Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Introduction

Airpero LTD ("Airpero", "we", "our", or "us") is committed to preventing money laundering, terrorist financing, fraud, sanctions violations, and other forms of financial crime.

This Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy explains how we identify our customers, monitor transactions, and comply with applicable anti-money laundering, counter-terrorist financing, sanctions, and financial crime prevention laws.

This Policy applies to all individuals using Airpero's services, including digital wallets, money transfers, foreign exchange, virtual and physical cards, bill payments, and any other financial services made available through Airpero or its regulated partners.

2. Purpose

The purpose of this Policy is to:

• Verify the identity of our customers.
• Prevent fraud and financial crime.
• Detect suspicious transactions and activities.
• Comply with applicable AML, CTF, and sanctions regulations.
• Protect our customers, partners, and financial system.
• Meet the compliance requirements of our licensed banking and payment partners.

3. Customer Identification (KYC)

Before providing certain services, Airpero may require you to complete identity verification.

Depending on the products or services you use, we may request:

• Full legal name.
• Date of birth.
• Residential address.
• Email address.
• Mobile phone number.
• Government-issued photo identification.
• Passport.
• National Identity Card.
• Driver's Licence.
• BVN or NIN (where applicable).
• Proof of address.
• Selfie or biometric verification.
• Source of funds documentation.
• Additional documents required for enhanced verification.

Failure to provide requested information may result in delays, service restrictions, or account closure.

4. Ongoing Customer Due Diligence

Airpero performs ongoing customer due diligence throughout the relationship.

We may periodically request updated information, including:

• Updated identification documents.
• Proof of address.
• Employment or occupation details.
• Source of funds information.
• Additional information relating to specific transactions.

Keeping your information current helps us comply with regulatory obligations and maintain account security.

5. Transaction Monitoring

Airpero continuously monitors transactions to identify unusual or suspicious activity.

Monitoring may include:

• Transaction size and frequency.
• Geographic risk.
• Transaction patterns.
• Velocity of transfers.
• High-risk payment recipients.
• Card usage behaviour.
• Foreign exchange activity.
• Wallet funding sources.
• Bill payment activity.
• Other risk indicators.

Transactions that appear unusual or inconsistent with your account profile may be reviewed before processing.

6. Sanctions Screening

Airpero screens customers and transactions against applicable sanctions lists and restricted party databases.

This may include screening against lists maintained by relevant national or international authorities.

If a transaction or customer matches a sanctions list or presents an unacceptable compliance risk, Airpero may:

• Decline the transaction.
• Delay processing.
• Restrict account access.
• Suspend or terminate services.
• Report the matter to the appropriate authorities where required by law.

7. Politically Exposed Persons (PEPs)

Airpero may identify customers who are Politically Exposed Persons (PEPs), their family members, or close associates.

Where required, additional due diligence measures may be applied before or during the customer relationship.

8. Source of Funds and Source of Wealth

For certain transactions or higher-risk activities, Airpero may request evidence of the origin of your funds.

Examples of acceptable documentation include:

• Salary slips.
• Employment letters.
• Bank statements.
• Business income records.
• Investment statements.
• Sale agreements.
• Inheritance documentation.
• Other documents demonstrating the lawful origin of funds.

Failure to provide satisfactory documentation may result in transaction delays or restrictions.

9. Suspicious Activity

Airpero reserves the right to investigate any activity that appears suspicious or inconsistent with this Policy.

Examples include:

• Unusual transaction volumes.
• Rapid movement of funds.
• Transactions inconsistent with your expected account activity.
• Use of false or misleading information.
• Attempts to evade verification requirements.
• Transactions involving high-risk jurisdictions.
• Activity suggesting fraud or identity theft.
• Structuring transactions to avoid reporting or monitoring requirements.

Where required by law, Airpero may report suspicious activity to the appropriate regulatory or law enforcement authorities.

10. Prohibited Activities

Customers must not use Airpero for:

• Money laundering.
• Terrorist financing.
• Fraud.
• Identity theft.
• Sanctions evasion.
• Tax evasion.
• Bribery or corruption.
• Human trafficking.
• Illegal gambling.
• Illegal goods or services.
• Operating an unauthorized money service business.
• Transactions involving sanctioned individuals or entities.
• Any activity prohibited by our Acceptable Use Policy or applicable law.

Violation of this Policy may result in account suspension or termination.

11. Record Retention

Airpero retains customer identification records, transaction information, and compliance documentation for the period required by applicable law and regulatory obligations.

These records help support fraud prevention, regulatory compliance, dispute resolution, and lawful investigations.

12. Customer Responsibilities

As an Airpero customer, you agree to:

• Provide accurate and truthful information.
• Keep your account information up to date.
• Cooperate with verification requests.
• Use Airpero only for lawful purposes.
• Promptly respond to requests for additional information.
• Notify Airpero if your identification details change.

Failure to cooperate with compliance requests may affect your ability to use our services.

13. Enforcement

Where permitted by law, Airpero may take one or more of the following actions if we identify potential financial crime risks:

• Request additional information or documentation.
• Delay or decline transactions.
• Restrict certain services.
• Suspend or freeze your account where legally permitted.
• Close your account.
• Report suspicious activity to the relevant authorities.
• Share information with licensed banking or payment partners where necessary to meet legal and regulatory obligations.

These actions may be taken without prior notice where required by law or to protect the integrity of our platform.

14. Changes to This Policy

Airpero may update this Policy from time to time to reflect changes in:

• Applicable laws and regulations.
• Regulatory guidance.
• Industry best practices.
• Products and services.
• Risk management procedures.

The latest version will be available on our website and mobile application.

Continued use of Airpero services after changes become effective constitutes acceptance of the revised Policy.

15. Contact Us

If you have questions about this Policy or our compliance procedures, please contact:

Airpero LTD

Email: support@airpero.com

Website: https://www.airpero.com

Regulatory Notice

Airpero LTD is a financial technology company and is not a bank. Banking, payment, card issuing, foreign exchange, money transfer, and related financial services are provided through licensed financial institutions and regulated payment partners in the jurisdictions where such services are offered.

Airpero maintains a risk-based AML and KYC compliance program and works with its regulated partners to meet applicable anti-money laundering, counter-terrorist financing, sanctions, and financial crime prevention obligations.