Effective date: 6 October 2026 Last updated: 6 October 2026 Version: 2.1 Applies to: the YOUNGESTG app, youngestgexchange.com, and every fiat and virtual-asset service offered on the YOUNGESTG app.
- Purpose and commitment
YOUNGESTG HOLDINGS LTD (“the Company”, “we”, “us”, or “YOUNGESTG”) provides cross-border money transfer, fiat exchange, balance holding, and virtual-asset services through the YOUNGESTG app and at youngestgexchange.com. These services can be misused for money laundering, terrorist financing, proliferation financing, sanctions evasion, fraud, and other financial crime.
This Anti-Money Laundering and Countering the Financing of Terrorism Policy (“Policy”) sets out the standards YOUNGESTG applies to prevent, detect, and report that misuse. It is published for customers, employees, and contractors.
We will not knowingly provide a service that facilitates financial crime. We may refuse, delay, restrict, freeze, or end a relationship where the law, this Policy, or our risk appetite requires it. We do not tip off a customer where doing so is prohibited.
This Policy is our public statement of controls. Internal procedures, risk assessments, and alert rules are kept separately and are not published.
- Scope
This Policy applies to:
every individual and business user of YOUNGESTG;
every product we offer, including fiat deposits, fiat payouts, currency exchange, remittance, transfers between YOUNGESTG users (including YGE Pay), virtual-asset deposits, swaps, trades, and withdrawals, and related wallet and quote features;
employees, directors, and contractors who perform work for YOUNGESTG;
every corridor in which a service is enabled, including Canada, Cameroon, Nigeria, and any other country we expressly support.
Viewing public rates does not create a business relationship. A business relationship begins when a person applies for an account or attempts to deposit, exchange, transfer, or withdraw value.
Some fiat payouts are completed through licensed payout partners. Those payouts remain subject to this Policy. YOUNGESTG remains responsible for the customer relationship and for the controls in this Policy.
- Definitions
In this Policy:
Money laundering means concealing, converting, transferring, or using property that comes from crime, including attempts and arrangements to do so.
Terrorist financing means providing or collecting funds or other property, by any means, with the intention or knowledge that they will be used for terrorism.
Proliferation financing means providing funds or financial services for the development or delivery of nuclear, chemical, or biological weapons, or their means of delivery, in breach of applicable law.
Customer due diligence (CDD) means identifying the customer, verifying that identity, understanding the purpose of the relationship, and identifying the beneficial owner of a legal entity.
Enhanced due diligence (EDD) means additional measures applied to higher-risk customers, products, or transactions.
Politically exposed person (PEP) means a person who holds, or has held, a prominent public function, and includes immediate family members and known close associates. A person may remain a PEP for at least twelve (12) months after leaving office, or longer where the risk remains.
Virtual asset means a digital representation of value that can be traded or transferred and used for payment or investment, including BTC, ETH, USDT, USDC, and any other asset YOUNGESTG enables. It does not include fiat currency.
Platform means the YOUNGESTG app and youngestgexchange.com.
Suspicious activity means activity that we know, suspect, or have reasonable grounds to suspect is related to money laundering, terrorist financing, sanctions evasion, fraud, or another crime, including an attempt.
- Regulatory framework
YOUNGESTG designs this program to meet the laws that apply to our activities. Depending on the service and the corridor, those standards include:
the Financial Action Task Force (FATF) Recommendations, including the risk-based approach, customer due diligence, the travel rule for virtual assets, and targeted financial sanctions;
Law No. 2016/012 of 12 July 2016 on the suppression of money laundering and the financing of terrorism in Cameroon, related CEMAC regulations, and the expectations of the National Agency for Financial Investigation (ANIF) and the Banking Commission of Central Africa (COBAC), where those rules apply to our activity;
the Money Laundering (Prevention and Prohibition) Act and related Nigerian Financial Intelligence Unit (NFIU) and Central Bank of Nigeria requirements, where we serve users or process payouts in Nigeria;
the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) and applicable Canadian expectations, where we serve users or process value in Canada;
United Nations Security Council sanctions, and other sanctions regimes we are required or have chosen to observe, including applicable lists administered by OFAC, the European Union, the United Kingdom, Canada, and relevant African authorities.
Authorisations that apply to a specific service are disclosed in the YOUNGESTG app or on youngestgexchange.com. This Policy does not add a licence we do not hold.
- Governance
The board, or the senior officer acting in its place, approves this Policy and YOUNGESTG’s risk appetite, and receives reports on material financial-crime issues.
The Compliance Officer owns day-to-day operation of the program, reviews escalations, decides whether a matter is reported to a financial intelligence unit, and is the point of contact for competent authorities.
No commercial target overrides a compliance decision to refuse or exit a customer.
Employees must escalate concerns immediately. Retaliation against a person who raises a concern in good faith is prohibited.
A material change to a product or corridor is reviewed for financial-crime risk before launch.
Compliance contact: compliance@youngestgexchange.com Telephone: +1 289 818 9980
- Risk-based approach
We assess risk at enterprise level and at customer level. The assessment considers:
customer type (individual, sole trader, or company) and, for an entity, ownership and control;
geography of the customer, the sender, the beneficiary, and the corridor;
product (cash-like payout, third-party payment, virtual-asset transfer, high-value remittance, or rapid in-and-out flow);
remote onboarding;
source of funds and expected activity;
sanctions, PEP, and adverse-media results.
Customers are rated low, medium, or high. The rating determines the information we collect, the limits we apply, and how often we review the relationship. We reassess the rating when activity changes or new information appears. Enterprise risk is reviewed at least annually, and after any material incident or new corridor.
- Customer acceptance
YOUNGESTG does not open or maintain:
anonymous, numbered, or fictitious accounts;
an account for a person who will not complete identity verification;
an account for a shell bank, or for an unlicensed person carrying on money transmission, virtual-asset exchange, or gambling as a business through YOUNGESTG;
a relationship we cannot monitor, or where the customer refuses to explain the purpose of the account or the source of funds;
a relationship with a person or entity on a sanctions list we screen, or located in a jurisdiction subject to comprehensive sanctions.
We may refuse an applicant without giving a reason where the law permits, including where an explanation would tip off a suspect.
Prohibited use
YOUNGESTG must not be used for, or to conceal:
fraud, scams, romance fraud, business-email compromise, or mule activity;
terrorist financing, proliferation financing, or sanctions evasion;
human trafficking, child exploitation, or sexual exploitation;
narcotics trafficking or illegal arms dealing;
ransomware, darknet-market proceeds, or stolen virtual assets;
use of mixers, tumblers, privacy coins we have not enabled, or other tools designed to hide the origin of funds;
unlicensed gambling, pyramid or Ponzi activity, or investment fraud;
tax evasion, or the movement of funds to defeat a court order;
any other activity that is illegal where the customer, YOUNGESTG, or the beneficiary is located.
A third-party payment is permitted only where the payer and the purpose are clear and consistent with the customer profile. We may require the invoice, contract, or relationship evidence before releasing a supplier payment, tuition payment, or family remittance.
- Customer due diligence
YOUNGESTG verifies every customer before that customer can transact. Verification is our control. We may repeat it at any time.
8.1 Individuals
Before a customer can deposit, exchange, transfer, or withdraw, we verify identity. Verification normally includes:
a valid government photo identity document (national identity card, passport, or driver’s licence);
a liveness or biometric check comparing the customer to the document;
full name, date of birth, nationality, residential address, mobile number, and email;
a tax or national identifier where the corridor requires it, such as a National Identification Number for Nigerian users;
a purpose-of-account and source-of-funds declaration.
Proof of address may be required at onboarding or before a limit increase. We may reject a document that is expired, altered, incomplete, or inconsistent with other data.
An unverified user may view rates only. An unverified user cannot transact.
8.2 Businesses
For a business account we collect, as applicable:
legal name, registration number, date and place of incorporation, and registered address;
constitutional documents and proof of registration;
identity of directors and persons with authority to operate the account;
identity of each ultimate beneficial owner holding 25% or more, and of any person who otherwise controls the entity;
nature of business, expected volumes, and principal counterparties;
where the business pays suppliers or receives trade proceeds, invoices or contracts on request.
We do not onboard a business whose beneficial ownership cannot be established.
8.3 Enhanced due diligence
We apply EDD where the risk is higher, including PEPs, higher-risk corridors, unusual ownership, adverse media, virtual-asset flows with weak provenance, or activity that does not match the stated profile. EDD may include source-of-funds and source-of-wealth evidence (payslips, bank statements, tax filings, sale contracts, or business records), senior approval, lower limits, and more frequent review.
8.4 Ongoing due diligence
We keep customer information under review and may ask for a refresh at any time. A customer who does not respond may be restricted until the review is complete. We screen customers at onboarding and on a continuing basis.
