Anti-Money Laundering (AML) & Counter-Financing of Terrorism (CFT) Policy

Last Updated: June 8, 2026

1. Statement of Regulatory Commitment

Ojahmi limited ("Ojahmi", "OjahmiPay") is committed to the highest standards of financial integrity, transparency, and regulatory compliance. We maintain a zero-tolerance policy regarding the use of our software infrastructure and payment rails for financial crimes, money laundering, tax evasion, or the financing of terrorist activities.

This policy details the mandatory risk-management controls, transaction monitoring frameworks, and reporting protocols enforced across all Ojahmi storefronts to ensure compliance with relevant regional legislations, including but not limited to:

• The Money Laundering (Prevention and Prohibition) Act (Nigeria)

• The Proceeds of Crime Act (South Africa)

• The Anti-Money Laundering Act (Ghana)

• The Proceeds of Crime and Anti-Money Laundering Act (Kenya)

• Recommendations set by the Financial Action Task Force (FATF).

2. Risk-Based Merchant Profiling & Verification

OjahmiPay does not allow anonymous or unverified financial processing. We utilize a strict Risk-Based Approach (RBA) to evaluate every merchant account during onboarding and throughout the lifecycle of their digital storefront.

2.1 Sanctions & Watchlist Screening

Before an OjahmiPay ledger is activated for payouts, the merchant's personal identity, corporate executives, beneficial owners, and corporate entities are automatically screened against international and regional sanction vectors, including:

• The United Nations Security Council Sanctions List (UNSC)

• The Office of Foreign Assets Control List (OFAC)

• Local domestic watchlists issued by regional central banks and state security apparatuses.

Any match discovered during this screening phase results in immediate account rejection, permanent infrastructure blacklisting, and a formal freeze on all associated funds pending regulatory review.

2.2 Ultimate Beneficial Ownership (UBO)

For corporate entities registering a storefront, OjahmiPay requires the clear identification of all Ultimate Beneficial Owners holding 10% or more of the company’s shares or voting rights. You agree to provide clear documentation outlining your corporate structure upon request.

3. Transaction Monitoring & Anomaly Detection

Ojahmi's infrastructure deploys automated backend algorithms that analyze all incoming store transactions, payment frequencies, velocity trends, and withdrawal histories in real time.

3.1 Red Flag Indicators

Our security systems are configured to immediately flag, pause, and review transactions or merchant profiles that exhibit high-risk anomalies, including:

• Rapid Velocity Spikes: A newly created storefront experiencing a massive, uncharacteristic surge in high-value card payments within minutes of setup without prior historical scaling.

• Structuring (Smurfing): Intentionally breaking down large transactional amounts into multiple smaller payments to systematically stay underneath standard local cash transaction reporting limits.

• Cross-Border Mismatches: A merchant registered in one country processing high-volume transactions originating entirely from cards issued in completely unrelated international jurisdictions without logical logistical links.

• High Transaction Failures: A high volume of rapid, sequential card processing attempts utilizing different card numbers on a single storefront (indicative of card testing or automated fraud).

4. Account Suspensions & The "Right to Freeze"

When an AML red flag is triggered, Ojahmi reserves the absolute, unilateral right to place an administrative hold on the affected storefront and its OjahmiPay wallet balance.

• Investigation Window: Suspended accounts will undergo an internal forensic audit lasting up to fourteen (14) business days, during which the merchant must provide verifiable invoices, proof of physical inventory, delivery dispatch logs, and clear confirmation of order fulfillments.

• Fund Retention: If the merchant fails to provide clear, legitimate commercial evidence for the flagged transactions, or if fraud is confirmed, OjahmiPay will permanently freeze the funds and route them to our partner settlement banks' designated indemnity accounts for lawful repatriation to the rightful cardholders or state authorities.

5. Suspicious Transaction Reporting (STR) & "Anti-Tipping Off"

In accordance with international statutory financial codes, Ojahmi and its gateway partners are legally mandated to file Suspicious Transaction Reports (STRs) or Activity Reports (SARs) with local financial intelligence units (e.g., the Nigerian Financial Intelligence Unit [NFIU]) if we suspect or have reasonable grounds to believe that funds stem from illegal origins.

5.1 The Anti-Tipping Off Rule

Under strict financial regulations, Ojahmi is prohibited from notifying, warning, or hinting to a merchant that their account is being audited, investigated, or reported for money laundering or suspicious activity. Any communication from our support team during an AML hold will be restricted strictly to operational data requests to remain fully compliant with non-disclosure legislation.

6. Employee & Infrastructure Protection

Ojahmi routinely audits its system architecture, updates its transaction tracking rules, and trains its platform risk teams to adapt to evolving global financial crime tactics. Any attempt by a merchant to manipulate, reverse-engineer, exploit, or bypass our automated AML monitoring boundaries via code scripts, API injections, or dummy storefronts will result in immediate criminal prosecution.

7. Contact

Report fraud to fraud@ojahmi.com