Anti-Money Laundering Policy

Anti-Money Laundering, Combating the Financing of Terrorism and Counter Proliferation Financing (AML/CFT/CPF). Public summary of the Policy of Ricardian Labs Ltd (RC 7947032), version 1.0, approved by the Board of Directors and effective 24 September 2026. Last updated 12 October 2026.

Milo will not be used to launder money, finance terrorism or proliferation, or evade sanctions. We comply with the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, the Central Bank of Nigeria's anti-money laundering regulations, and the rules of our licensed partners. This policy is part of our Terms and Conditions.

1. Knowing our customers

Every customer is identified before an account opens, as set out in our KYC and KYB Policy. No anonymous or fictitious accounts are opened, and no account is opened for one person in another's name.

2. Screening

Customers, and the people they pay where the information is available, are screened, through our own checks and those of our licensed partners, against Nigerian, United Nations and other applicable sanctions lists and lists of politically exposed persons, at sign-up and afterwards.

3. Monitoring

Every transaction is recorded in records that cannot be altered or deleted, and is checked automatically every hour. Activity that does not fit a customer's profile is reviewed, including unusual amounts, many transactions just under a limit, rapid movement of money in and straight out, payments with no clear purpose, and links to high-risk places or people.

4. Reporting

Suspicious transactions are reported to the Nigerian Financial Intelligence Unit, directly or through our licensed partners, as the law requires and within the time it sets. Cash and currency reports required by law are made. A customer is never told that a report has been made or is being considered.

5. Our right to act

Where we suspect money laundering, terrorism financing, fraud or a sanctions breach, we may without notice refuse, hold, delay or reverse a transaction, freeze or close an account, keep funds until the authorities or our partners direct otherwise, and give information to regulators, law enforcement and our partners. We are not liable for any loss that results.

6. Records

Customer identification and transaction records are kept for at least five years after the account closes or the transaction is completed, and longer where an investigation or the law requires.

7. Responsibility

The Board of Directors of Ricardian Labs Ltd approves this Policy and keeps ultimate responsibility for it. A Chief Compliance Officer, who is also the Money Laundering Reporting Officer, owns it day to day, files reports with the NFIU, reports directly to the Board and may restrict any account where there are grounds for suspicion. Staff are trained on appointment and every year. The Policy is independently reviewed at least once a year and on every material change to Milo's products or the law. Reports made in good faith are protected disclosures.

8. Your part

Use Milo only for lawful purposes and only for yourself or your own business. Give true details and answer our questions. Do not let anyone else use your account, PIN or device. Breaking this policy is a breach of our Terms and will be reported where the law requires.

Milo is a service of Ricardian Labs Ltd (RC 7947032), a private company limited by shares incorporated in Nigeria on 22 September 2024 under the Companies and Allied Matters Act 2020. Registered office: 5, Ladipo Latinwo Crescent, Lekki, Lagos State, Nigeria. Contact: support@milo.ng.

Terms · Privacy · KYC and KYB · AML/CFT/CPF