AML / CFT Framework

AML / CFT policy.

A public summary of Ubuntu Exchange anti-money laundering and counter-financing of terrorism controls, onboarding standards, and reporting posture.

Framework Risk-based AML / CFT
Entity Ubuntu Cygnet Digital Limited
Market Nigeria-focused operations
Coverage Onboarding · Monitoring · Escalation
01

AML / CFT framework

This page provides a public summary of the anti-money laundering and counter-financing of terrorism posture applied to Ubuntu Exchange. It reflects a risk-based control approach intended to reduce misuse of the platform and support lawful, reviewable service operations.

This public summary does not disclose every internal control detail, escalation threshold, or investigative process used by the platform.
02

Policy objective

Ubuntu Exchange applies AML / CFT controls to reduce illicit use, support lawful onboarding and settlement, and align platform operations with applicable legal and risk obligations. These controls shape onboarding, account review, transaction handling, internal escalation, and partner-facing diligence posture.

03

Customer due diligence

Identity verification requirements are calibrated to account type, product access, activity profile, and risk posture. Additional diligence may be required where transaction volume, behavioral signals, jurisdictional exposure, or account structure creates higher review obligations.

Baseline verification

Every account is expected to satisfy the level of onboarding review appropriate to the services requested.

Additional review

Higher-risk use cases may require expanded due diligence before access, settlement, or continued activity is permitted.

04

Screening and monitoring

Accounts and transactions may be screened against internal and external risk signals, including sanctions, watchlist, source-of-funds, and unusual activity indicators. Monitoring intensity may differ by product, settlement corridor, account profile, and the context of the transaction being reviewed.

05

Escalation and reporting

Where activity cannot be satisfactorily understood or supported, access may be restricted while internal review is completed. Escalation and statutory reporting obligations are handled through the platform’s compliance process and may involve additional information requests, delayed execution, or service restriction.

06

Record retention

Onboarding, review, and transaction records are retained in line with compliance, audit, and operational requirements for as long as reasonably required by policy or law. Record handling is intended to support traceability, review, and lawful response obligations.

07

Enhanced review

Higher-risk activity, elevated volumes, unusual structuring, or complex counterpart arrangements may trigger additional internal review before execution or settlement continues. Enhanced review may also apply when activity diverges materially from the profile established during onboarding.

Compliance Desk

Request AML / CFT clarification.

Institutional counterparties, partners, and customers who require further AML posture detail may request additional clarification directly from the compliance desk.