We have no tolerance for money laundering, the financing of terrorism or any other form of illicit activity, and are committed to implementing appropriate policies, procedures and controls to prevent those activities. Our policies are shaped by industry best practices, a risk-based approach and the effective anti-money laundering standards applied in Nigeria, The United States of America, the European Union and worldwide. These policies apply, without exception, to all employees of Vella Technologies Inc, its Board Members and Directors, as well as to its subsidiaries.

The purpose of this is to provide Vella Technologies Clients, Providers, Partners, Vendors, Contractors, Employees, Law enforcement and other concerned stakeholders a high-level and summarized overview of Vella’s main AML/CTF policies and procedures.

This document and all underlying policies, processes and procedures are prepared in line with provisions, requirements and recommendations of:

• Money Laundering and Terrorist Financing Prevention Act, as amended from time to time;
• FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Assets Service Providers.

Vella operates from, and under the laws of Nigeria.

As a registered business, Vella is required to comply with the Money Laundering and Terrorist Financing Prevention Act and International Sanctions Act, which require Vella to identify and verify its clients’ identities appropriately, conduct ongoing monitoring of their activity (including transaction monitoring), maintain records of clients’ activity and related documents for at least six years and report suspicious transactions to authorities.

Vella understands Money Laundering as:

• The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;
• The concealment or disguise of the true nature, source, location, disposition, movement, and rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
• The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity;
• Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points above.

Vella understands Terrorist financing as:

• Provides funds for terrorist activity, meaning as the provision or collection of funds, by any means, directly or indirectly, with the intention that they are used or in the knowledge that they are to be used, in full or in part, in order to carry out any of the offences within the meaning of the law. This activity is done by intentionally killing, seriously harming or endangering a person, causing substantial property damage that is likely to seriously harm people or by seriously interfering with or disrupting essential services, facilities or systems.

Vella takes a risk-based approach (“RBA”) towards assessing and containing the money laundering and terrorist financing risks arising from any transactions it has with clients and uses all available data when reviewing client activity.

Vella performs risk-based due diligence and collects necessary information such as (name, date of birth, address, and ID) and documentation on each prospective client in order to assess the risk profile. Before entering into a client relationship, necessary checks are conducted in line with the RBA so as to ensure that the identity of the clients does not match with an entity with a known criminal background or with banned entities, such as terrorist organizations.

Enhanced due diligence is required for clients who are deemed to be of high risk, especially those for whom the business activity (sources of funds) are not clear, or for transactions of higher value and frequency, which can be determined by Vella at its sole and absolute discretion.

Vella’s employees exercise care, due diligence and good judgment in determining the overall profile and business nature of its clients. Vella conducts its business in accordance with the highest ethical standards and may decide not to enter into a client relationship that can adversely affect Vella’s reputation.

For the purpose of identification, assessment and analysis of risks related to its activities, Vella has established a risk assessment, taking account of the following factors:

• Client risk;
• Geographical risk;
• Product risk;
• Delivery channel risk.

After the risk is assessed and attributed to a particular client. Depending on the assigned degree of risk, it will be revised periodically upon knowledge of the client and its activities.

Vella requires all individual and business clients to undergo proper due diligence or Know Your Customer/Business (KYB/C) checks before using our services. This includes, without limitation:

• A high-resolution, clearly readable, non-expired, detailed and verifiable copy of the client incorporation document. This must include details on the ownership of the client business, its address, tax number, purpose and activities;
• A description of the sector and business activities and corresponding online website. The website must be registered under the same entity name as the certificate of incorporation provided;
• Details of the bank account of the Client.

Additionally, for any clients deem to be of high risk, the Identity Verification may include:

• A high-resolution, clearly readable, non-expired copy of the business beneficial owners’ government-issued ID or IDs (passport, national identity card and/or a driver’s license);
• A high-resolution, clearly readable, non-expired proof of address document not older than 3 months old. The document must carry the Client’s business name and address (recent utility bill or bank statement);
• A video conference with the account holder/business contact person and/or company Director(s), if deemed necessary.

Further documentation may be required for businesses operating in certain regulated, restricted or high-risk sectors of activity.

Care must be taken that all documents provided are true copies of the original. Providing false, forged, modified or documents meant to deceive will be considered fraud and treated as such.

All assets derived from fraudulent transactions and/or suspicious activity may be seized and forfeited. Such activity may also be reported to the relevant authorities.

Vella may use recognized and specialized electronic providers for the technical acquisition of identity data. Vella may also decide to use the following non-documentary methods of verifying identity:

• Independently verifying the Client’s identity through the comparison of information provided by the Client with information obtained from a consumer reporting agency, public database or other sources;
• Checking references with other institutions;
• Analyzing whether there is logical consistency between the identifying information provided, such as the Client’s name, street address, postal code, and date of birth;
• Utilizing complex device identification (such as “digital fingerprints” or IP geolocation checks); and
• Obtaining a notarized or certified true copy of an owner, manager, shareholder or UBO’s government-issued ID for valid identification.

terrorism financing activities, or where there shall be any doubt about the adequacy or veracity of previously obtained Clients’ identification data, further due diligence measures shall be undertaken, including verifying the identity of the Client again and obtaining information regarding the purpose and intended nature of the relationship with Vella.

The management board of Vella appointed a Compliance Officer, who acts as a contact person of the EFCC and FIU and performs the AML/CTF duties and obligations of Vella. A Compliance Officer reports directly to the management board and has the competence, means and access to relevant information across all the structural units of Vella.

Only a person who has the education, professional suitability, the abilities, personal qualities, experience and impeccable reputation required for the performance of the duties listed below may be appointed as a Compliance Officer. The appointment of a Compliance Officer is coordinated with the EFCC and FIU.

The duties of a Compliance Officer include, among others:

• The organisation of the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the activities of Vella;
• Reporting in the event of suspicion of money laundering or terrorist financing;
• Periodic submission of written statements on compliance with the requirements arising from the Act to the management board of Vella;
• Performance of other duties and obligations related to compliance with the requirements of Vella;
• Updating internal policy documents, and business and client risk assessments regularly.

Vella has developed and implemented rules of procedure that allow for effective mitigation and management of risks relating to money laundering and terrorist financing, which are identified in the risk assessment performed in accordance with Vella’s risk-based approach. Each employee of Vella must strictly adhere to the rules of procedure set forth herein.

The rules of procedure consist of the following:

• a procedure for the application of due diligence measures regarding a client, including a procedure for the application of simplified and enhanced due diligence measures;
• a model for identification and management of risks relating to a client and its activities and the determination of the client’s risk profile;
• the methodology and instructions where Vella has a suspicion of money laundering and terrorist financing or an unusual transaction or circumstance is involved as well as for instructions for performing the reporting obligation; the procedure for data retention and making data available;
• instructions for effectively identifying whether a person is a politically exposed person or a local politically exposed person subject to international sanctions.

Vella applies at least the following due diligence measures:

• Requests identification of the company based on documentation submitted by the Client;
• Requests identification of the company’s sector of activity, place of incorporation and public profile (where applicable);
• Verifies the company-related information and documentation submitted by the Client;
• Requests identification of the beneficial owner(s) at the proper tier level, for the purpose of verifying their identity, taking measures to the extent that allows the Company to make certain that it knows who the beneficial owner is, and understands the ownership and control structure of the client;
• Performing additional due diligence for the Client and its transactions, as necessary per established risk assessment policies and procedures;
• Maintains ongoing monitoring of the business relationship and transactions.

Vella may apply simplified due diligence (“SDD“) measures where a risk assessment prepared on the basis of these rules of procedure identifies that, in the case of the jurisdiction, economic sector of activity or amounts transacted the risk of money laundering or terrorist financing is lower than usual.

Before the application of SDD measures to a client, an employee of Vella establishes that the business relationship, transaction or act is of a lower risk and Vella attributes to the transaction, act or client a lower degree of risk.

