Anti-Money Laundering and Counter-Financing of Terrorism Statement

Our commitment

Technest Limited ("Technest", "we", "us", or "our") is committed to preventing money laundering, terrorism financing, the financing of the proliferation of weapons of mass destruction, fraud, sanctions evasion, and other financial crime. As a Nigerian fintech company licensed by the Central Bank of Nigeria as an International Money Transfer Operator (IMTO), we hold ourselves to the standards expected of regulated financial institutions in Nigeria. This Statement sets out the principles that guide our anti-money-laundering ("AML") and counter-financing-of-terrorism ("CFT") posture.

Regulatory framework

We operate within the framework established by Nigerian law and by the international standards that inform it, including:

• the Money Laundering (Prevention and Prohibition) Act and related amendments;
• the Terrorism (Prevention and Prohibition) Act and related amendments;
• the Central Bank of Nigeria's AML/CFT/CPF Regulations and related circulars applicable to financial institutions and to International Money Transfer Operators;
• the Nigerian Financial Intelligence Unit Act and related guidance issued by the Nigerian Financial Intelligence Unit (NFIU);
• the Economic and Financial Crimes Commission (Establishment) Act and related instruments;
• the Nigeria Data Protection Act 2023 (NDPA 2023) and the Nigeria Data Protection Regulation 2019 (NDPR), insofar as they apply to the personal data we process in connection with our AML/CFT programme;
• the recommendations of the Financial Action Task Force (FATF), as reflected in Nigerian law and supervisory expectations. We are supervised by the Central Bank of Nigeria and we cooperate with the NFIU, the Economic and Financial Crimes Commission (EFCC), the Nigeria Data Protection Commission, and other competent Nigerian authorities. We also cooperate with international partners and regulators where this is consistent with Nigerian law.

Customer due diligence

We carry out customer due diligence ("CDD") on every customer in line with applicable law and our regulatory obligations. The depth of our CDD reflects the risk associated with the customer, the product, the geography, and the channel.

Consistent with the Central Bank of Nigeria's tiered "know-your-customer" framework, the information and documentation we collect typically includes the customer's full name, date of birth, residential or business address, identification documents, Bank Verification Number (BVN) where appropriate, Tax Identification Number where appropriate, and — for business customers — information about the entity, its directors, and its beneficial owners. Higher tiers, which support higher transaction limits, require correspondingly more information. We may carry out enhanced due diligence on customers, transactions, or relationships that present higher risk, including politically exposed persons, customers in higher-risk jurisdictions, and customers whose activities or sources of funds require additional verification. We periodically review the information we hold about our customers to keep it current and accurate. We may request additional information or documentation at any point in the relationship where this is necessary to satisfy our regulatory obligations or to assess risk.

We do not provide services to anonymous customers, shell companies that lack a genuine business purpose, or customers who fail to satisfy our customer-due-diligence requirements.

Sanctions screening

We screen customers, transactions, and counterparties against the sanctions and prohibited-persons lists that apply to us. These include sanctions issued by the Government of the Federal Republic of Nigeria, the United Nations Security Council, and other sanctions regimes that apply to our operations or to the operations of our banking and payment partners (for example, sanctions administered by OFAC, HMT/OFSI, and the European Union). Where a screening hit cannot be cleared, we may refuse, delay, or reject a transaction, freeze funds where required by law, and report to the appropriate authorities.

Transaction monitoring

We monitor transactions executed through our Services to identify activity that may indicate money laundering, terrorism financing, fraud, sanctions evasion, or other financial crime. Monitoring is risk-based and uses a combination of rules-based and analytical approaches that we review and refine over time.

Where we identify activity that warrants investigation, our compliance team reviews it and takes the action that is appropriate in the circumstances. This may include requesting additional information from the customer, restricting access to the account, refusing or reversing a transaction, closing the account, and reporting to the NFIU or other competent authority.

Reporting suspicious activity

We file Suspicious Transaction Reports and other reports with the NFIU and other competent authorities where required by law. We do not tip off customers or third parties about the existence or contents of these reports, and applicable law prohibits us from doing so.

If you suspect that the Services are being used to commit fraud, money laundering, terrorism financing, or other financial crime, please contact us at compliance@the-technest.com. We will treat your report confidentially to the extent permitted by law and will investigate and respond appropriately. You can also report concerns directly to the relevant Nigerian authority.

Record-keeping

We retain customer-identification information, transaction records, and records relating to our AML/CFT activities for the periods required by Nigerian law. These records are available to regulators and law-enforcement authorities on lawful request.

Governance, training, and culture

Technest operates a documented AML/CFT compliance programme overseen by a designated compliance function reporting to senior management and the board, in line with the requirements applicable to CBN-licensed IMTOs. We train our staff on AML/CFT obligations on induction and at regular intervals afterwards. We undertake periodic reviews of our programme — including, where appropriate, independent reviews — to ensure it remains effective and aligned with current law, regulatory expectations, and the evolving risk environment.

Cooperation with regulators and law enforcement

We cooperate fully with the Central Bank of Nigeria, the NFIU, the EFCC, the Nigeria Data Protection Commission, and other competent authorities. We respond to lawful requests for information and we disclose information about customers, accounts, and transactions where we are required to do so by law or where disclosure is otherwise permitted by applicable law.

Changes to this Statement

We may update this Statement from time to time to reflect changes in our compliance posture, in our Services, or in applicable law. When we make material changes, we will publish the updated Statement on our website. The "lastReviewed" and "effective" dates at the top of this document indicate when it was last updated.

Contact

For questions about this Statement or about our AML/CFT posture, please contact us at:

Technest Limited 8 Providence Street, Lekki Phase 1 Lagos State, Nigeria Email: compliance@the-technest.com