Anti-Money Laundering Policy

1. Introduction and Purpose

Agastronicx Ltd (“Agastronicx”, “Company”, “we”, “us”), registered in Nigeria with Registration Number 9022634, is committed to full compliance with all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations, including the Money Laundering (Prevention and Prohibition) Act 2022 and applicable directives of the Central Bank of Nigeria (CBN).

This policy sets out the controls and procedures Agastronicx maintains to prevent its platform and services from being used for money laundering, terrorism financing, or other financial crimes.

2. Scope

This policy applies to all employees, contractors, partners, and third-party service providers of Agastronicx. It covers all business activities including training enrolments, software service fees, and digital product sales.

3. Know Your Customer (KYC) Requirements

Agastronicx implements appropriate Know Your Customer procedures. When onboarding users, we collect and verify:

• Full legal name
• Email address
• Phone number
• Source of funds (where transaction thresholds warrant)

Where required, Agastronicx may request additional identification documentation including government-issued ID. We reserve the right to suspend accounts pending identity verification.

4. Prohibited Activities

Agastronicx strictly prohibits the use of its platform for:

• Money laundering or the concealment of proceeds of crime
• Financing of terrorism or terrorist organizations
• Structuring payments to avoid reporting thresholds
• Using third-party payment instruments without authorization
• Any activity that violates applicable AML/CTF laws or regulations

5. Payment Controls

All payments on the Agastronicx platform are processed through Flutterwave, a PCI-DSS compliant payment processor regulated by the CBN. Our payment infrastructure incorporates:

• Server-side transaction verification (never relying solely on client-side data)
• Unique payment references for each transaction
• Real-time webhook verification to confirm payment authenticity
• Secure storage of transaction metadata in our Firestore database
• Reconciliation of payment records against processor confirmations

6. Risk Assessment

Agastronicx conducts periodic risk assessments to identify and evaluate AML/CTF risks. Risk factors considered include:

• Customer identity and verification status
• Unusual payment patterns or amounts
• High-risk jurisdictions
• Politically Exposed Persons (PEPs)
• Inconsistencies in provided information

7. Transaction Monitoring

We monitor transactions for suspicious activity, including but not limited to:

• Unusually large or frequent payments inconsistent with stated purpose
• Multiple payment attempts followed by successful payment
• Transactions originating from high-risk jurisdictions
• Refund requests inconsistent with legitimate use

8. Suspicious Activity Reporting

Agastronicx is committed to reporting suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) as required by law. Staff are trained to recognize red flags and escalate concerns through internal channels without alerting the subject of the investigation (tipping-off prohibition).

9. Record Keeping

Agastronicx maintains records of all transactions and customer identification information for a minimum of five (5) years from the date of the transaction or the end of the business relationship, as required by Nigerian AML legislation.

10. Training and Awareness

All relevant personnel at Agastronicx receive training on AML/CTF obligations, their responsibilities, and the recognition and reporting of suspicious activity. Training is reviewed and updated annually or whenever significant regulatory changes occur.

11. Policy Review

This policy is reviewed at least annually or when significant changes occur in applicable legislation. The Board of Directors is responsible for approving this policy and ensuring its implementation.

12. Contact

To report concerns or for questions about this policy: