Anti-Money Laundering, Counter-Terrorist Financing & Know Your Customer (AML/CFT & KYC) Policy

Value Cycle Network LTD (“VCN”) is committed to maintaining a lawful, transparent and responsible digital platform. VCN does not permit its platform, payment systems, accounts, products or services to be used for money laundering, terrorist financing, fraud, sanctions evasion or other unlawful financial activity.

VCN collects and verifies basic customer information, which may include a customer's name, phone number, verified email address and verified WhatsApp number.

VCN may require additional identity or transaction information whenever reasonably necessary for security, fraud prevention, regulatory compliance or risk management.

A customer attempting a single transaction of ₦50,000 or more may be required to complete enhanced KYC verification before the transaction is finally processed or credited for the relevant VCN service.

Enhanced verification may include:

• a valid government-issued photo identification document
• verification that the customer's identity corresponds with the information registered on the VCN account
• reasonable verification of the payment account or payment source
• proof of residential or business address

VCN may request additional supporting information concerning the purpose or source of a transaction where reasonably necessary.

The ₦50,000 threshold does not prevent VCN from carrying out verification on transactions below that amount. VCN may review, delay, restrict or reject transactions where there are reasonable concerns about suspicious activity, including repeated transactions apparently structured to avoid verification requirements, unusual transaction patterns, inconsistent customer information, suspected fraud, unauthorized payment methods or other indicators of unlawful activity.

Customers must not use VCN to facilitate money laundering, terrorist financing, fraud, corruption, sanctions evasion, financing of prohibited activities or transactions involving funds derived from unlawful conduct.

Where appropriate, VCN may screen customers or transactions against applicable sanctions, watchlists or other compliance information and may request additional verification before providing a service.

VCN may monitor transactions and account activity for unusual or potentially suspicious patterns. Transactions may be placed under review where information supplied by a customer is incomplete, inconsistent or raises reasonable compliance or security concerns.

VCN reserves the right, subject to applicable law and payment-provider requirements, to delay, reject or restrict a transaction; request additional information; restrict access to relevant services; or suspend an account where necessary to investigate suspected fraud, money laundering, terrorist financing, sanctions violations or other unlawful activity.

VCN may cooperate with its payment service providers, financial institutions and competent authorities where required by applicable law or lawful regulatory process.

VCN maintains appropriate customer, verification and transaction records for compliance, security, dispute resolution and fraud-prevention purposes. Relevant records will be retained for the period required under applicable Nigerian law and VCN's legitimate compliance obligations.

Payments processed through VCN may involve regulated payment service providers and financial institutions. Customers may therefore be subject to additional identity verification, transaction monitoring or compliance requirements imposed by those providers.

Customers must provide accurate, complete and current information. A customer must not impersonate another person, submit falsified documents, conceal the true source or purpose of funds, use another person's payment account without authorization, or structure transactions for the purpose of avoiding verification or compliance controls.

VCN may update this policy as its services, regulatory obligations, risk controls or payment-provider requirements develop.

Questions concerning this policy may be directed to:

Value Cycle Network LTD

Email: support@valuecyclenetwork.com

Nigeria

This policy is effective from 10 September 2026.