Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT) & Counter-Proliferation Financing (CPF) Policy
Overview
Roqqu (the "Company") refers to the group of affiliated entities operating under the Roqqu brand and providing digital asset services across multiple jurisdictions.
Roqqu is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. The Company implements robust controls to prevent, detect, and report money laundering, terrorist financing, proliferation financing, and other forms of financial crime.
Regulatory Compliance
Roqqu complies with applicable AML/CFT/CPF laws, regulations, and guidelines across all jurisdictions in which it operates, including but not limited to:
- The Securities and Exchange Commission (Capital Market Operators AML/CFT/CPF Regulations, 2022), as its primary regulatory framework in Nigeria
- The Money Laundering (Prevention and Prohibition) Act (MLPPA) and Terrorism (Prevention and Prohibition) Act (TFPPA)
- Guidelines and reporting obligations issued by the Nigerian Financial Intelligence Unit (NFIU) and other competent authorities
Roqqu aligns its compliance framework with applicable national regulations as well as international standards and best practices
Risk-Based Approach
Roqqu adopts a risk-based approach to AML/CFT/CPF compliance, applying controls proportionate to identified risks. These include:
- Customer, geographic, and transactional risks
- Product and service risks, including digital assets and unhosted wallets
- Risks associated with third-party relationships and counterparties
Enhanced due diligence measures are applied to higher-risk customers and activities.
Customer Due Diligence
Roqqu conducts customer due diligence prior to onboarding and on an ongoing basis. This includes:
- Identity verification (KYC)
- Risk profiling and classification
- Enhanced Due Diligence for high-risk customers, including politically exposed persons (PEPs)
- Identification of beneficial owners (for legal entities)
Roqqu may decline, restrict, or terminate relationships where risks cannot be adequately mitigated or required information is not provided.
Monitoring & Reporting
Roqqu maintains systems to monitor customer activity and detect suspicious behaviour, including:
- Ongoing transaction monitoring and behavioural analysis
- Real-time sanctions screening
Roqqu strictly prohibits tipping-off and ensures confidentiality in all reporting processes.
Sanctions Compliance
Where required, Roqqu implements measures to freeze assets without delay in accordance with applicable sanctions obligations.
Governance & Oversight
Roqqu maintains a strong governance framework, including:
- A designated Compliance Officer with overall responsibility for AML/CFT compliance
- An independent compliance function
- A "three lines of defence" model (business, compliance, and internal audit)
- Ongoing staff training and independent review of controls
Technology & Controls
Roqqu leverages advanced technology to support compliance, including:
- Digital identity verification systems
- Automated transaction monitoring tools
- Blockchain analytics and risk assessment solutions
Cross-Border Compliance
Roqqu applies the highest applicable regulatory standards across its operations and ensures compliance with local requirements in each jurisdiction. Where differences exist, the Company adopts the more stringent standard where permissible under applicable law.
Zero-Tolerance Approach
Roqqu maintains a zero-tolerance policy towards financial crime. Any misuse of the platform may result in account restrictions, reporting to authorities, and legal action.
Contact
For compliance-related inquiries or to report suspicious activity: Email: compliance@roqqu.com
Policy Updates
This policy may be updated periodically to reflect regulatory developments and evolving risks.
Last Updated: 31, March, 2026
