Anti-Money Laundering Policy

Dag Global Limited operates Dagpay in strict adherence to the regulations of the Federal Republic of Nigeria, including:

• Money Laundering (Prevention and Prohibition) Act, 2022.

• Terrorism (Prevention and Prohibition) Act, 2022.

• Central Bank of Nigeria (CBN) Anti-Money Laundering, Combating the Financing of Terrorism and Countering Proliferation Financing (AML/CFT/CPF) regulations.

• Directives issued by the Nigerian Financial Intelligence Unit (NFIU) and the Economic and Financial Crimes Commission (EFCC).

• KYC Verification: We enforce strict identity checks under a tiered KYC framework before allowing wallet withdrawals, high-value deposits, or transfers.

• Sanctions Watchlists: All user details are automatically screened against local and international sanctions databases, including the United Nations Security Council (UNSC) lists, domestic EFCC lists, and the US Office of Foreign Assets Control (OFAC) list.

• Politically Exposed Persons (PEPs): We conduct enhanced due diligence on PEPs, requiring additional verification checks and closer monitoring of their transaction velocities.

Our risk-compliance engine monitors transactions in real-time. The system automatically flags and restricts accounts that exhibit suspicious transaction behavior, including:

• Rapid sequential wallet fundings from multiple different bank accounts.

• Structuring transactions (splitting high amounts into multiple smaller values to bypass tier limits).

• Immediate full wallet withdrawals or transfers following a bulk bank funding (pass-through behavior).

• Out-of-pattern high-volume purchases inconsistent with user profile or tier.

• Suspicious Transaction Reports (STRs): When our compliance system flags a transaction as suspicious, the transaction is put on hold. If the user fails to provide legitimate source-of-funds documentation, we are legally mandated to file an STR with the NFIU.

• Tipping Off Prohibition: Under Nigerian AML laws, we are strictly prohibited from informing or tipping off the customer that their account has been flagged or that a report has been sent to regulatory authorities.

We conduct regular compliance audits to verify the effectiveness of our transaction checking systems and staff training programs.

For regulatory inquiries, compliance audits, or law enforcement requests, please contact our Compliance Officer directly at compliance@dagpay.co.