AML/CFT/CPF Policy

1. Policy Statement

Dr. Bills Exchange is committed to the highest standards of financial integrity and regulatory excellence. We ensure that our crypto-exchange, virtual card services, and payment platforms are not utilized as conduits for money laundering (ML), terrorism financing (TF), or proliferation financing (PF) of weapons of mass destruction.

Under our guiding principle of "Compliant Innovation," we bridge fiat and digital assets by:

• Implementing sound AML and CFT/CPF policies ensuring our platforms are not used as conduits for money laundering or illicit business financing.
• Implementing policies and guidelines from relevant regulatory bodies to ensure compliance with all domestic and international AML/CFT laws.
• Full compliance with both the letter and spirit of all regulatory requirements, maintaining a high standard of market conduct.
• Conducting all digital asset and virtual card business in accordance with all regulatory policies governing our operating environment.
• Giving full cooperation to law enforcement authorities within the limits of rules governing confidentiality and data protection.
• Maintaining a robust technical compliance framework by enforcing mandatory KYC/KYB identity verification, advanced blockchain monitoring (KYT), and dynamic velocity limits on virtual card transactions.

2. Regulatory Compliance & Partnership Statement

Dr. Bills Exchange is committed to the following standards of governance and regulatory alignment:

• Strategic Regulatory Alignment: The platform operates in strategic partnership with Busha, a pioneer SEC-licensed VASP, ensuring alignment with the SEC Nigeria ARIP and the Investments and Securities Act.
• Collaborative Vigilance: We regularly train staff and academy students to identify suspicious activities and high-risk blockchain interactions.
• Authorized Educational Standard: Dr. Bills Academy maintains an AML/CFT training program that mirrors the latest SEC and NFIU directives, including the Travel Rule and blockchain forensics requirements.
• Regulatory Referral Protocols: Clear internal referral processes ensure all compliance matters are handled with the transparency required for SEC-regulated ecosystems.
• Agile Compliance Adaptation: Dr. Bills Exchange continuously implements internal controls to adapt to the evolving SEC digital asset framework.
• Executive Accountability & Liaison: An Executive Director serves as Executive Compliance Officer and a senior management lead as Chief Compliance Officer (CCO), overseeing all AML/CFT/CPF programs.

3. Role of the Chief Compliance Officer (CCO)

The CCO is the designated officer responsible for ensuring the platform's operations align with SEC regulatory requirements, managing the compliance interface with Busha Digital Limited.

4. Staff Obligations & AML Compliance Mandate

All employees of Dr. Bills Exchange are the primary defence against financial crime. This policy ensures integrity of our partnership with Busha and standing with the SEC is maintained at every level.

5. Regulatory & Legal Framework (VASP Summary)

Dr. Bills Exchange operates in strategic partnership with Busha, an SEC-Licensed VASP. Our compliance architecture is governed by the following apex authorities:

6. ML/TF/PF Risk Assessment Framework

Dr. Bills Exchange adopts a proactive Risk-Based Approach (RBA) to ensure resources are focused on areas of highest vulnerability. Standard KYC alone is considered insufficient; our framework evaluates the inherent risk of every user and transaction before applying calibrated controls.

Risk Identification Pillars

• Customer Risk: Identification of PEPs, users from high-risk jurisdictions, or entities with opaque ownership structures.
• Product & Service Risk: Assessing risks of Virtual Cards (anonymity/velocity) and Cryptocurrency Exchange (traceability/cross-border speed).
• Geography Risk: Monitoring transactions originating from or destined for Grey-listed or Black-listed FATF jurisdictions.
• Channel/Technology Risk: Evaluating risks from non-face-to-face onboarding and anonymity-enhancing technologies (e.g., mixers or privacy coins).

Risk Classification Matrix

Technical Mitigation & Monitoring

• Real-time Blockchain Forensics (KYT): We verify the Transaction (KYT) in addition to the Person (KYC). Any crypto-asset linked to darknet markets, scams, or sanctioned addresses is automatically frozen.
• Virtual Card Velocity Limits: Automated systems flag layering behavior such as multiple small loads and rapid off-ramping — classic indicators of money laundering.
• Travel Rule (FATF R.15): For transfers exceeding regulatory thresholds, originator and beneficiary information is securely transmitted.

