VIBES TECHNOLOGY LTD
ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING POLICY
Address: 90, Allen Avenue, Ikeja, Lagos, Nigeria
Gaming License: Online Casino Category, issued by the Lagos State Lotteries and Gaming Authority (LSLGA), License No. LSLGA/OP/OCAS/7KB030925, valid until 02 September 2026.
Date of Issue: 20th of January 2026
Policy Drafted and Approved by: Legal and Compliance teams.
Version: 01.
Table of content
- Purpose
- Regulatory Framework
- Integration with International AML and CFT Standards
- Application of Nigerian Legislation
- Money Laundering (Prevention and Prohibition) Act, 2022
- Terrorism (Prevention and Prohibition) Act
- Economic and Financial Crimes Commission Act
- Lagos State Lotteries and Gaming Authority Regulations
- Governance Structure and Compliance Team Activities
- Risk-Based Approach
- The Bettor as the Subject of the Policy
- Bet Analysis and Corruption Prevention
- Cryptoassets and Enhanced Controls
- Reporting of Suspicious Transactions
- Recordkeeping, Audit and Data Retention
- Legal Effect and Review
1. Purpose
The purpose of this Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) policy is to establish a clear framework for the identification, prevention, and reporting of potential money laundering (ML) and terrorist financing (TF) activities within Vibes Technology Ltd in compliance with the relevant laws and regulations of Nigeria, including the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism Prevention and Prohibition Act, 2022 and the Central Bank of Nigeria (CBN) Regulations.
Vibes Technology Ltd is committed to ensuring that its operations are free from involvement in any financial crimes, including but not limited to money laundering and the financing of terrorism. This policy is designed to mitigate the risks of the company being used as a vehicle for such illicit activities, promote transparency, and maintain the integrity of the gaming industry in Nigeria.
This Policy constitutes a mandatory compliance instrument with international AML and CFT standards and with the applicable legislation of the Federal Republic of Nigeria, forming an integral part of the Company’s governance, integrity and compliance framework.
2. Regulatory Framework
Vibes Technology Ltd acknowledges its legal obligations under the applicable laws and regulations in Nigeria governing Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) and commits to operating in full compliance with these frameworks.
As an operator licensed by the Lagos State Lotteries and Gaming Authority, the Company is legally required to adopt effective controls for the prevention of money laundering and terrorism financing, due to the inherent risk associated with gaming and betting activities, as recognized by both Nigerian authorities and international regulatory bodies.
Failure to comply with the obligations set forth herein may result in administrative, civil and criminal sanctions, including license suspension, monetary penalties and personal liability of directors, officers and employees.
3. Integration with International AML and CFT Standards
Vibes Technology Ltd is committed to maintaining the highest standards of compliance with international norms and practices regarding Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT).
The structure of this Policy reflects the Recommendations of the Financial Action Task Force (FATF), requiring gaming operators to adopt a risk-based approach, conduct customer identification, monitor transactions, and report suspicious activities.
The United Nations Conventions against Transnational Organized Crime and the Financing of Terrorism underpin this Policy.
4. Application of Nigerian Legislation
This Policy has been drafted in strict compliance with Nigerian laws, including:
Money Laundering (Prevention and Prohibition) Act 2022:
Customer due diligence, suspicious transaction reporting, and record keeping.
Terrorism Prevention and Prohibition Act, 2022:
Monitoring and reporting of terrorism financing.
Central Bank of Nigeria (CBN) AML/CFT Guidelines:
Customer identification, transaction monitoring and reporting to NFIU.
Economic and Financial Crimes Commission Act:
Full cooperation with EFCC investigations.
Lagos State Lotteries and Gaming Authority Regulations:
Maintenance of integrity, transparency and internal control.
5. Governance Structure and Compliance Team Activities
The Company maintains an independent compliance team responsible for:
• Validating KYC and due diligence processes
• Monitoring transactions and betting behavior
• Assessing ML/TF risks
• Account suspension or termination
• Reporting to authorities
• Training staff annually
6. Risk-Based Approach
The Company adopts a Risk-Based Approach (RBA) including:
• Customer risk assessment
• Transaction monitoring
• Enhanced due diligence
• Reporting to NFIU
• Ongoing review of risks
Risk factors include bettor profile, transaction volume, crypto usage and geographic origin.
7. The Bettor as the Subject of the Policy
All bettors are subject to AML controls. The Company may:
• Request documentation
• Restrict or suspend accounts
• Cancel transactions
• Terminate relationships
These measures are legal obligations.
8. Bet Analysis and Corruption Prevention
The Company monitors betting behavior to detect:
• Abnormal patterns
• High-volume low-risk bets
• Financial circulation behavior
• Match-fixing indicators
Employees are trained to identify suspicious activity.
9. Cryptoassets and Enhanced Controls
Enhanced monitoring applies to crypto transactions, including:
• Wallet analysis
• Transaction tracing
• Risk scoring
• Internal audits
10. Reporting of Suspicious Transactions
Suspicious activities are reported to the Nigerian authorities without notifying the bettor.
Monitoring systems are reviewed regularly for effectiveness.
11. Record-Keeping, Audit and Retention
The Company maintains records for a minimum of five (5) years, including:
• Customer data
• Transactions
• Compliance reports
Records are available for audits and regulatory review.
12. Legal Effect and Review
This Policy is legally binding on all employees, contractors and partners.
Failure to comply may result in disciplinary or legal action.
The Policy is reviewed periodically to ensure compliance with Nigerian law and international standards.