AML/CFT Policy

KoinKoin Global Network Ltd · Version 3.0 · June 2026

Regulatory Status
KoinKoin operates under CBN AML/CFT/CPF VASP Supervision Pilot (ref: CMD/FCS/PR/VAS/001/2026) in Nigeria and SEC Ghana VASP Sandbox Licence (Act 1154, Cohort 1) in Ghana.

Customer Due Diligence (CDD)

All customers must complete identity verification before trading. We apply Standard CDD for retail customers and Enhanced Due Diligence (EDD) for high-risk customers, PEPs, and those from high-risk jurisdictions.

Know Your Customer (KYC)

KYC is performed by our partner Sumsub. Required documents: government-issued photo ID (passport, national ID, or driver's licence) and proof of address for Level 2 verification. Liveness checks are mandatory.

Transaction Monitoring

We monitor all transactions in real-time using automated systems. Suspicious transactions are reviewed by our compliance team and reported to the relevant Financial Intelligence Unit (FIU) where required.

Sanctions Screening

All customers and transactions are screened against OFAC, UN, EU, and local sanctions lists. We do not serve residents of sanctioned jurisdictions. Screening is performed at onboarding and on an ongoing basis.

Suspicious Activity Reporting

We file Suspicious Activity Reports (SARs) with the Nigerian Financial Intelligence Unit (NFIU) and the Financial Intelligence Centre (FIC) Ghana as required. Staff are trained to identify and report suspicious activity.

Record Keeping

We retain all customer records, transaction records, and compliance documentation for a minimum of 5 years as required by the Money Laundering (Prevention and Prohibition) Act 2022 (Nigeria) and AMLA 2008 (Ghana).

Compliance Officer

Our Compliance Manager is responsible for day-to-day AML/CFT compliance. Contact: compliance@koinkoin.com