Ongoing Risk Re-Assessment

• Daily automated scans of the Sanctions List (OFAC, UN, SEC).
• Quarterly enterprise-wide risk assessments to identify new Crypto Typologies.
• Annual independent audits to ensure our RBA remains commensurate with the scale of operations.

7. Know Your Customer (KYC) & Identity Verification

All customers must undergo identity verification before accessing platform services. Dr. Bills Exchange employs a comprehensive KYC framework aligned with Busha and SEC VASP standards, with enhanced checks applied to higher-risk profiles.

As our regulated partner, Busha has real-time audit access to our KYC logs to ensure we meet the VASP Gold Standard. Any user blacklisted on Busha for suspicious activity is automatically blocked from Dr. Bills Exchange.

8. Tiers of KYC & Transaction Limits

Aligned with Busha & SEC VASP Standards

Dr. Bills Exchange implements a three-tier system that allows for financial inclusion while enforcing strict Value-at-Risk limits.

Critical Partnership Protocol: The "Busha Sync"

• Uniformity: Our Tier 1–3 requirements are identical to Busha's. Users blacklisted on Busha are automatically blocked from Dr. Bills Exchange.
• Audit Readiness: All Tier 2 and Tier 3 KYC documents are stored in encrypted format accessible for Busha Spot Audits to satisfy SEC regulators.
• Cross-Platform Portability: Users who have completed Tier 3 on Busha may be offered Express Onboarding on Dr. Bills Exchange, maintaining a seamless regulated ecosystem.

9. Politically Exposed Persons (PEPs) Policy

Dr. Bills Exchange defines PEPs as individuals entrusted with prominent public functions, including governmental officials, senior executives of state-owned enterprises, directors of international organizations (e.g., UN, AU, ECOWAS), and their immediate family and close business associates (RCAs).

Risk Assessment & Minimization

• Data Governance: A dedicated PEP Register is maintained, with Declassified PEPs (former officials) tracked for 12–24 months after leaving office.
• Transaction Monitoring: PEP accounts are subject to real-time monitoring; unusual velocity or high-risk wallet interactions trigger an immediate STR.
• The Proxy Rule: Close Associates and Immediate Family are treated with the same level of scrutiny as the PEP themselves, and automatically subjected to EDD.

10. Sanctions Compliance & Internal Enforcement

Dr. Bills Exchange maintains a Zero-Tolerance Policy regarding interactions with sanctioned individuals, entities, or jurisdictions. We perform real-time screening against UNSC, OFAC, EU, SEC Nigeria, and NFIU sanctions lists.

Protocol for a Sanctions Match

• Immediate Freeze: The account and all associated crypto/fiat assets are frozen instantly without prior notice to the user.
• Regulatory Notification: A report is filed with the NFIU and the SEC within 24 hours.
• Prohibited Jurisdictions: We do not provide virtual cards or exchange services to residents of FATF-identified High-Risk (Black-listed) countries.

Internal Enforcement & Penalties (Staff)

11. Audit, Monitoring & Policy Review

The Internal Audit/Compliance Team is mandated to conduct objective, periodic reviews to provide assurance to the Board and Busha that our AML/CFT/CPF framework is effective and compliant with SEC, NFIU, and EFCC requirements.

Audit Scope

• KYC/CDD Verification: Testing the accuracy of Tier 1–3 onboarding and the validity of biometric Liveness checks.
• Transaction Monitoring (KYT): Reviewing effectiveness of blockchain forensic tools in flagging Red Flag wallet addresses.
• Reporting Accuracy: Verifying all STRs and CTRs were filed correctly and within the 24-hour regulatory window.
• Staff Training Validation: Ensuring 100% of the team have completed mandatory annual compliance certifications.

Annual Policy Review & Revision

This policy is subject to a mandatory formal review every 12 months, or sooner if triggered by:

• Legislative shifts — new SEC directives or amendments to the Money Laundering Act 2022.
• Partnership requirements — updates to Busha's internal compliance standards.
• Emerging typologies — new FATF or NFIU-identified methods of financial crime targeting virtual assets.
• Operational expansion — launching new product features such as cross-border payment gateways.

12. Board Signatory Page

This AML/CFT/CPF Policy has been reviewed and formally adopted by the Board of Directors of Dr. Bills Exchange. By signing below, the Board affirms its commitment to maintaining a compliant and transparent financial ecosystem.