Bit9ja
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Bit9ja Anti-Money Laundering (AML) & Combating the Financing of Terrorism (CFT) Policy

1. Definitions

  • AML/CFT: Anti-Money Laundering and Combating the Financing of Terrorism.
  • Money Laundering (ML): Any act intended to conceal, disguise, or legitimize the origin of proceeds derived from criminal activities.
  • Terrorist Financing (TF): The provision, collection, or use of funds to support terrorist acts or organizations, regardless of whether the funds are from legitimate or illegitimate sources.
  • Customer Due Diligence (CDD): Measures undertaken to identify, verify, and monitor customers to prevent ML/TF risks.
  • Enhanced Due Diligence (EDD): Additional checks applied to customers assessed as high risk.
  • NFIU: Nigeria’s national authority responsible for receiving, analyzing, and disseminating financial intelligence relating to ML/TF.

2. Introduction

Bit9ja is a digital financial services platform providing cryptocurrency trading, gift card exchange, and bill payment services. As part of our commitment to financial integrity and regulatory compliance, Bit9ja maintains a robust AML/CFT framework designed to prevent the misuse of our platform for money laundering, terrorist financing, or other financial crimes. Bit9ja recognizes its responsibility to comply with all applicable Nigerian AML/CFT laws and to cooperate fully with regulatory and law-enforcement authorities.

3. Legal and Regulatory Framework

Bit9ja’s AML/CFT program is guided by applicable Nigerian laws and regulations, including but not limited to:

  • Money Laundering (Prevention and Prohibition) Act, 2022
  • Terrorism (Prevention and Prohibition) Act, 2022
  • Central Bank of Nigeria (CBN) AML/CFT Regulations
  • Securities and Exchange Commission (SEC) Rules and Guidelines
  • Nigerian Financial Intelligence Unit (NFIU) Regulations

Bit9ja commits to continuous compliance with any updates or new directives issued by relevant authorities.

4. Risk-Based Approach

Bit9ja adopts a risk-based approach to AML/CFT compliance. This approach allows the company to allocate resources proportionately to the level of risk identified.

Risk assessments are conducted periodically to evaluate:

  • The nature of Bit9ja’s products and services
  • Customer types and transaction behavior
  • Geographic exposure
  • Emerging ML/TF threats

Higher-risk customers or activities are subject to increased scrutiny and controls.

5. Customer Due Diligence (CDD)

Bit9ja implements comprehensive CDD measures before onboarding customers and throughout the business relationship.

Standard CDD includes:

  • Verification of customer identity using government-issued identification
  • Collection of proof of address and other supporting documents
  • Understanding the purpose and intended nature of the customer relationship
  • Assessment of the customer’s source of funds where applicable

Enhanced Due Diligence (EDD)

Customers assessed as high risk—such as politically exposed persons (PEPs), high-net-worth individuals, or customers from high-risk jurisdictions—are subject to EDD, which may include:

  • Additional identity verification
  • Deeper source-of-funds analysis
  • Increased transaction monitoring

6. Transaction Monitoring

Bit9ja continuously monitors transactions using a combination of automated systems and manual reviews to detect suspicious or unusual activity.

Monitoring includes:

  • Identification of unusual transaction patterns
  • Detection of large, frequent, or inconsistent transactions
  • Review of transactions involving high-risk customers or jurisdictions

Suspicious activities are promptly investigated and escalated in line with regulatory requirements.

7. Record Keeping

Bit9ja maintains accurate and complete records of:

  • Customer identification and verification documents
  • Transaction histories
  • Risk assessments and monitoring results

Records are retained for a minimum of five (5) years after the completion of a transaction or termination of the customer relationship, in accordance with Nigerian law.

8. Reporting Obligations

Bit9ja complies fully with its reporting obligations under Nigerian AML/CFT regulations.

  • Suspicious transactions are reported to the NFIU via Suspicious Transaction Reports (STRs).
  • Employees are required to escalate any unusual or suspicious activity immediately to the compliance function.
  • Reports are made confidentially and without tipping off the customer.

9. Training and Awareness

Bit9ja ensures that all relevant employees receive regular AML/CFT training.

Training programs cover:

  • AML/CFT laws and obligations
  • Identification of suspicious transactions
  • Reporting procedures and escalation channels
  • Updates on emerging financial crime trends

Refresher training is conducted periodically to ensure continued compliance and awareness.

10. Internal Controls and Governance

Bit9ja maintains strong internal controls to support AML/CFT compliance, including:

  • Clear compliance oversight and reporting structures
  • Segregation of duties where appropriate
  • Periodic internal reviews and audits of AML/CFT processes

Senior management is responsible for ensuring the effectiveness of the AML/CFT framework.

11. Sanctions and Enforcement

Bit9ja operates a zero-tolerance policy toward money laundering and terrorist financing.

Non-compliance may result in:

  • Regulatory investigations
  • Financial penalties and sanctions
  • Termination of employment or business relationships
  • Criminal prosecution where applicable

12. Conclusion

Bit9ja is committed to maintaining a secure, transparent, and compliant platform. Through strong governance, continuous monitoring, and adherence to Nigerian AML/CFT regulations, Bit9ja aims to prevent financial crime while protecting users and maintaining trust with regulators and partners. This policy is reviewed periodically and updated to reflect regulatory changes and evolving risks.

For AML inquiries, contact: compliance@bit9ja.com