The application of SDD measures is permitted to the extent that Vella ensures sufficient monitoring of transactions, acts and business relationships so that it would be possible to identify unusual transactions and allow for notifying of suspicious transactions in accordance with these rules of procedure.

Vella applies enhanced due diligence (“EDD“) measures in order to adequately manage and mitigate a higher-than-usual risk of money laundering and terrorist financing. EDD measures are applied always when:

Prior to client onboarding:

• Upon analysis of submitted client information and documents, there are reasonable doubts as to the truthfulness of the submitted data, authenticity of the documents or the true purpose of its business activities;
• The client is engaged in a sector or activity classified as high risk;
• The client is incorporated in a jurisdiction classified as high risk (eg: in jurisdictions that have not established effective AML/CTF systems that are in accordance with the recommendations of the Financial Action Task Force).

After client onboarding:

• When the client processed transactional volume exceeds the assigned risk threshold for the client;
• If unusual or suspicious patterns of activity are detected;
• If a transaction request is not consistent with a client’s stated business activity.

Vella also applies EDD measures whereas the assessment of risk is assessed as higher, in accordance with its internal policies and procedures.

We do not serve Clients from certain jurisdictions that are deemed too high-risk and/or unwelcoming from a legal or regulatory perspective.
While it’s beyond our scope to set policies for the client’s own business dealings, we reserve the right to not serve Clients who themselves have business activities, clients or otherwise accept purchases originating from certain jurisdictions.
It goes without saying that we can’t provide services to any client that isn’t legally established or is offering illegal goods or services in their operating jurisdiction(s). Besides this base consideration, we also cannot serve Clients who operate in certain restricted sectors.
Clients incorporated in non-serviced jurisdictions and from restricted sectors cannot access or be onboarded to use our services. Attempts to circumvent this policy, by providing false, forged or modified documents meant to deceive or mislead will be considered fraud and treated as such by law enforcement.

Politically Exposed Persons (“PEP“) (as well as their families and persons known to be close associates, as described below) are required to be subject to enhanced scrutiny by reporting entities. This is because international standards issued by the Financial Action Task Force recognize that a PEP may be in a position to abuse their public office for private gain and a PEP may use the financial system to launder the proceeds of this abuse of office.
PEP means a natural person who is or who has been entrusted with prominent public functions including:

• head of State;
• head of government;
• minister and deputy or assistant minister;
• a member of parliament or of a similar legislative body;
• a member of a governing body of a political party;
• a member of a supreme court;
• a member of a court of auditors or of the board of a central bank;
• an ambassador, a chargé d’affaires and a high-ranking officer in the armed forces;
• a member of an administrative, management or supervisory body of a State-owned enterprise;
• a director, deputy director and member of the board or equivalent function of an international organization.

PEPs do not include middle-ranking or more junior officials.
A family member of a PEP means the spouse, or a person considered to be equivalent to a spouse, of a PEP or local PEP; a child and their spouse, or a person considered to be equivalent to a spouse, of a PEP or local PEP; a parent of a PEP or local PEP.
A person known to be a close associate of a PEP means a natural person who is known to be the beneficial owner or to have joint beneficial ownership of a legal person or a legal arrangement, or any other close business relations, with a PEP or a local PEP; and a natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a PEP or local PEP.
While the company does not accept natural persons as clients, the PEP definition and classification still apply to the beneficial owners of the business and may constitute an additional factor of risk.

Dealing with persons against which imposed international sanctions poses a great risk to Vella, its directors, officers and owners. Vella may employ automated screening software to identify and block known virtual asset addresses associated with sanctions and numerous illegal and high-risk activities. Per its established policy, Vella does not do business with companies under sanctions. Sanction lists considered include, among others:

• EU Sanctions;
• UN Sanctions;
• Sanctions are administered by the Office of Foreign Assets Control (“OFAC-US”). All verified matches are automatically blocked and the matter escalated to a Compliance Officer for further analysis and appropriate actions.

