Anti-Money Laundering, Counter-Terrorist Financing & Counter-Proliferation Financing Policy

1. Purpose

Sentinel Escrow Limited ("Sentinel") is committed to preventing its platform from being used for money laundering, terrorist financing, proliferation financing, fraud, or other financial crimes.

This policy establishes the basic controls Sentinel uses to identify customers, assess risks, monitor transactions, identify suspicious activity, and maintain appropriate records.

2. Scope

This policy applies to Sentinel's customers, transactions, employees, contractors, and business activities conducted through its escrow platform and related services.

Sentinel primarily facilitates escrow transactions involving physical goods, while also supporting legitimate services that can appropriately be facilitated through an escrow arrangement.

3. Customer Identification and KYC

Sentinel applies a risk-based Know Your Customer (KYC) process.

• Level 1: Phone number and email verification. Level 1 users may interact with Sentinel's platform and explore available features but cannot initiate or participate in monetary transactions.
• Level 2: BVN and government-issued identification are required before customers can access applicable monetary transaction functionality.
• Level 3: Additional verification, including proof of address and live selfie verification, may be required based on transaction limits, risk level, or other compliance requirements.

Sentinel may request additional information or documentation where necessary to verify a customer's identity or assess risk.

4. Customer Risk Assessment

Sentinel may assess customers based on factors including:

• KYC status and completeness
• Transaction activity and volume
• Transaction patterns and frequency
• Nature of the customer's activities
• Unusual or inconsistent account activity
• Sanctions or politically exposed person (PEP) exposure
• Other factors that may indicate increased financial crime risk

Higher-risk customers may be subject to enhanced due diligence, transaction restrictions, suspension, or account closure.

5. Transaction Monitoring

Sentinel maintains controls designed to identify unusual or potentially suspicious activity.

• Unusually large or frequent transactions
• Repeated or unusual transaction patterns
• Activity inconsistent with a customer's profile
• Multiple accounts exhibiting linked or suspicious behaviour
• Attempts to circumvent applicable KYC or transaction limits
• Transactions associated with suspected fraud or other financial crime

Where activity is considered suspicious, Sentinel may delay, restrict, reject, or suspend a transaction or account while appropriate review is conducted.

6. Sanctions, PEPs and Prohibited Activity

Sentinel may screen customers and transactions against applicable sanctions, watchlists, and politically exposed person information.

Sentinel does not knowingly facilitate transactions involving sanctioned persons, prohibited activities, or transactions connected to money laundering, terrorism financing, fraud, or other unlawful activity.

Where appropriate, enhanced due diligence or additional verification may be required.

7. Suspicious Activity

Employees and relevant personnel are required to escalate suspected money laundering, terrorist financing, fraud, or other financial crime to the Compliance Officer.

The Compliance Officer is responsible for reviewing escalated activity and determining the appropriate action, including any reporting or regulatory notification required under applicable Nigerian law.

Customers will not be informed where disclosure of a suspicious activity review or report is prohibited by law.

8. Record Retention

9. Compliance Responsibilities

The Compliance Officer is responsible for:

• Overseeing implementation of this policy
• Reviewing escalated suspicious activity
• Coordinating KYC and AML controls
• Maintaining appropriate compliance records
• Ensuring relevant personnel understand their AML obligations
• Reviewing and updating this policy as Sentinel's business and regulatory obligations develop

All Sentinel personnel are expected to comply with this policy and promptly escalate concerns to the Compliance Officer.

10. Policy Review

This policy will be reviewed periodically and updated when necessary to reflect changes in Sentinel's business model, risk profile, technology, applicable Nigerian laws, or regulatory requirements.