- Sanctions and PEP screening
We screen customers, beneficial owners, and, where the data is available, beneficiaries and counterparties against sanctions, PEP, and adverse-media data. We also analyse virtual-asset flows for exposure to illicit activity.
If a true match is confirmed on a sanctions list, we reject or freeze the relationship, block the relevant transaction, and report to the competent authority where required. A possible match is held until cleared. We do not inform the customer of a sanctions report where the law forbids it.
Jurisdictions subject to comprehensive or near-comprehensive sanctions are prohibited. These currently include the Democratic People’s Republic of Korea, Iran, Syria, Cuba, and the Crimea, Donetsk, Luhansk, Zaporizhzhia, and Kherson regions of Ukraine, together with any other territory added by a sanctions authority we observe. We may also refuse a jurisdiction we are not prepared to serve. The country list in the YOUNGESTG app is the operational list.
- Transaction monitoring
All deposits, exchanges, transfers, and withdrawals are subject to monitoring, calibrated to the customer’s profile. We look for, among other things:
activity inconsistent with the stated occupation, business, or expected volume;
rapid pass-through of fiat or virtual assets, with little economic purpose;
splitting transactions to stay under a limit or a reporting threshold;
multiple accounts, devices, or beneficiaries controlled by the same person;
third-party funding with no clear relationship;
payout to a new beneficiary immediately after a deposit;
virtual-asset exposure to sanctioned, darknet, fraud, or mixer-related addresses;
use of the service after a fraud report, chargeback, or law-enforcement enquiry.
An alert may lead to a request for information, a temporary hold, a limit reduction, rejection of the transfer, or an internal suspicious-activity case. A hold is a compliance measure, not a finding of guilt. We may refuse to complete a transfer until we are satisfied.
A deposit or withdrawal may be delayed, refused, or reported if review identifies risk.
- Travel rule and payment information
Where the law requires it, we collect and transmit originator and beneficiary information with a virtual-asset transfer. This can include name, account or wallet identifier, and address or another identifier. We may delay or reject a transfer if the required information is missing.
For a fiat remittance we collect the beneficiary name, destination account, country, and purpose of payment. The customer is responsible for the accuracy of beneficiary details. An error may be irreversible once paid out.
- Reporting
Staff and systems escalate internal suspicious-activity reports to the Compliance Officer. The Compliance Officer decides, independently of commercial staff, whether to file a suspicious transaction or activity report with the competent financial intelligence unit. That may be ANIF, the NFIU, FINTRAC, or another FIU, depending on the service and the legal nexus.
We also file currency, large-transaction, or other regulatory reports where a threshold law applies. Thresholds differ by country and are applied to the transfer we execute.
We cooperate with lawful requests from regulators, financial intelligence units, law enforcement, and courts. We may freeze or preserve value pending that process.
- Record keeping
We keep, for at least five (5) years after the transaction or the end of the relationship, whichever is later:
identification and verification records, including beneficial-ownership information;
account files and correspondence;
transaction records sufficient to reconstruct the transfer;
screening results, alert investigations, and reports made to authorities;
training and assurance records.
Where Cameroonian or CEMAC law, or another applicable law, requires a longer period, we keep the record for that longer period, commonly up to ten (10) years. Records are stored securely and produced to a competent authority on lawful request.
- Training and assurance
Staff in onboarding, operations, support, finance, and compliance receive financial-crime training at induction and at least annually. Training covers red flags for remittance and virtual assets, sanctions, tipping-off, and how to escalate.
The program is reviewed at least annually. Independent testing is arranged on a cycle proportionate to our size and risk. Findings are tracked to closure.
- What we expect from you
You agree to:
provide true, complete, and current information, and update it when it changes;
use the account only for yourself, or for the business you have registered with us;
explain the purpose of a payment and the source of funds when asked, and within the time we set;
not structure activity to avoid controls;
not allow another person to operate your account;
cooperate with a hold or an information request. Failure to cooperate is a reason to restrict or close the account.
- Consequences
We may refuse onboarding, impose limits, delay a transfer, return funds to source where lawful, freeze an account, file a report, or end the relationship. We may also preserve records after closure. Contractual consequences are set out in the Terms of Use.
- Review
This Policy is reviewed at least annually, and sooner if the law or our products change. The version on youngestgexchange.com is the current public version.
Approved for publication by the compliance function of YOUNGESTG HOLDINGS LTD. 6 October 2026
Contact: compliance@youngestgexchange.com Telephone: +1 289 818 9980