereafter

PEPs require enhanced monitoring and approval.

7. Transaction Monitoring

Eden implements automated and manual monitoring systems to detect:

• Unusual transaction patterns
• Structuring (smurfing)
• Rapid inflows/outflows
• Suspicious cross-border activity

AI-driven tools are used for behavioral analysis and anomaly detection.

8. Source of Funds Verification

For significant transactions, Eden may require:

• Proof of income
• Donation origin verification
• Supporting financial documentation from the sender & beneficiary

9. Suspicious Activity Reporting (SAR)

All suspicious activities must be reported to the AML Officer immediately.

Reports must include:

• Customer identity
• Nature of suspicion
• Supporting evidence

The AML Officer will:

• Investigate internally
• File Suspicious Transaction Reports (STR) with SCUML or relevant authorities within regulatory timelines

Non-Tipping-Off Rule:

Employees must not disclose to customers that a report has been filed.

10. Record Keeping

Records will be maintained for:

• Customer identification
• Transactions
• Reports filed

Retention period:

• Minimum of 5 years after the relationship ends

11. Ongoing Monitoring & Review

• Continuous monitoring of transactions
• Periodic KYC updates (annually or risk-based)
• Reclassification of customer risk levels

12. Third-Party Risk Management

All partners (banks, payment processors, APIs) must:

• Meet AML compliance standards
• Undergo due diligence

13. Data Protection & Privacy

All AML data is:

• Securely stored
• Access-controlled
• Shared only with authorized authorities

In compliance with NDPR and GDPR.

14. Governance & Responsibilities

AML Officer Responsibilities:

• Oversee AML program
• Report to executive management
• Liaise with regulators
• Conduct training

Management Responsibilities:

• Ensure compliance enforcement
• Support AML initiatives

15. Training

All staff must undergo:

• Annual AML training
• Role-specific compliance training

16. Enforcement & Disciplinary Actions

Non-compliance may result in:

• Disciplinary action
• Termination
• Legal consequences

17. Policy Review

This policy will be:

• Reviewed periodically & annually
• Updated based on regulatory changes

18. Jurisdiction-Specific Compliance (Nigeria, UK, US, EU)

Eden operates globally and therefore aligns its AML/CTF controls with key regulatory expectations across major jurisdictions:

18.1 Nigeria

Eden complies with:

• Money Laundering (Prohibition) Act, 2011 (as amended)
• Terrorism Prevention Act
• Special Control Unit Against Money Laundering (SCUML) regulations
• Central Bank of Nigeria (CBN) AML/CFT Guidelines

Requirements include:

• Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures
• Reporting Suspicious Transaction Reports (STRs) to SCUML
• Maintaining proper transaction records and audit trails
• Compliance with threshold reporting requirements
• Ongoing monitoring of transactions and customer relationships

18.2 United Kingdom (UK)

Eden adheres to:

• UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
• Financial Conduct Authority (FCA) guidance

Requirements include:

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk clients
• Ongoing monitoring of business relationships
• Reporting Suspicious Activity Reports (SARs) to the UK National Crime Agency (NCA)
• Maintaining appropriate internal controls and independent audits

18.3 United States (US)

Eden aligns with:

• Bank Secrecy Act (BSA)
• USA PATRIOT Act
• Financial Crimes Enforcement Network (FinCEN) requirements

Requirements include:

• Customer Identification Program (CIP)
• Monitoring and reporting Suspicious Activity Reports (SARs) to FinCEN
• Screening against Office of Foreign Assets Control (OFAC) sanctions lists
• Recordkeeping and transaction reporting (including Currency Transaction Reports where applicable)

18.4 European Union (EU)

Eden complies with:

• EU Anti-Money Laundering Directives (AMLD5 & AMLD6)
• European Banking Authority (EBA) guidelines

Requirements include:

• Risk-based AML framework implementation
• Beneficial ownership identification and verification
• Ongoing monitoring and reporting to relevant Financial Intelligence Units (FIUs)
• Strong data protection alignment under GDPR

Approved By: