Anti-Money Laundering Policy

CodeXtra Technologies Ltd maintains a zero-tolerance approach to money laundering, terrorist financing, corruption, and any other financial crime. We have implemented robust internal controls, procedures, and due-diligence measures designed to detect, prevent, and report suspicious activities.

All transactions processed through our platform are subject to continuous monitoring, and we retain full and accurate records of all transaction data in accordance with applicable regulatory requirements.

As part of our ongoing commitment to compliance, we require all customers to provide accurate, complete, and up-to-date information regarding their business activities, ownership structure, source of funds, and compliance status. We reserve the right to verify this information at any time.

You may not use our platform or services to facilitate any of the following activities:

• Money laundering, terrorist financing, or proliferation financing
• Corruption or bribery of any government official or public officer
• Unlicensed cryptocurrency dealings or unlicensed digital lending
• Disguising the source of illegally obtained funds
• Any activity that violates applicable sanctions or financial crime laws

We maintain real-time monitoring systems to detect unusual or suspicious transaction patterns. All transaction records are retained securely and are subject to audit by relevant authorities.

Customers are provided with dashboard access to monitor their transactions in real-time, and monthly reconciliation reports are available upon request. Suspicious activities are reported to the appropriate regulatory authorities in accordance with applicable law.

All personal and financial information collected in the course of our compliance obligations is treated with the utmost confidentiality. We implement appropriate technical and organizational measures to safeguard data against unauthorized access, breaches, or misuse, in full compliance with the Data Protection Act, 2012 (Act 843) and the Cybersecurity Act, 2020 (Act 1038).

We will not disclose your confidential information to third parties except as required by law, regulation, or competent authority, or where necessary for the provision of our services.

We reserve the right to suspend or terminate services immediately, without prior notice, where we reasonably suspect fraud, money laundering, terrorist financing, sanctions violations, or other financial crimes. We may also suspend services on short notice where necessary to mitigate material financial, operational, or reputational risk.

This AML Policy is governed by the laws of the Republic of Ghana. Any disputes arising from or related to compliance with this policy shall first be referred to our compliance team for resolution. If unresolved within thirty (30) days, disputes shall be referred to arbitration in accordance with the Alternative Dispute Resolution Act, 2010 (Act 798).

The language of arbitration shall be English, and the place of arbitration shall be Accra, Ghana. The arbitral tribunal shall be constituted by a sole arbitrator appointed by the Ghana Arbitration Centre in the absence of agreement by the parties.