An investigation into suspicious activity will try to establish the true motivation behind the activity in question. This may result in confirmation of the suspicious activity or removal of reasonable doubt. If suspicious activity is confirmed, the issue will be escalated accordingly both internally and externally. When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary.
Where Vella identifies an activity or facts whose characteristics refer to the use of criminal proceeds or terrorist financing or other criminal offences or an attempt thereof or with regard to which Vella suspects or knows that it constitutes money laundering or terrorist financing or the commission of another criminal offence, a Compliance Officer of Vella must report it to the FIU diligently.
When such suspicious activity is detected, the Compliance Officer will determine whether a filing with any law enforcement authority is necessary. Vella and all its employees, officers and directors are prohibited to inform a person, its beneficial owner, representative or third party about a report submitted on them to the FIU, an intention to submit such a report as well as about the commencement of criminal proceedings

Vella reserves the right to deny or terminate servicing a client or account at any time in line with the terms stipulated in the User Agreement if suspicion arises that a Client is involved with or connected with money laundering, criminal activity, terrorist financing or any other predicate offence to money laundering or terrorist financing.

Vella is obligated to retain all documents and information which served for identification and verification of the client, for a period of no less than 8 (eight) years after termination of the business relationship.
Vella implements necessary rules for the protection of personal data upon application of the requirements arising from its obligations hereunder.
Vella is allowed to process personal data gathered upon implementation of these rules only for the purpose of preventing money laundering and terrorist financing and the data must not be additionally processed in a manner that does not meet the purpose, for instance, for marketing purposes.

The Compliance Officer shall ensure that Company’s employees are fully aware of their legal obligations under the AML/CTF regime, by introducing a complete employees’ education and training program.
The timing and content of the training provided are determined according to the needs of Vella. The frequency of the training can vary depending on the amendments of legal and/or regulatory requirements, employees’ duties as well as any other changes in the business model. The training program aims at educating Vella’s employees on the latest developments in the prevention of money laundering and terrorist financing, including the practical methods and trends used for this purpose.

Vella is required to cooperate with supervisory and law enforcement authorities in preventing money laundering and terrorist financing, thereby communicating information available to Vella and replying to queries within a reasonable time, following the duties, obligations and restrictions arising from legislation. As part of its duties, as per applicable law and company policy, we are required to assist enforcement agencies’ requests. We comply with Law Enforcement requests for information where it pertains to specific preservation orders and fund freezing.
We will not and do not voluntarily disclose non-public information to a requesting party. In accordance with European Union privacy laws, Vella will only disclose non-public user information if it has received the consent of the user and in response to a legitimate and an enforceable subpoena, court order or search warrant from a body that has jurisdiction to compel Vella to disclose that information. Please note that in case you represent a law enforcement agency outside of the European Union, the procedure under the Mutual Legal Assistance Treaty (“MLAT”) may apply.
We take data protection and security seriously and encourage you to consult our Terms of Service for more information.
General Guidelines for Requests:

• When law enforcement agencies request non-public information (such as a client's personal or financial information), we will not share this information unless enforceable court order, subpoena or search warrant has been issued, received and validated as legitimate;
• We will notify affected clients if we believe we are legally required to provide their personal or financial information to a law enforcement agency unless we are prohibited by law from doing so;
• When law enforcement agencies request information about a client, we cannot and will not provide information about such client’s clients who are not our clients or platform users. We consider this information to be in the possession, control and custody of the client, who is the controller and processor of such information. If law enforcement agencies request this information, such requests for information should be directed to the relevant client and not us;
• Only information specifically requested and clearly outlined in an enforceable court order, subpoena or search warrant will be disclosed.

This policy does not constitute legal advice or a promise or guarantee that we will respond to any requests for information in a specific way, timeframe or at all. All legal requests for information are evaluated on a case-by-case basis. We reserve the right to change this policy or these guidelines at our sole discretion at any time.
When requesting the confirmation of the existence of data on our platform the law enforcement agency must be very specific about what information it is looking to obtain as we may not be able to respond to vague, ambiguous or blanket requests. Certain identifiers may be helpful in determining whether we currently retain the requested information.
Submitting a Request: