Anti-Money Laundry Policy

Anti-Money Laundering and Combating the Financing of Terrorism Policy (AML/CFT Policy)

Last updated: 26 October 2026

1. Purpose and scope

1.1 This Policy sets out how OwoDaily Limited (RC 2009981) ("OwoDaily", "the Company") prevents its platform, owodaily.com, from being used to launder the proceeds of crime or to finance terrorism, and how it meets its obligations under the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, the Economic and Financial Crimes Commission (Establishment) Act 2004, the Cybercrimes (Prohibition, Prevention, etc.) Act 2015 (as amended), the Advance Fee Fraud and Other Fraud Related Offences Act 2006 and any regulations, guidelines or directives made under them.

1.2 OwoDaily operates a rewards marketplace. It takes payment from members, campaign owners and partners for memberships, courses and campaign services, and it pays members for approved work, bounties, commissions and cashback. OwoDaily is not a bank, a mobile money operator or a licensed payment service provider, and it does not hold customer deposits. Its money-laundering risk comes from three places: a user paying in funds of criminal origin to post campaigns or buy credits; a user receiving payouts through an account that is not their own or under a false identity; and a user abusing the platform's payment flows to move value between people. This Policy is proportionate to those risks.

1.3 This Policy applies to all directors, employees, contractors and agents of OwoDaily, and its customer-facing requirements apply to every user of the platform through clause 12 of the Terms of Use.

1.4 Regulatory status. As at the date above, OwoDaily has not been designated a "financial institution" or a "designated non-financial business and profession" under the Money Laundering (Prevention and Prohibition) Act 2022 and is not registered with the Special Control Unit against Money Laundering (SCUML). The Compliance Officer must review this status annually with the Company's lawyer and, if OwoDaily becomes a designated business or is directed to register, must register with SCUML within the statutory period and apply the full reporting regime in section 7. Until then, OwoDaily applies this Policy as a matter of good practice and reports suspicious activity to law enforcement under section 7.3.

2. Definitions

Money laundering means concealing, converting, transferring, removing, acquiring, using or possessing property that is, or represents, the proceeds of an unlawful act, or helping anyone to do so.

Terrorism financing means providing, collecting or making available funds or property, directly or indirectly, with the intention or knowledge that they will be used for an act of terrorism, by a terrorist or by a terrorist organisation, whether the funds are of lawful or unlawful origin.

Customer in this Policy means any user of the platform, and includes members, campaign owners, creators, affiliates, partners and gift card buyers.

Compliance Officer means the person designated under section 5.

Suspicious activity means any transaction, pattern or behaviour that gives reasonable grounds to suspect money laundering, terrorism financing, fraud or another crime.

Politically exposed person (PEP) means a person who holds or has held a prominent public function in Nigeria or elsewhere, their immediate family members and close associates.

3. Customer due diligence (know your customer)

3.1 Everyone. Before an account is activated, OwoDaily collects the user's full name, email address, phone number, date of birth, country and state, and requires confirmation that the user is 18 or older. Before the first payout, the user must register a bank account (or, outside Nigeria, a PayPal account) in their own name; the account name is verified against the bank record through a licensed verification provider and locked once verified. Payouts are never made to third-party accounts.

3.2 Identity documents. A government-issued identity document is required where the Company needs to verify age or identity, where a user asks to change a locked email address or verified bank name, where a payout is held under section 6, or where a payment partner or the law requires it. Documents are checked for authenticity and consistency with the account details, stored encrypted, and deleted within 30 days of verification unless the law requires longer retention.

3.3 Enhanced due diligence is applied before any of the following relationships is accepted and is refreshed at least annually:

(a) Partners, including brands listing deals with cashback, agencies posting campaigns for clients and sellers of digital products: certificate of incorporation or business name registration verified with the Corporate Affairs Commission, the identity of at least one director or proprietor and of any beneficial owner holding 25% or more, the nature of the business, and the source of campaign funding where a single funding or the funding in any month exceeds ₦[2,000,000]; (b) any customer whose funding of campaigns or credits exceeds ₦[5,000,000] in any 12-month period; (c) any customer identified as a PEP; (d) any customer paying from, or receiving payouts to, an account outside Nigeria; (e) any customer flagged as high risk under section 4.

3.4 Refusal. OwoDaily will not open or keep an account, accept a campaign funding or make a payout where identity cannot be satisfactorily established, where the customer refuses to provide requested information, or where the Compliance Officer directs that the relationship be declined.

3.5 Ongoing monitoring. Customer information is kept current. Users are prompted to confirm their details when they change bank accounts, change plans or after any period of 24 months without verification. Transaction monitoring under section 6 runs continuously.

4. High-risk customers and activities

The following are treated as high risk and require enhanced due diligence and Compliance Officer approval before the relationship continues:

(a) a person who refuses to comply with identity or information requests; (b) an entity whose ownership or control cannot be determined; (c) a person about whom there is information indicating possible involvement in crime, including appearance on any sanctions or terrorism list published by the Nigerian Sanctions Committee, the United Nations Security Council or another list the Company screens against; (d) a business whose activity or source of funds cannot reasonably be verified; (e) a customer that is itself required to register with SCUML (for example a casino, real estate agency, dealer in luxury goods or jewellery) and cannot show that registration; (f) PEPs, their family members and close associates; (g) cross-border payments and payouts; (h) customers whose campaign funding, credits purchases or payouts are inconsistent with their stated business or membership type; (i) any attempt to use the platform to move value from one user to another rather than to buy or deliver a genuine service.

