Anti-Money Laundering Policy

Zerne Capital is fully committed to preventing money laundering, terrorist financing, and other financial crimes. We comply with the Money Laundering (Prohibition) Act, the Terrorism (Prevention) Act, CBN AML/CFT regulations, and FATF recommendations.

This policy applies to all employees, directors, agents, contractors, and third-party service providers of Zerne Capital.

• Money Laundering (ML): The process of disguising the origins of money obtained through illegal means.
• Terrorist Financing (TF): The provision or collection of funds with the intention that they be used to carry out terrorist acts.
• Know Your Customer (KYC): The process of verifying the identity of our customers.
• Customer Due Diligence (CDD): The ongoing assessment of customer risk.
• Suspicious Transaction Report (STR): A report filed with the Nigerian Financial Intelligence Unit (NFIU) when suspicious activity is detected.

We verify every customer's identity before providing any financial service. Our KYC process includes:

• Identity Verification: Valid government-issued ID (NIN, driver's licence, passport, voter's card) matched against BVN records.
• Address Verification: Utility bill, tenancy agreement, or bank statement showing the customer's residential address.
• Biometric Verification: Liveness checks and facial matching where required.
• Business Verification (SME): CAC registration, tax ID (TIN), and business bank account verification.

We do not accept anonymous or pseudonymous accounts.

We classify customers into risk categories:

• Low Risk: Salaried employees with stable income, established residence, and clean credit history.
• Medium Risk: Self-employed individuals, informal traders, or first-time borrowers.
• High Risk: Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, or those with complex ownership structures.

Enhanced Due Diligence (EDD) is applied to high-risk customers, including additional documentation, source-of-wealth checks, and more frequent transaction monitoring.

We monitor all transactions for suspicious patterns, including:

• Transactions significantly above the customer's stated income or profile.
• Rapid movement of funds between multiple accounts.
• Structured transactions designed to evade reporting thresholds.
• Transactions involving high-risk jurisdictions or sanctioned entities.
• Unusual repayment behaviour (e.g., lump-sum repayments from third-party accounts).

Automated alerts are generated for review by our Compliance Officer.

We maintain comprehensive records of all KYC documents, transaction histories, and STRs for a minimum of 7 years from the date of the transaction or account closure, in compliance with CBN and NDPR requirements.

Any employee who suspects money laundering or terrorist financing must immediately report it to the Compliance Officer. The Compliance Officer will evaluate the suspicion and, if justified, file a Suspicious Transaction Report (STR) with the Nigerian Financial Intelligence Unit (NFIU) within 24 hours.

It is a criminal offence under Nigerian law to tip off a customer that their transaction has been reported as suspicious.

We screen all customers and counterparties against international sanctions lists (UN, OFAC, EU) and domestic Nigerian sanctions lists. Politically Exposed Persons (PEPs) and their close associates are subject to Enhanced Due Diligence.

All employees receive AML/CFT training upon joining and annually thereafter. Training covers: recognising suspicious activity, KYC procedures, record-keeping requirements, and the legal obligations for reporting.

Zerne Capital has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for:

• Overseeing the implementation of this AML policy.
• Receiving and assessing internal suspicious activity reports.
• Filing STRs with the NFIU.
• Liaising with regulators and law enforcement.
• Ensuring staff are adequately trained.

Contact: compliance@zernegroup.com

This AML Policy is reviewed at least annually or whenever there is a significant change in legislation, regulation, or business operations.

For AML-related enquiries, contact our Compliance Officer at compliance@zernegroup.com.