Anti-Money Laundering &
Counter-Terrorism Financing

1. Customer Due Diligence (CDD)

Mojeaga Network applies risk-based Customer Due Diligence (CDD) procedures before establishing business relationships or processing certain transactions.

CDD measures may include:

• Verification of identity through approved KYC procedures.
• Verification of residential or business address.
• Verification of banking information where required.
• Screening against sanctions or watch lists where legally required.
• Identification of beneficial owners for corporate accounts.
• Assessment of the purpose and intended nature of the business relationship.
• Enhanced due diligence for higher-risk customers or jurisdictions.

The Company reserves the right to request additional documentation where the level of risk warrants further verification.

No commissions, withdrawals, or other financial transactions requiring verification will be processed until mandatory CDD requirements have been satisfactorily completed.

2. Monitoring Transactions

Mojeaga Network continuously monitors transactions and account activity to detect unusual, suspicious, or potentially unlawful behaviour.

Monitoring may include review of:

• Distributor registrations.
• Product purchases.
• Commission payments.
• Withdrawal requests.
• Wallet activity.
• Refund requests.
• Account modifications.
• Multiple account creation.
• Geographic transaction patterns.
• High-value or unusual transactions.
• Repeated failed payment attempts.

Automated monitoring systems, manual reviews, and risk-based controls may be used to identify activities requiring further investigation.

The Company reserves the right to delay, suspend, or decline transactions pending completion of appropriate reviews.

3. Suspicious Activity

Examples of activities that may be considered suspicious include, but are not limited to:

• Providing false or forged identity documents.
• Using another person’s identity or payment instrument without authorization.
• Attempting to circumvent KYC or verification requirements.
• Creating multiple accounts to manipulate commissions or incentives.
• Unusual purchasing patterns inconsistent with legitimate business activity.
• Requests for payment through unauthorized channels.
• Transactions involving sanctioned persons or jurisdictions, where prohibited by law.
• Efforts to conceal the true source or destination of funds.
• Any activity reasonably suspected to involve fraud, money laundering, terrorist financing, bribery, corruption, or other financial crime.

Identification of suspicious activity does not automatically imply wrongdoing but may result in further review and temporary account restrictions while investigations are conducted.

4. Reporting

Employees and authorized representatives must promptly report any suspected money laundering, terrorist financing, fraud, or other financial crime to the Company’s Compliance Department.

Reports should include all relevant information available at the time, including:

• Account details.
• Transaction references.
• Supporting documents.
• Description of the suspected activity.
• Dates and times of relevant events.

Where required by applicable law, Mojeaga Network may report suspicious activities to competent regulatory, financial intelligence, or law enforcement authorities.

Employees and distributors must not inform a customer or third party that a suspicious activity report has been made or that an investigation is underway, except where disclosure is authorized or required by law.

5. Record Keeping

Mojeaga Network maintains appropriate records to demonstrate compliance with applicable AML and CTF requirements.

Records may include:

• Customer identification documents.
• KYC verification records.
• Transaction histories.
• Payment records.
• Commission records.
• Risk assessments.
• Internal investigation files.
• Compliance communications.
• Regulatory reporting documentation.

Records will be retained for the period required by applicable law or for as long as reasonably necessary to support legal, regulatory, audit, or operational requirements.

At the end of the applicable retention period, records will be securely deleted, anonymized, or destroyed in accordance with the Company’s Records Retention Policy.

6. Staff Responsibilities

All employees, officers, and relevant contractors share responsibility for supporting the Company’s AML and CTF compliance programme.

Responsibilities include:

• Understanding and complying with this Policy.
• Completing mandatory compliance training.
• Following Customer Due Diligence procedures.
• Monitoring for suspicious behaviour within the scope of their duties.
• Promptly reporting concerns to the Compliance Department.
• Protecting the confidentiality of investigations.
• Cooperating with internal and external audits or regulatory inquiries.

Managers are responsible for promoting a culture of compliance and ensuring that staff understand their obligations under this Policy.

Failure to comply with AML requirements may result in disciplinary action, termination of employment or contractual relationships, and, where appropriate, referral to law enforcement authorities.

7. Sanctions Compliance

Where required by applicable law, Mojeaga Network may screen customers, distributors, business partners, and transactions against applicable sanctions lists and other legally recognized restricted-party lists.

The Company reserves the right to refuse or terminate business relationships that present unacceptable legal or compliance risks.

8. Training and Awareness

Mojeaga Network will provide appropriate AML and CTF training to employees and other relevant personnel on a periodic basis.

Training may include:

• AML and CTF obligations.
• Fraud prevention.
• Customer Due Diligence procedures.
• Identification of suspicious activities.
• Reporting obligations.
• Data protection and confidentiality.

Records of completed training may be maintained by the Company.

9. Policy Review

This Policy will be reviewed periodically to ensure continued compliance with applicable laws, regulatory expectations, industry standards, and operational requirements.

Any amendments will be approved by management and published through appropriate Company channels.

10. Contact Information

Questions regarding this AML & CTF Policy or reports of suspected financial crime should be directed to: