AML/KYC Policy

This policy explains how SplitPocket works to prevent money laundering, terrorism financing, and fraud on the platform. It applies to everyone who uses SplitPocket, including hosts who list subscription seats and members who join them.

SplitPocket Technologies Limited is registered in Nigeria under RC 9746389, with its registered address at Block 4, Dunvale Cluster C, Coleman Nwafor Street, Orchid Road, Lekki, Eti-Osa, Lagos. SplitPocket operates only in Nigeria and in naira.

This policy is governed by the laws of the Federal Republic of Nigeria, including the Money Laundering (Prevention and Prohibition) Act 2022.

SplitPocket is a marketplace that connects hosts with spare seats on a subscription plan to members who want to join those seats. When a member pays for a seat, SplitPocket holds the payment until the subscription renews. Once the renewal is confirmed, SplitPocket releases the payment to the host.

SplitPocket does not offer wallets, savings products, virtual cards, or bill payment services. Payments on the platform are processed through Flutterwave, a licensed payment service provider.

SplitPocket conducts identity verification through secure API integrations with licensed payment partners. Using a partner to run these checks does not shift the responsibility away from SplitPocket. SplitPocket confirms the outcome of every check and ensures each host and member is properly verified before certain features become available.

Here is what you need to know about verification:

• SplitPocket collects your name, phone number, and email address when you create an account.
• SplitPocket verifies your identity through API integrations with Flutterwave, a licensed payment service provider recognised by the Central Bank of Nigeria.
• Verification can include checks such as your Bank Verification Number (BVN) or National Identification Number (NIN), carried out through Flutterwave's systems and confirmed by SplitPocket before your account is fully activated.
• SplitPocket applies tiered verification levels, so the checks required depend on what you want to do on the platform. Joining a pocket as a member requires a lower tier of verification than hosting a pocket and receiving payouts.
• SplitPocket will not activate certain features, including receiving payments as a host, until your identity has been verified and confirmed.

SplitPocket classifies every account and every pocket as low, medium, or high risk. This rating is not fixed. It can change as new information comes in.

SplitPocket sets your risk rating using factors such as:

• How often you transact, and the value of those transactions.
• Where you are located within Nigeria, and whether that location carries known fraud risk.
• Your account history, including any past disputes or restrictions.
• Whether you are a host, a member, or both, since hosts carry higher risk because they receive payouts.

Accounts and pockets rated medium or high risk receive closer review before approval and more frequent checks afterwards.

Verifying your identity once is not enough. SplitPocket also checks accounts and activity on an ongoing basis, watching for signs of card fraud, cash-out schemes, and other misuse common to subscription marketplaces.

SplitPocket treats the following as red flags that trigger closer review:

• A single host setting up many high-value pockets at the same time.
• Multiple accounts linked to the same debit card, bank account, or device.
• Payouts requested immediately after a seat is purchased, with little or no delay.
• Repeated changes to payout details, or disputes and failed renewals that follow a pattern.

When SplitPocket identifies one of these patterns, it places the account or pocket under review, and features such as new pocket creation or payouts may be paused until the review is complete.

SplitPocket checks hosts and members against relevant sanctions lists when they create an account, and continuously afterwards as those lists are updated.

This includes screening for Politically Exposed Persons, known as PEPs. A PEP is someone such as a Nigerian public official, their family member, or a close associate, since these accounts carry a higher money laundering risk.

If an account matches a sanctions list or a PEP list, SplitPocket restricts the account right away and may freeze any related funds. A PEP match requires sign-off from the Compliance Officer before the account can be reinstated or any restriction lifted. This sign-off can include a review of the source of funds and the nature of the account's activity on SplitPocket.

If SplitPocket identifies suspicious activity, such as an unexplained pattern of payments, an account linked to fraud, or behaviour that suggests money laundering, SplitPocket will report it to the Nigerian Financial Intelligence Unit (NFIU), as required by law.

SplitPocket will not tell you if your account has been reported or is under investigation. This is a legal requirement, not a choice SplitPocket makes. Section 8 of the Money Laundering (Prevention and Prohibition) Act 2022 prohibits telling anyone that a report has been made or that an investigation is underway. This is called the prohibition against tipping off, and it applies to SplitPocket and everyone who works there.

SplitPocket keeps records of your account and transactions for at least five years, in line with Nigerian AML law. Some records, such as payment and transaction history, may be kept for up to six years. These records include:

• Your identity and verification information.
• Your transaction history, including payments, refunds, and payouts.
• Records of any suspicious activity reports or account restrictions.
• Communication related to disputes or investigations.

Under the Nigeria Data Protection Act, you generally have the right to ask SplitPocket to delete your personal information. This right does not override SplitPocket's legal duty to retain AML records for the periods set out above. If your account is closed, SplitPocket deletes personal information not subject to this retention duty and keeps the records it is legally required to keep for the full retention period.

SplitPocket operates under Nigeria's anti-money laundering framework. Depending on SplitPocket's licensing and partner structure, this includes oversight from the following bodies:

• The Nigerian Financial Intelligence Unit (NFIU), which receives suspicious transaction reports.
• The Special Control Unit Against Money Laundering (SCUAML), which supervises designated non-financial businesses for AML compliance.
• The Central Bank of Nigeria (CBN), which regulates and supervises SplitPocket's licensed payment partners.
• The Nigeria Data Protection Commission (NDPC), which oversees how SplitPocket handles personal data.

SplitPocket works with these bodies where relevant and updates this policy if its regulatory obligations change.

SplitPocket has appointed a Compliance Officer who is responsible for this policy. The Compliance Officer reviews reports of suspicious activity, decides when to report to the NFIU, signs off on PEP matches, and makes sure SplitPocket's practices stay in line with Nigerian law.

You can reach the Compliance Officer at support@getsplitpocket.com.

SplitPocket commits to an annual independent audit of its AML and KYC controls. This audit checks whether SplitPocket's practices match this policy and Nigerian law, and identifies any gaps that need to be fixed. The Compliance Officer reviews the findings and makes sure they are addressed within a set timeframe.

Everyone at SplitPocket who works with user accounts, payments, or disputes receives training on this policy. Training covers how to recognise suspicious activity, escalate a concern, and protect your information.

SplitPocket integrates directly with Flutterwave's systems to process payments and to run identity verification checks. Flutterwave is a licensed payment service provider recognised by the Central Bank of Nigeria.

Using Flutterwave for this work does not shift the responsibility away from SplitPocket. SplitPocket remains responsible for confirming that every host and member has been properly verified and for ensuring the controls described in this policy are followed, regardless of which partner carries out the underlying check.

SplitPocket may update this policy as its practices or Nigerian law change. If a change is significant, SplitPocket will let you know before it takes effect.

If you have questions about this policy or how SplitPocket handles your information, contact us at support@getsplitpocket.com.