Monica Compliance Statement

1. About this statement

This Compliance Statement summarises the legal and regulatory framework within which Monica operates and the programmes through which Monica discharges its obligations. It is informational and does not vary the rights of any customer, regulator or counterparty.

2. Legal entity

The Monica services are provided by Monica Technologies Limited, a private limited company incorporated and existing under the laws of the Federal Republic of Nigeria with its registered office in Lagos State. Monica is not a deposit-taking institution and does not hold a banking licence. Monica is not a custodian; following onchain confirmation, Cryptocurrency forms part of Monica's treasury and the customer's claim is a contractual Naira receivable. Cryptocurrency processed through the Monica platform is not insured by the Nigerian Deposit Insurance Corporation (NDIC), and Naira amounts owed to customers are likewise not NDIC-insured deposits.

3. Regulatory framework

Monica is aligned with, and where applicable directly bound by, the following Nigerian legal and regulatory instruments:

• Investments and Securities Act 2025 (ISA 2025) and the Securities and Exchange Commission's Virtual Asset Service Provider (VASP) framework, which establish the regulatory perimeter for virtual asset activities in Nigeria;
• Money Laundering (Prevention and Prohibition) Act 2022;
• Terrorism (Prevention and Prohibition) Act 2022;
• Nigerian Financial Intelligence Unit Act 2018 and the NFIU Regulations and Advisories;
• Nigeria Sanctions Act 2022;
• Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR);
• relevant Central Bank of Nigeria (CBN) circulars and directives, including the December 2023 guidelines reopening bank rails to compliant Virtual Asset Service Providers;
• applicable Financial Action Task Force (FATF) recommendations on virtual assets and VASPs as implemented in Nigeria;
• the Consumer Protection Framework of the Federal Competition and Consumer Protection Commission (FCCPC).

4. Compliance programme

Monica's compliance programme is owned by a designated Compliance Officer reporting directly to the Board. The programme covers AML/CFT, KYC, sanctions, data protection, consumer protection, tax reporting where applicable, and information security. Programme effectiveness is reviewed at least annually through institutional risk assessments, independent testing and Board oversight.

5. AML/CFT

Monica operates a documented, risk-based AML/CFT programme aligned with the Money Laundering (Prevention and Prohibition) Act 2022 and NFIU regulations. The programme is described in our AML/CFT Policy and includes customer due diligence, ongoing monitoring, suspicious-activity reporting, sanctions screening, record-keeping, training and independent testing.

6. KYC and customer identification

Before any Naira withdrawal, Monica completes customer due diligence under a tiered, risk-based model:

• Verification Tier 1. the customer registers a Nigerian bank account in his or her legal name, verified through NIBSS name-enquiry. Supports Naira withdrawals up to ₦500,000 per transaction.
• Verification Tier 2. the customer additionally submits a National Identification Number (NIN), verified through the National Identity Management Commission (NIMC). Supports Naira withdrawals up to ₦1,000,000 per transaction.

Enhanced due diligence is applied to higher-risk profiles, including Politically Exposed Persons, and may unlock higher limits at Monica's discretion. Sanctions, PEP and adverse-media screening is conducted on onboarding and continuously thereafter.

7. Sanctions and PEP screening

Customers are screened on onboarding and continuously thereafter against the United Nations Security Council Consolidated Sanctions List, the OFAC Specially Designated Nationals List, the European Union and UK consolidated sanctions lists, Nigerian sanctions lists and commercial PEP and adverse-media databases. Positive matches are escalated to the Compliance Officer for resolution before service is provided.

8. Privacy and data protection (NDPA)

Monica processes personal data in accordance with the Nigeria Data Protection Act 2023 and the Nigeria Data Protection Regulation 2019. Our lawful bases, retention periods, security measures, transfer arrangements and the rights of data subjects (including access, rectification, erasure, restriction, portability and objection) are described in our Privacy Policy. A Data Protection Officer is designated and reachable at [email protected].

9. Operating model. off ramp and treasury

Monica operates strictly as a one-way crypto to naira off ramp. Monica is not a custodian and does not hold Cryptocurrency for, or on behalf of, any customer.

When a customer sends Cryptocurrency to a Monica-issued deposit address, the deposit address is the inbound mechanism by which Monica recognises the Order. On confirmation of the deposit on the relevant blockchain, the Cryptocurrency is treated as sold to Monica at the conversion rate displayed at confirmation, and title passes to Monica's treasury. Monica's continuing obligation to the customer is the contractual obligation to pay the corresponding Naira amount to the customer's verified Nigerian bank account.

The operating model means:

• there is no customer-asset segregation requirement, because there is no customer asset on the platform after onchain confirmation;
• customers do not bear ongoing custody, key-management or rehypothecation risk in respect of their sold Cryptocurrency;
• treasury assets are managed within Monica's documented treasury risk-management framework and are not lent, staked or pledged in any manner that would prejudice Monica's ability to meet its Naira payment obligations to customers;
• in the event of Monica's insolvency, customer claims are contractual claims for Naira owed; customers have no in rem claim to any specific Cryptocurrency.

10. Tax compliance

Customers are responsible for understanding and meeting their own tax obligations under Nigerian law, including any capital-gains, personal income, value-added tax or other liabilities arising from cryptocurrency-related activity. Monica provides customers with downloadable transaction histories sufficient to support tax reporting. Monica complies with all applicable tax-reporting obligations imposed on it by the Federal Inland Revenue Service (FIRS) and state revenue services.

11. Consumer protection and complaints

Monica is committed to fair treatment of customers in line with the Federal Competition and Consumer Protection Commission (FCCPC) framework and SEC consumer-protection expectations. Complaints may be submitted in app, by email to [email protected], or by post to the registered office. Material complaints are tracked, escalated where appropriate to the Compliance Officer, and acknowledged within two (2) business days; substantive responses are issued within ten (10) business days save where a longer investigation is required and the customer has been notified.

12. Independent audits, security testing and oversight

Monica engages independent professional firms for the annual financial audit, periodic AML/CFT independent testing, and recurring penetration testing of in-scope systems. Findings are reviewed by the Board and tracked to remediation. Monica's internal control framework draws on the principles of ISO 27001 and SOC 2 although Monica does not represent that it currently holds either certification.

13. Cooperation with law-enforcement and regulators

Monica cooperates with lawful requests from the Nigerian Financial Intelligence Unit (NFIU), the Economic and Financial Crimes Commission (EFCC), the Nigeria Police Force, the Securities and Exchange Commission (SEC), the Central Bank of Nigeria (CBN), the Nigeria Data Protection Commission (NDPC), and equivalent foreign authorities acting through Mutual Legal Assistance Treaties or recognised channels.

Lawful requests for information, production of records, account freezing, or disclosure of customer data should be directed to:

Compliance Officer
Monica Technologies Limited
[email protected]
Lagos, Nigeria

To enable timely processing, please ensure the request is made on official letterhead, signed by an authorised officer, and accompanied by a copy of the underlying legal instrument. Monica acknowledges receipt of valid requests within two (2) business days.

14. Whistleblowing

Reports of suspected financial crime, regulatory breach, fraud, bribery, sanctions violation or any other serious wrongdoing involving Monica may be made confidentially to [email protected]. Reports may be made anonymously. Monica protects whistleblowers from retaliation in line with applicable Nigerian whistleblower protections.

15. Contact

Compliance Officer. Monica Technologies Limited
[email protected]
Lagos, Nigeria

General customer support: [email protected]