AML / KYC Policy

1. Our commitment

234 Exchange is committed to preventing money laundering, terrorist financing and other financial crime, and to complying with applicable AML/CFT laws. We conduct our virtual asset activities in partnership with Ideospay Solutions Limited, a FINTRAC-registered Money Services Business, and we align our controls with applicable Nigerian and Canadian requirements.

2. Risk-based approach

We apply a risk-based approach, assessing and mitigating money-laundering and terrorist-financing risk across our customers, products, transactions, geographies and delivery channels, and calibrating our controls accordingly.

3. Customer Due Diligence (KYC)

• Crypto-to-crypto swaps are non-custodial; identity verification is generally not required to swap.
• Cash-out to Naira requires identity verification (KYC) before settlement, including collection and verification of identifying information and documents, tiered to the value and risk of the transaction.
• We may apply Enhanced Due Diligence to higher-risk customers or transactions, including additional verification and source-of-funds checks.
• We may refuse or discontinue service where due diligence cannot be completed satisfactorily.

4. Transaction monitoring and screening

• We screen transactions and, where applicable, the source of funds, including checks against sanctions and prohibited-persons lists and blockchain-analytics risk indicators.
• We monitor for unusual or suspicious activity, structuring, and patterns indicative of financial crime, and may hold, delay or decline transactions pending review.

5. Sanctions and Politically Exposed Persons

We screen against applicable sanctions lists and do not provide Services to sanctioned persons or in sanctioned jurisdictions. We apply appropriate measures to identify and manage Politically Exposed Persons (PEPs).

6. Reporting

Where required, we make reports to the relevant authorities — including the Nigeria Financial Intelligence Unit (NFIU) and, via our partner, to FINTRAC — and we may be legally prohibited from disclosing that a report has been made ("tipping off").

7. Holds, freezes and refusals

Where we identify or suspect financial crime, sanctions exposure or a legal-reporting trigger, we may delay, hold, refuse, freeze or report a transaction or funds. Funds subject to a lawful compliance hold may not be immediately returnable.

8. Record-keeping

We retain customer, verification and transaction records for the periods required by applicable AML law.

9. Governance and training

We maintain internal AML/CFT policies and procedures, designate responsibility for compliance compliance@234exchange.com, and provide relevant training to staff.

10. Prohibited use

You must not use the Services to launder money, finance terrorism, breach sanctions, or transact proceeds of crime. See our Acceptable Use Policy and Terms of Use.

11. Contact

AML/compliance queries: support@234exchange.com (attn: Compliance).