AML & CFT Policy

Reptalia Labs is the technology innovation lab behind the development of Amani, SatFlux, and other digital applications. Alpha Sight Ltd is the registered legal entity that operates these products. Together, we provide secure transaction and payment solutions for freelancers, businesses, and individuals across Africa. This AML/KYC policy is a procedural guideline on all matters relating to crime compliance. This Policy provides safeguards to combat Money Laundering ("ML"), the Financing of Terrorism ("FT"), and the Prevention of the Financing and Proliferation of Weapons of Mass Destruction, in line with Nigerian (NFIU) and US (FinCEN) regulations.

This AML/KYC Policy applies to all directors, officers, and employees (collectively "Personnel") of Alpha Sight Ltd, the registered entity, and all its subsidiaries and products, including those developed by Reptalia Labs such as Amani and SatFlux. This Policy sets out the key principles of our Risk-Based Approach (RBA) to identify, manage, and mitigate our risks of exposure to crime.

All users operate from a central Amani account. Account capabilities are determined by a tiered KYC level, regardless of which interface (Web, Telegram, WhatsApp) is used to access it. The user's verified phone number is the unique identifier linking all interfaces to the single account. Tier 0: "P2P User" (Phone-Verified): Baseline entry for users via Authorized Digital Channels. Verification: Automatic verification of the user's phone_number_hash and digital_channel_id. Permitted Activities: Receive crypto-assets, send internal P2P transfers. Hard-Coded AML Controls: Daily send limit ($200), no fiat/external withdrawals, no device linking until upgrade. Tier 1: "Verified User" (Full KYC): Required for banking and high-value functions. Verification Trigger: Upgrade required for fiat deposit, exceeding send limit, or using settlement assurance. Information Collected: Full legal name, DOB, address, ID, biometric verification. Permitted Activities: All Tier 0, higher limits, fiat deposit/withdrawal, external withdrawal, device linking, settlement assurance. Institutional Users: Must provide incorporation docs, business details, and full KYC for UBOs. Enhanced Due Diligence (EDD): Applied to high-risk profiles (PEPs, high-risk jurisdictions, suspicious activity). Specific Due Diligence for Settlement Assurance: Mandatory Tier 1 for all parties, prohibition for Tier 0 users.

Risk-based approach with automated and manual processes. Automated monitoring: sanctions screening, velocity limits, anti-void logic, structuring detection. Specific monitoring for settlement assurance: Collusion risk, transaction legitimacy, value mismatch. All alerts escalated to Compliance Officer.

Authorized to monitor and enforce AML/KYC Policy. Responsibilities: monitor transactions, ensure compliance, administer program, train employees, review policy, approve suspicious transactions.

Risk-based approach for crime risks. Product & User Risk Profile: SatFlux (Tier 0) is low-risk, Amani (Tier 1) is high-risk. Specific risks: Source of funds, mule/shell accounts, collusion. Mitigations: full KYC, monitoring, refusal rights.

Adhere to statutory reporting in Nigeria (NFIU & SCUML): STRs, CTRs, FTRs. USA (FinCEN): SARs, CTRs. Timely reporting and compliance.

Obliged to cooperate fully with all governmental authorities, including NFIU, EFCC, SEC (Nigeria), and FinCEN.

PEPs subject to mandatory Enhanced Due Diligence. Approval required from Managing Director and Compliance Officer before business relationship.

Daily automated screening against OFAC SDN, UN Sanctions, global watchlists. No accounts for sanctioned jurisdictions. Matches frozen and escalated.

Mandatory annual training for all personnel on AML/CFT laws, KYC principles, and red flags for account and Settlement Assurance models.

Maintain records of KYC data, transaction ledgers, investigation notes, STRs/SARs/CTRs. Retain for minimum 5 years after user relationship ends.

Annual independent audit of AML/KYC Policy to test controls, especially Tier 0 limits and risk monitoring.

Reviewed annually by Compliance Officer to ensure currency with regulations and product offerings.