spronet.ng

Anti-Money Laundering Policy

Effective Date: 25 April 2026  ·  Last Updated: 25 April 2026

1. Introduction and Purpose

Spronet Nig Ltd ("Spronet.ng," "the Company," "we," "us," or "our") is committed to operating a lawful and transparent business-to-business (B2B) industrial procurement marketplace. We recognise that online marketplaces can be vulnerable to exploitation by those seeking to launder the proceeds of crime or finance terrorist activities.

This Anti-Money Laundering and Counter-Terrorism Financing Policy ("AML Policy") sets out the principles, procedures, and controls that Spronet.ng has adopted to prevent, detect, and report money laundering and terrorism financing ("ML/TF") activities conducted through the Platform.

This Policy applies to all employees, contractors, partners, and users of the Spronet.ng platform, including Buyers, Dealers (Sellers), and any third parties who interact with or through our services.

This AML Policy is designed in compliance with, and is guided by, the following Nigerian laws, regulations, and international standards:

  • Money Laundering (Prevention and Prohibition) Act, 2022 — The principal legislation criminalising money laundering in Nigeria and establishing compliance obligations for designated non-financial institutions.
  • Terrorism (Prevention and Prohibition) Act, 2022 — Legislation prohibiting the financing of terrorism and establishing obligations for reporting and compliance.
  • Economic and Financial Crimes Commission (EFCC) Act — Establishing the EFCC as the primary enforcement agency for economic and financial crimes.
  • Central Bank of Nigeria (CBN) AML/CFT Regulations — Regulatory guidance for financial institutions and designated non-financial businesses.
  • Nigerian Financial Intelligence Unit (NFIU) Act, 2018 — Establishing the NFIU as the national centre for receiving, analysing, and disseminating Suspicious Transaction Reports (STRs).
  • Financial Action Task Force (FATF) Recommendations — International standards on combating money laundering and the financing of terrorism, to which Nigeria is committed through its membership in GIABA (Inter-Governmental Action Group against Money Laundering in West Africa).

3. Key Definitions

  • "Money Laundering" — The process of making illegally obtained proceeds appear legitimate by concealing or disguising their true origin, nature, source, location, disposition, movement, or ownership.
  • "Terrorism Financing" — The provision, collection, or receipt of funds with the intention or knowledge that they will be used to carry out terrorist acts.
  • "Politically Exposed Person (PEP)" — An individual who is or has been entrusted with a prominent public function, as well as their family members and close associates.
  • "Suspicious Transaction" — Any transaction or activity that is inconsistent with a user's known legitimate business or personal activities, or that appears to have no lawful economic purpose.
  • "Know Your Customer (KYC)" — The process of verifying the identity of users and understanding the nature and purpose of their business relationships.
  • "Customer Due Diligence (CDD)" — The measures taken to identify and verify users and to understand the nature of their activities to assess ML/TF risk.
  • "Enhanced Due Diligence (EDD)" — Additional verification measures applied to higher-risk users, transactions, or business relationships.

4. Risk Assessment

4.1 Platform Risk Profile

As a B2B industrial procurement marketplace, Spronet.ng facilitates connections between Buyers and Dealers for the purpose of sourcing industrial goods and services. While the Platform does not process, hold, or escrow transaction funds between users (payments are made directly between Buyers and Dealers), we recognise the inherent risks that may arise from marketplace facilitation, including:

  • Use of fictitious businesses or shell companies to create profiles for the purpose of conducting illegitimate transactions.
  • Over-invoicing or under-invoicing of goods to move illicit funds across borders or between entities.
  • Conducting sham or phantom transactions (goods that are never delivered) to create the appearance of legitimate commerce.
  • Structuring multiple small transactions to avoid detection thresholds.
  • Use of the Platform by sanctioned individuals, entities, or those associated with terrorism financing.

4.2 Risk-Based Approach

Spronet.ng employs a risk-based approach to AML/CTF compliance, meaning that the level of due diligence, monitoring, and controls applied is commensurate with the assessed level of risk. Higher-risk users, transactions, and geographies receive enhanced scrutiny.

5. Know Your Customer (KYC) and Customer Due Diligence (CDD)

5.1 User Registration

All users of the Spronet.ng platform are required to:

  • Register with a valid, verifiable email address.
  • Authenticate their identity through our identity provider (currently Clerk).
  • Provide truthful and accurate information during registration.

5.2 Dealer Verification

Dealers (Sellers) are subject to an additional verification process before gaining full access to Platform features, including responding to RFQs and listing products. The Dealer verification process may include:

  • Verification of business name and registration with the Corporate Affairs Commission (CAC) of Nigeria.
  • Confirmation of business address, contact information, and representative identity.
  • Review of business category, products, and operational legitimacy.
  • Cross-referencing against sanctions lists and PEP databases where applicable.
  • On-site inspection at the discretion of the Platform's trust and safety team.

5.3 Enhanced Due Diligence (EDD)

EDD is applied in the following circumstances:

  • Users or transactions identified as high-risk by our monitoring systems.
  • Users from high-risk jurisdictions or sectors prone to ML/TF activity.
  • Users who are or are associated with Politically Exposed Persons (PEPs).
  • Transactions that are unusually large, complex, or inconsistent with a user's known business activity.
  • Cases where there are reasonable grounds to suspect ML/TF activity.

5.4 Ongoing Monitoring

KYC is not a one-time event. Spronet.ng conducts ongoing monitoring of user activity and may periodically request updated verification documents. Users who fail to comply with re-verification requests may have their accounts restricted or suspended.

6. Transaction Monitoring

6.1 Automated Monitoring

Spronet.ng maintains systems to monitor transactions and user activity for patterns that may indicate ML/TF activity, including:

  • Unusually high transaction volumes or values relative to a user's verified business profile.
  • Rapid and repeated transactions between the same Buyer and Dealer with no clear commercial rationale.
  • Transactions involving goods that do not match the Dealer's listed products or business category.
  • Multiple accounts linked to the same individual, device, IP address, or business entity.
  • Significant discrepancies between quoted prices and prevailing market prices for similar goods.
  • Unusual geographic patterns, such as transactions involving regions not typically associated with the user's business.

6.2 Manual Review

Transactions or accounts flagged by automated systems are escalated to the Platform's compliance team for manual review. The compliance team may request additional information from the user, conduct further investigation, or file a Suspicious Transaction Report (STR) as appropriate.

6.3 Handshake Score Integration

Spronet.ng's proprietary Handshake Score trust metric serves as an additional layer of AML monitoring. Users with consistently low trust scores, irregular transaction patterns, or whose behaviour triggers AML alerts may be subject to enhanced scrutiny, account restrictions, or suspension.

7. Suspicious Activity Reporting

7.1 Internal Reporting

All employees, contractors, and partners of Spronet.ng are required to report any suspicious activity to the designated Compliance Officer immediately upon detection. Failure to report known or suspected ML/TF activity constitutes a serious disciplinary offence.

7.2 Suspicious Transaction Reports (STRs)

Where Spronet.ng has reasonable grounds to suspect that a transaction involves the proceeds of crime, is intended to finance terrorism, or is otherwise suspicious, we will file a Suspicious Transaction Report (STR) with the Nigerian Financial Intelligence Unit (NFIU) in accordance with the Money Laundering (Prevention and Prohibition) Act, 2022.

7.3 Tipping Off

It is a criminal offence under Nigerian law to "tip off" a person who is the subject of an STR — that is, to inform them that a report has been or will be made, or that an investigation is underway. All Spronet.ng personnel are strictly prohibited from disclosing any information about STRs to the persons involved.

7.4 User Reporting

Users of the Platform who suspect that another user is involved in money laundering, terrorism financing, or other financial crime are encouraged to report their concerns to Spronet.ng at compliance@spronet.ng or via the Platform's content flagging system. All reports will be treated confidentially.

8. Record Keeping

In compliance with Nigerian law, Spronet.ng maintains comprehensive records of:

  • All user identification and verification documents collected during KYC/CDD processes.
  • All transaction records, including RFQs, Quotes, Orders, Invoices, and payment proofs.
  • All communication logs within the Platform, including Negotiation Room messages.
  • All internal and external reports relating to suspicious activity.
  • All AML/CTF training records.

Records are retained for a minimum period of five (5) years from the date of the transaction or the date of the end of the business relationship with the user, whichever is later, or for such longer period as may be required by Nigerian law or by order of a competent authority.

9. Sanctions Screening

Spronet.ng screens users and transactions against applicable sanctions lists, including:

  • United Nations Security Council Consolidated List.
  • EFCC and Nigerian Government watch lists.
  • Other applicable international and regional sanctions lists.

Users or transactions that match entries on sanctions lists will be blocked, and the relevant authorities will be notified in accordance with applicable law. Spronet.ng prohibits any transaction, business relationship, or activity involving sanctioned individuals, entities, or jurisdictions.

10. Employee Training and Awareness

All Spronet.ng employees, contractors, and relevant third parties receive regular AML/CTF training, covering:

  • The legal and regulatory framework for AML/CTF in Nigeria.
  • Recognition of red flags and indicators of money laundering and terrorism financing.
  • Internal reporting procedures and the role of the Compliance Officer.
  • The prohibition on tipping off and consequences of non-compliance.
  • Updates on emerging ML/TF typologies, techniques, and regulatory changes.

