Anti-Money Laundering (AML) Policy

Effective Date: April 7, 2026

1. Introduction

Jadegate Tech Limited ("Jadegate", "we", "our", or "us") is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes. We recognize our responsibility in safeguarding the financial system and ensuring that our platform is not used for illegal activities.

Jadegate implements strict Anti-Money Laundering (AML) policies, procedures, and controls in compliance with applicable laws and regulations in the Federal Republic of Nigeria, including guidelines issued by the Central Bank of Nigeria (CBN) and the Nigerian Financial Intelligence Unit (NFIU).

2. Purpose of This Policy

The purpose of this AML Policy is to:

  • Prevent the use of Jadegate for money laundering or terrorist financing
  • Detect and report suspicious activities
  • Ensure compliance with all applicable AML laws and regulations
  • Protect Jadegate from legal, regulatory, and reputational risks
  • Maintain trust with users, partners, and financial institutions

3. Scope

This policy applies to:

  • All Jadegate products and services
  • All employees, contractors, and agents
  • All users, customers, and business partners
  • All transactions processed through the platform, including:
    • Wallet funding
    • Currency conversion (NGN to RMB)
    • Bill payments
    • China marketplace transactions

4. Definitions

Money Laundering

The process of disguising the origin of illegally obtained funds to make them appear legitimate.

Terrorist Financing

The use of funds (legal or illegal) to support terrorist activities.

Customer Due Diligence (CDD)

The process of identifying and verifying customers to assess risk and prevent financial crime.

Enhanced Due Diligence (EDD)

Additional verification procedures applied to high-risk customers or transactions.

5. Customer Due Diligence (CDD)

Jadegate conducts comprehensive Customer Due Diligence at onboarding and throughout the customer lifecycle.

Identification and Verification

We collect and verify:

  • Full name
  • Email address
  • Phone number
  • BVN (Bank Verification Number)
  • NIN (National Identification Number)
  • Government-issued identification where required

Risk Assessment

Each user is assessed based on:

  • Transaction behavior
  • Geographic location
  • Source of funds
  • Account activity

Enhanced Due Diligence (EDD)

EDD is applied to:

  • High-value transactions
  • High-risk users
  • Suspicious activity patterns
  • Cross-border transactions involving elevated risk

6. Transaction Monitoring

Jadegate continuously monitors transactions to detect suspicious activity.

Examples of monitored activities include:

  • Unusual transaction volumes or frequency
  • Transactions inconsistent with user profile
  • Rapid movement of funds (layering)
  • Multiple accounts linked to a single user
  • High-risk geographic transactions
  • Suspicious China marketplace transactions

We use automated systems and manual review processes to identify such activities.

7. Record Keeping

Jadegate maintains records of:

  • Customer identification data
  • Transaction history
  • Communications

These records are retained for a minimum period as required by applicable laws and regulations and may be provided to authorities upon request.

8. Reporting Obligations

Jadegate complies with all statutory reporting obligations.

This includes:

  • Reporting suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU)
  • Filing Suspicious Transaction Reports (STRs) where required
  • Cooperating with regulatory authorities

9. Restricted and Prohibited Activities

Users are prohibited from using Jadegate for:

  • Money laundering
  • Terrorist financing
  • Fraudulent activities
  • Illegal cross-border transfers
  • Trade-based money laundering via the marketplace

Any such activity may result in:

  • Immediate account suspension
  • Reporting to authorities
  • Legal action

10. Internal Controls and Compliance

Jadegate implements strong internal controls, including:

  • Appointment of an AML Compliance Officer
  • Regular monitoring and auditing
  • Segregation of duties
  • Risk-based compliance procedures

11. Employee Training and Awareness

All employees receive:

  • Regular AML training
  • Updates on regulatory requirements
  • Awareness programs on fraud and financial crime risks

12. Cooperation with Authorities

Jadegate fully cooperates with regulatory bodies and law enforcement agencies in investigating financial crimes.

13. Policy Review

This AML Policy is reviewed regularly to ensure:

  • Compliance with evolving regulations
  • Adaptation to new risks
  • Continuous improvement of controls

14. Marketplace Risk Management

For China marketplace services:

  • Transactions are monitored for trade-based money laundering risks
  • Suspicious procurement or sourcing requests may be flagged or declined
  • Users may be required to provide additional documentation

15. Conclusion

Jadegate is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. Our AML framework is designed to protect our users, partners, and the financial ecosystem.

16. Contact Information

For AML-related inquiries or to report suspicious activity:

Jadegate Tech Limited

Ibadan, Oyo State, Nigeria

Email: admin@jadegatetech.com