Anti-Money Laundering & Compliance Statement

1. Our Commitment

Sawa Wallet ("we," "our," or "us") is committed to preventing the use of our platform for money laundering, terrorist financing, fraud, and other financial crimes. This statement describes the measures we apply to our services — in particular our fiat on-ramp and off-ramp rails, where money moves between bank accounts, mobile money, and cryptocurrency.

2. Scope

This statement applies to:

• Buying cryptocurrency with local currency through Sawa
• Cashing out cryptocurrency to bank accounts or mobile money
• Bill payment and airtime services funded from a Sawa balance

Purely on-chain, wallet-to-wallet transfers are executed by public blockchain networks under your own keys; we monitor platform activity but do not control blockchain networks themselves.

3. Identity Verification (KYC)

Before using our fiat rails, users complete identity verification proportionate to their activity. Depending on your verification level and jurisdiction, this may include:

• Verified phone number and account credentials
• Government-issued identity document checks through our licensed identity-verification partner
• Bank account or mobile-money account name matching
• Enhanced due diligence for higher transaction volumes or unusual activity

Higher verification levels unlock higher transaction limits. We may decline, limit, or reverse transactions where verification cannot be completed.

4. Transaction Monitoring

We monitor platform activity for patterns associated with financial crime, including:

• Structuring (breaking large amounts into many small transactions)
• Rapid pass-through activity inconsistent with normal wallet use
• Activity linked to addresses associated with sanctioned entities, hacks, or scams
• Velocity and volume anomalies relative to a user's verification level

Flagged activity may result in additional verification requests, transaction delays, limits, or account restriction while we review.

5. Sanctions Compliance

We do not provide services to individuals or entities on applicable sanctions lists, or in jurisdictions subject to comprehensive sanctions. Where required, users and transactions are screened against relevant lists, and matches are escalated for review and reported to the appropriate authorities.

6. Reporting & Record-Keeping

We retain transaction and verification records for the periods required by applicable law and cooperate with lawful requests from regulators and law enforcement, including filing suspicious-activity reports where required. Our practices are designed to align with Nigerian AML/CFT requirements — including the Money Laundering (Prevention and Prohibition) Act 2022 and relevant guidance applicable to virtual-asset services — as well as international standards such as the FATF Recommendations.

7. Your Obligations

• Provide accurate, current information during verification
• Use Sawa only for lawful purposes and your own funds
• Do not let others use your account (no account renting or "P2P agency" on your identity)
• Respond to verification requests promptly when asked

Warning: Allowing third parties to move money through your verified account is a common money-mule pattern and will result in account restriction and, where required, reporting to authorities.

8. Contact

Questions about this statement or our compliance program:

See also our Privacy Policy and Terms of Service.