Effective Date: April 1, 2025
Last Updated: March 1, 2026

SECTION 1: STATEMENT OF PURPOSE AND COMPLIANCE

1.1. Zero Tolerance Policy: Zelencio (“the Platform”) maintains a zero-tolerance policy regarding money laundering, terrorist financing, and the facilitation of financial crimes. We are committed to the highest standards of compliance as set forth by the Financial Action Task Force (FATF) and the relevant financial intelligence units in the jurisdictions where we operate (including the SEC and EFCC in Nigeria).

1.2. Scope of Policy: This policy applies to all users, employees, and third-party partners of Zelencio. Our objective is to ensure that the platform is not used to hide the proceeds of crime, facilitate the movement of illegal funds, or support sanctioned entities.

SECTION 2: THE COMPLIANCE FRAMEWORK

2.1. Money Laundering Reporting Officer (MLRO): Zelencio appoints a dedicated Compliance Officer/MLRO responsible for overseeing the AML/CTF framework. The MLRO has the authority to block transactions, freeze accounts, and report activity to government authorities without user consent.

2.2. Risk-Based Approach (RBA): Zelencio utilizes a Risk-Based Approach to monitor users. Each account is assigned a risk profile (Low, Medium, High) based on:

• Geographic location (IP address and residency).

• Transaction frequency and volume.

• The use of "High-Risk" features such as Zelencio Codes or P2P Trading.

SECTION 3: CUSTOMER DUE DILIGENCE (KYC/CDD)

3.1. Verification Requirements: No user is permitted to execute financial transactions on the Zelencio Internal Ledger without completing the mandatory tiered KYC process.

• Identification: Verification of government-issued ID via AI-driven authenticity checks.

• Liveness: Visual biometric verification to prevent the use of static photos or deepfakes.

• Sanctions Screening: Every user is screened against global sanctions lists (e.g., OFAC, UN, EU, and local watchlists).

3.2. Ongoing Due Diligence: Zelencio does not just verify users once. We perform "Ongoing Monitoring" to ensure that user behavior remains consistent with their declared profile. If a "Basic KYC" user suddenly attempts a $50,000 transaction, the account will be flagged for Enhanced Due Diligence (EDD).

SECTION 4: TRANSACTION MONITORING AND DETECTION

4.1. Real-Time Surveillance: Zelencio utilizes proprietary AI monitoring to scan the Internal Ledger 24/7 for "Red Flag" behaviors:

• Structuring (Smurfing): Multiple small transactions designed to avoid hitting a KYC threshold.

• Rapid Movement: Assets deposited and immediately withdrawn to an external address with no trading activity.

• Voucher Abuse: High-frequency generation and redemption of Zelencio Codes between unrelated UIDs.

• P2P Anomalies: Frequent trade cancellations or disputes in the C2C Marketplace.

4.2. Internal Ledger Traceability: Unlike decentralized wallets, Zelencio maintains a centralized record of every movement. Every "Zelencio Code" and "Internal Transfer" is permanently linked to the creator’s and redeemer’s Verified UID.

SECTION 5: SUSPICIOUS ACTIVITY REPORTING (SAR)

5.1. Mandatory Reporting: Where Zelencio has reasonable grounds to suspect that funds are the proceeds of criminal activity, we are legally bound to file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the relevant financial authorities.

5.2. "Tipping Off" Prohibition: In accordance with international law, Zelencio is strictly prohibited from notifying a user that their account is under investigation or that a SAR has been filed.

SECTION 6: SANCTIONS AND PROHIBITED COUNTRIES

6.1. Geofencing: Zelencio employs IP-blocking and KYC-blocking to prevent access from "High-Risk Jurisdictions" as defined by the FATF.
6.2. Asset Freezing: If a user is added to an international sanctions list after they have joined the platform, Zelencio will immediately freeze their assets and notify the relevant regulatory body.

SECTION 7: RECORD KEEPING AND DATA RETENTION

7.1. The 5-Year Mandate: To assist in historical criminal investigations, Zelencio retains the following records for a minimum of five (5) years after the termination of the user relationship:

• Copies of all KYC documents and liveness recordings.

• Full transaction history (including IP addresses and device IDs).

• All communication logs from the P2P Chat and Support Hub.

SECTION 8: TRAINING AND INTERNAL AUDIT

8.1. Staff Training: All Zelencio employees handling financial data undergo annual AML/CTF training to identify modern money laundering techniques, including "Triangular Scams" and "Voucher Layering."
8.2. Independent Audit: Zelencio subjects its internal ledger and compliance protocols to periodic independent audits to ensure the platform meets global CEX (Centralized Exchange) standards.