policy

AML/CFT Policy

Effective date: 31 March 2026

UseMoon maintains a risk-based AML/CFT program aligned with Central Bank of Nigeria (CBN) AML/CFT Guidelines, including robust KYC/CDD, transaction monitoring, and suspicious activity reporting.

1. Purpose and Scope

  • Prevent UseMoon from being used to launder proceeds of crime, finance terrorism, or evade sanctions.
  • Applies to all employees, contractors, agents, partners, and customers.

2. Customer Due Diligence (CDD)

  • Standard CDD: Verify identity, address, and beneficial ownership before onboarding.
  • Enhanced Due Diligence for high-risk customers (PEPs, cross-border remitters, unusual patterns).
  • Ongoing CDD: Periodic re-verification based on risk.

3. Transaction Monitoring

  • Deploy automated monitoring to detect suspicious patterns, thresholds, and typologies.
  • Maintain audit trails and tune rules and machine learning models.

4. Suspicious Activity Reporting

  • MLRO files SARs to the appropriate Nigerian authority promptly when suspicion arises.
  • Accounts may be frozen or restricted as required by law.

5. Sanctions Screening

  • Screen customers and transactions against Nigerian and international sanctions lists.
  • Block or report matches per legal requirements.

6. Training & Audit

  • Regular mandatory AML/CFT training for all staff.
  • Annual independent review of AML program effectiveness.

Questions? Contact us at support@usemoon.space

Last updated: March 2026 · Moon Finance Ltd.