Anti-Money Laundering (AML) Policy

1. Purpose

This policy sets out MelonGram's commitment to detecting, preventing, and reporting money laundering and related financial crimes. It applies to all staff, agents, and activities related to our UK to Nigeria money transfer service.

2. Our Obligations

As a UK-regulated financial services provider, MelonGram is required to comply with:

• The Proceeds of Crime Act 2002.
• The Terrorism Act 2000.
• The Money Laundering Regulations 2017.
• The Financial Action Task Force (FATF) guidelines.

3. Risk-Based Approach

MelonGram adopts a risk-based approach to AML compliance. We assess each customer, transaction, and business relationship against defined risk criteria and apply proportionate controls accordingly.

4. Customer Due Diligence (CDD)

All users of MelonGram must complete identity verification before sending money. We conduct ongoing monitoring of transactions and may apply enhanced due diligence for higher-risk customers or transactions.

5. Transaction Monitoring

MelonGram continuously monitors transactions for patterns that may indicate money laundering, fraud, or other financial crime. Unusual or suspicious transactions are escalated to our compliance team for review.

6. Suspicious Activity Reporting

If we suspect or have reasonable grounds to suspect money laundering or financing of terrorism, we are legally obligated to report this to the UK National Crime Agency (NCA) via a Suspicious Activity Report (SAR). We cannot inform a customer that such a report has been made.

7. Record Keeping

We maintain records of all customer due diligence, transactions, and suspicious activity reports for a minimum of five years in compliance with UK legal requirements.

8. Staff Training

All MelonGram staff receive regular training on AML obligations, red flags, and internal reporting procedures.

9. Contact

AML concerns or queries can be directed to our compliance team:

• Email: compliance@melongram.com