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Anti-Money Laundering & Countering the Financing of Terrorism (AML/CFT) Policy

Last updated: 25 July 2026

Darangi Solutions & Consult ("we", "us", or "our") is a B2B software development company registered in Nigeria. We operate darangisolutionsandconsult.com and develop software products including GymCore (gymcore.tech), a gym membership and payment management platform. This policy sets out our commitment and approach to preventing our products and services from being used for money laundering, terrorism financing, or other financial crime.

1. Policy statement

We are committed to full compliance with applicable Nigerian AML/CFT laws and regulations, including:

  • The Money Laundering (Prevention and Prohibition) Act, 2022
  • The Terrorism (Prevention and Prohibition) Act, 2022
  • The Central Bank of Nigeria (CBN) AML/CFT/CPF Regulations
  • Guidelines and directives issued by the Nigerian Financial Intelligence Unit (NFIU) and other relevant authorities

We have zero tolerance for money laundering, terrorism financing, and proliferation financing, and we will not knowingly conduct business with any person or entity engaged in such activities.

2. Scope

This policy applies to all directors, employees, and contractors of Darangi Solutions & Consult, and to all products and services we operate, including GymCore.

3. Our business and payment model

We do not hold, custody, or transmit customer funds. All payment transactions on our platforms are processed by licensed Payment Service Providers regulated by the Central Bank of Nigeria (including Paystack and Fincra), which maintain their own AML/CFT programmes, KYC verification, and transaction monitoring. On GymCore, gym member payments are settled directly to the gym's dedicated bank account via the payment provider; we receive only transaction confirmations and limited metadata.

4. Risk-based approach

We apply a risk-based approach to identifying, assessing, and mitigating money laundering and terrorism financing risks arising from our customers, products, delivery channels, and geographic exposure. Given our B2B model and the fact that funds flow through regulated payment providers, our inherent risk exposure is limited, but we remain vigilant and review our risk assessment periodically.

5. Customer due diligence (KYC/KYB)

Before onboarding a business customer (e.g. a gym owner or operator onto GymCore), we take reasonable steps to:

  • Verify the identity of the business and its authorised representative (name, contact details, and, where applicable, business registration details)
  • Confirm that the business has a legitimate, lawful purpose consistent with our services
  • Ensure that settlement bank accounts are held in the name of the business or its verified owner, verified through our licensed payment providers' KYC processes

We do not onboard anonymous customers, shell entities, or customers who refuse to provide required identification information. Enhanced due diligence is applied where a customer presents higher risk, including politically exposed persons (PEPs).

6. Sanctions screening

We will not knowingly provide services to individuals or entities on applicable sanctions lists, including the Nigerian Sanctions List and United Nations Security Council consolidated lists. Our payment providers additionally screen transactions and counterparties as part of their regulatory obligations.

7. Transaction monitoring

We monitor activity on our platforms for unusual patterns, including transactions inconsistent with a customer's known business profile, attempts to use our services for purposes other than those intended, and other red flags. Suspicious activity is escalated internally for review and appropriate action, which may include suspension or termination of the account.

8. Suspicious transaction reporting

Where we know or suspect that funds or activity are related to money laundering or terrorism financing, we will report to the Nigerian Financial Intelligence Unit (NFIU) and cooperate with law enforcement and regulatory authorities as required by law. We prohibit "tipping off" — employees must not disclose to a customer that a report has been or may be filed.

9. Record keeping

We retain customer identification records, transaction records, and related documentation for a minimum of five (5) years after the end of the business relationship or the date of the transaction, whichever is later, in line with the Money Laundering (Prevention and Prohibition) Act, 2022.

10. Compliance responsibility

A designated compliance officer is responsible for implementing this policy, maintaining our risk assessment, handling internal escalations, filing reports where required, and serving as the point of contact for regulators and payment partners on AML/CFT matters.

11. Training

All relevant staff receive AML/CFT awareness training on onboarding and periodically thereafter, covering their obligations under this policy, common red flags, and escalation procedures.

12. Prohibited activities

Our services must not be used to process payments for illegal goods or services, or in connection with fraud, money laundering, terrorism financing, or sanctions evasion. We reserve the right to refuse, suspend, or terminate service to any customer suspected of such activity, consistent with our Terms of Service.

13. Review of this policy

This policy is reviewed at least annually, or sooner if there are material changes to our business, products, or the regulatory environment. Updates will be posted on this page with a revised date.

14. Contact

Darangi Solutions & Consult
House A-V10, Behind Galaxy International School, Eastern Bypass Road, Minna, Niger State, Nigeria
hello@darangisolutionsandconsult.com

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