5. Compliance Officer

5.1 The Board designates a Compliance Officer of appropriate seniority, and notifies the Board of any change. The Compliance Officer:

(a) owns this Policy and the AML/CFT programme, including the procedures, checklists and thresholds that implement it; (b) approves high-risk relationships and enhanced due diligence files; (c) receives internal reports of suspicious activity, investigates them and decides whether an external report is required; (d) makes external reports and acts as the point of contact for the Economic and Financial Crimes Commission, the Nigerian Financial Intelligence Unit, SCUML (if registered), the Nigeria Police Force and any other competent authority; (e) keeps the register of internal and external reports and of all held, declined and reversed transactions; (f) arranges staff training under section 8; (g) reviews this Policy annually, and sooner if the law changes, and reports to the Board at least once a year on the programme's operation.

5.2 The Compliance Officer can be contacted at [email protected] with the subject "Compliance". The Compliance Officer may also serve as Data Protection Officer provided the Board is satisfied there is no conflict.

6. Transaction monitoring, holds and reversals

6.1 OwoDaily's systems and review team monitor for, among other things: multiple accounts linked by device, bank account, phone or address; payout requests to accounts whose name does not match; sudden large campaign funding from a new or dormant account; campaigns whose structure suggests the purpose is to pass value to specific members rather than to buy genuine work; funding split into amounts just below a review threshold; repeated refunds or chargebacks; and payment from a card or account in a name other than the customer's.

6.2 Where a transaction or pattern is flagged, the Company may hold the payout or decline the transaction while checks are made, request documents under section 3.2, and reverse earnings obtained through a breach of the Terms of Use. The customer is told that a review is in progress, but not the content of any suspicion report.

6.3 Tipping off. No employee may tell a customer or any other person that a suspicious activity report has been made or is being considered.

7. Reporting suspicious activity

7.1 Internal reports. Every employee, contractor and agent must report suspected money laundering, terrorism financing or fraud to the Compliance Officer immediately, using the internal report form, which records: the person reporting, the date, the customer and accounts concerned, the transactions concerned, what is suspected and why, and any involvement of OwoDaily staff or systems. Reporting in good faith is protected; no one will be penalised for a report that turns out to be unfounded.

7.2 Assessment. The Compliance Officer may make reasonable enquiries within the Company, review the customer's file and transactions, and decide within 5 business days whether to file an external report, to hold or close the account, or to take no further action, recording the reasons in each case.

7.3 External reports. Where there are reasonable grounds to suspect a crime, the Compliance Officer reports to the Economic and Financial Crimes Commission or the Nigeria Police Force, and, if OwoDaily is registered with SCUML, files a suspicious transaction report with the Nigerian Financial Intelligence Unit through SCUML within the period the law prescribes (currently 24 hours of the suspicion for a suspicious transaction). The Company cooperates fully with lawful requests from competent authorities and preserves relevant records on request.

7.4 Terrorism. Any match against a published terrorism or sanctions list is reported immediately to the Compliance Officer, the transaction is frozen, and the Compliance Officer reports to the competent authority without delay as the Terrorism (Prevention and Prohibition) Act 2022 requires.

8. Training

8.1 All employees and contractors complete AML/CFT training within 30 days of joining and at least once a year after that. Customer-facing, payments and review staff receive additional training on the red flags in section 6.

8.2 Training covers the applicable laws, this Policy and its procedures, how to recognise and report suspicious activity, the tipping-off prohibition, and current typologies, including those specific to rewards and affiliate platforms. Training may be delivered by external facilitators or in-house sessions run by the Compliance Officer, and attendance is recorded.

9. Record keeping

9.1 The Company keeps, for at least five years after the end of the relationship or the date of the transaction, whichever is later: customer identification and verification records; transaction records sufficient to reconstruct each payment and payout; internal and external suspicious activity reports and the Compliance Officer's decisions; training records; and copies of this Policy and each earlier version.

9.2 Records are kept in a form that can be produced promptly to a competent authority, and are handled in accordance with the Company's Privacy Policy and the Nigeria Data Protection Act 2023. Personal data retained under this section is retained on the lawful basis of legal obligation and legitimate interest in preventing crime.

10. Sanctions for breach

A breach of this Policy by an employee, contractor or agent is a disciplinary matter and may lead to dismissal or termination of contract, and the Company may refer the matter to law enforcement. A breach by a customer is a breach of the Terms of Use and leads to the measures in clause 10 of those Terms, including closure of the account and withholding of balances earned through the breach.

11. Review and approval

The Compliance Officer reviews this Policy at least annually, and whenever new AML/CFT laws, regulations or guidance are issued, and submits any amendment to the Board. The Board of Directors is responsible for approving this Policy and all amendments to it.