1) Purpose & Scope

This Policy sets out how Monica reduces the risk that its coin-to-naira off-ramp is used for money laundering, terrorist financing, fraud, or other unlawful activity. It applies to all Monica services, personnel, and contractors who handle identity data, transactions, or official requests.

2) Business Model (What We Are / Are Not)

• Off-ramp only. Users send supported digital assets (“coin”) to a Monica-provided address; after network confirmation we convert to NGN and pay out to the user’s bank.

• Not a custodian or exchange. We do not hold user private keys and do not control users’ external wallets.

• Finality. Blockchain transfers are irreversible; funds mis-sent (wrong asset/network/address) cannot be recovered.

3) Legal Framework

We operate under applicable laws of the Federal Republic of Nigeria and any binding orders from competent authorities. Where cross-border obligations apply (e.g., information-sharing between VASPs), we respond in line with law.

4) Risk Control Principles

1. Know the User (ID confirmation). We confirm user identity before enabling conversion & payout.

2. Proportional controls. Controls are fit-for-purpose for an off-ramp (Sections 5–9).

3. Act when required. We may review, delay, restrict, refuse, reverse, or place limits on transactions or account features where required by law or to protect users or the integrity of the service.

4. No duty created. Our actions do not constitute any promise that unlawful activity will be detected, prevented, blocked, reversed, or remedied.

5) Customer Identification & Data We Collect

To confirm identity and operate payouts, we collect only what’s listed here (“Identity Data” and “Operational Data”):

Identity Data

• NIN (National Identification Number)

• Phone number

• Email address

• Address and basic identity fields derived from NIN for verification

• Selfie image captured during verification (where required)

Operational Data

• Device identifiers/user agents (app version/OS)

• IP addresses and access timestamps

• Bank payout details (bank name, account name, account number, payout references)

• Deposit addresses generated by Monica, on-chain txids, amounts, timestamps, internal references

Verification channel. Identity steps occur only inside the Monica app—never by DM or social media.

6) User Responsibilities & Prohibited Use

Users must:

• use Monica lawfully and only for supported assets/networks;

• provide accurate information and keep accounts/devices secure;

• ensure the lawful source of funds and satisfy any tax/filing duties that apply to them.

Prohibited: using Monica in connection with unlawful activity, misrepresenting identity (including another person’s NIN), attempting to bypass controls, or abusing systems. Monica may restrict or close accounts for violations or legal reasons.

7) Transaction Handling & Reviews

• Large-volume awareness. We may review large-volume transactions (e.g., unusually high value or activity) to protect users and service integrity.

• Travel Rule / Information-sharing. Where required by applicable law or information-sharing obligations between virtual asset service providers, Monica may share originator/beneficiary information we hold with authorized counterparties.

• Actions we may take. Where required by law or necessary to protect users/service integrity, Monica may review, delay, restrict, refuse, reverse, or limit activity; and provide information to competent authorities. These actions may occur without prior notice and do not create a duty to detect or prevent unlawful activity.

8) Recordkeeping

We retain Identity and Operational Data, transaction and payout records, and official correspondence for at least the period required by applicable law and to the extent necessary to operate the service, respond to valid legal requests, and protect users and Monica.

9) Law Enforcement & Official Requests

• Point of contact: [email protected]

• Monica responds to valid legal process from competent authorities. Where lawful and necessary, we can provide only the information we hold, which may include:

  • Identity Data (Section 5)

  • Operational Data (Section 5)

  • Service records (deposit addresses generated by Monica, on-chain txids, amounts/timestamps, payout bank details & references)

• We can preserve records upon written request from a competent authority.

• Where a freezing or transfer is sought, Monica requires an appropriate freezing order or other valid legal authority.

• Data is transmitted via secure channels (e.g., encrypted archive with out-of-band key exchange).

10) Sanctions & Regulatory Directives

Where Monica receives a binding directive (e.g., from a competent authority or regulated counterparty) identifying a person or activity that must be restricted, Monica will act accordingly and may limit, refuse, or end services consistent with law.

11) Governance & Accountability

• Board/Management: oversee adoption of this Policy and ensure resources to comply with law.

• Compliance Function: manages identity confirmation processes, handles official requests, maintains records, and coordinates lawful actions described in Sections 7–10.

• Access discipline: Identity and Operational Data are accessed only by authorized personnel for legitimate business or legal reasons.

12) Availability, Changes & Publication

Monica aims for 24/7 availability but does not guarantee uninterrupted service. We may update this Policy; the current version will be published in-app/website and applies moving forward.

13) No Third Party Rights / No Private Cause of Action

This Policy is an internal standard and user notice. It does not create rights in favor of any third party, and does not create a private cause of action against Monica.