Training records are maintained and updated annually. New employees receive AML/CTF training as part of their onboarding process.

11. Compliance Officer

Spronet.ng has designated a Compliance Officer with responsibility for:

  • Overseeing the implementation of this AML Policy.
  • Receiving and assessing internal reports of suspicious activity.
  • Filing STRs with the NFIU and cooperating with regulatory and law enforcement authorities.
  • Conducting periodic risk assessments and updating AML procedures.
  • Ensuring all personnel receive appropriate AML/CTF training.
  • Reporting to the Company's management and board of directors on AML/CTF matters.

The Compliance Officer may be contacted at compliance@spronet.ng.

12. Red Flags and High-Risk Indicators

The following are examples of activities that may indicate ML/TF risk and trigger enhanced scrutiny or reporting:

  • A Dealer whose product listings are inconsistent with their stated business type or verification documents.
  • A Buyer or Dealer who creates multiple accounts or frequently changes identity information.
  • Transactions significantly above or below market prices for the goods involved.
  • A user who is reluctant to provide identification or verification documents, or who provides documents that appear forged or altered.
  • Unusually complex transaction structures with no apparent commercial purpose.
  • Transactions involving high-risk jurisdictions identified by FATF or international bodies.
  • A pattern of transactions immediately followed by cancellations, refunds, or disputes with no clear reason.
  • Users who insist on conducting transactions off-Platform immediately after initiating contact through the Platform.
  • Payment proofs that appear altered, inconsistent, or that relate to third-party accounts unrelated to the registered user.
  • Significant changes in transaction volume or value that are inconsistent with the user's verified business profile.

13. User Obligations

All users of the Spronet.ng platform are required to:

  • Provide truthful, accurate, and current identification and business information during registration and verification.
  • Immediately update their information if it changes.
  • Cooperate with any verification, re-verification, or investigation request from the Platform.
  • Not use the Platform for any illegal purpose, including money laundering, terrorism financing, or fraud.
  • Report any suspected ML/TF activity by other users to compliance@spronet.ng.
  • Maintain adequate records of their own transactions and business activities.

Failure to comply with these obligations may result in account restriction, suspension, termination, and/or referral to the relevant Nigerian law enforcement or regulatory authorities.

14. Enforcement and Consequences

Spronet.ng takes AML/CTF compliance extremely seriously. Users found to be in violation of this Policy may face:

  • Immediate account suspension — pending investigation.
  • Permanent account termination — following a confirmed violation.
  • Referral to law enforcement — including the EFCC, NFIU, and the Nigeria Police Force.
  • Forfeiture of all Platform benefits — including Handshake Score, Boost Campaign credits, and any pending transactions.
  • Legal action — Spronet.ng reserves the right to pursue civil remedies against users who cause the Company financial or reputational harm through ML/TF activity.

Employees or contractors found to have facilitated, ignored, or failed to report ML/TF activity will face disciplinary action, including termination of employment or contract, and may be subject to criminal prosecution under Nigerian law.

15. Cooperation with Authorities

Spronet.ng is committed to full cooperation with Nigerian regulatory and law enforcement authorities in the prevention, investigation, and prosecution of money laundering and terrorism financing. This includes:

  • Timely filing of STRs with the NFIU.
  • Responding promptly to lawful requests for information from the EFCC, NFIU, CBN, and other competent authorities.
  • Providing access to records and documentation as required by law or court order.
  • Participating in inter-agency coordination efforts as appropriate.

16. Policy Review and Updates

This AML Policy is reviewed and updated at least annually, or more frequently in response to:

  • Changes in Nigerian AML/CTF legislation or regulatory guidance.
  • Emerging ML/TF risks, typologies, or techniques identified through industry intelligence or regulatory advisories.
  • Significant changes to the Platform's services, user base, or geographic reach.
  • Findings from internal or external audits, risk assessments, or regulatory examinations.

Any material changes to this Policy will be communicated to affected users through the Platform and/or via email.

17. Contact Information

For questions, concerns, or reports related to this AML Policy, money laundering, or terrorism financing, please contact:

  • Compliance Officer: compliance@spronet.ng
  • General Support: support@spronet.ng
  • Legal: legal@spronet.ng
  • Company: Spronet Nig Ltd
  • Address: Rivers State, Nigeria

Spronet.ng is committed to maintaining the highest standards of integrity and compliance in the fight against money laundering and terrorism financing. We encourage all users to join us in this effort by reporting any suspicious activity and cooperating fully with our compliance processes.