AML & KYC policy.

Athena, operated by Artemis Ltd, is committed to preventing the use of its platform for money laundering, terrorist financing, fraud, sanctions evasion, and other unlawful activity.

This AML & KYC Policy explains how Athena verifies users, monitors activity, and responds to compliance risks.

Athena operates a tiered identity verification system.

Tier 1 verification may require:

• Full name
• Email address
• Phone number
• Date of birth
• Bank account information
• Residential address

Tier 2 verification may require:

• Occupation
• National Identification Number (NIN)

Tier 3 verification may require:

• Bank Verification Number (BVN)
• Facial biometric verification

Athena may request additional information at any time where necessary for compliance, fraud prevention, security, or risk management purposes.

Athena may review accounts, transactions, deposits, transfers, cashout activity, and account behavior to identify suspicious or unusual activity.

Reviews may be conducted automatically, manually, or through a combination of both methods.

Users may be asked to provide additional information before certain actions are approved or completed.

Athena prohibits the use of its services for:

• Money laundering
• Terrorist financing
• Fraud
• Identity theft
• Sanctions evasion
• Stolen funds
• Unauthorized account access
• Illegal marketplaces
• Any activity prohibited by applicable law

Accounts involved in prohibited activity may be restricted, suspended, or terminated.

Athena may place temporary holds or restrictions on accounts, balances, transfers, or cashout requests where necessary to:

• Protect users
• Investigate suspicious activity
• Prevent fraud
• Comply with legal obligations
• Respond to lawful requests from courts, regulators, or law enforcement agencies

Holds may remain in place until the relevant review has been completed.

Athena reserves the right to restrict or terminate access to its services where required by applicable sanctions laws, court orders, regulatory directives, or other legal obligations.

Athena may refuse to process transactions that present sanctions, compliance, or legal risks.

Athena may retain identity verification records, transaction records, account information, and compliance-related documentation for up to five years after account closure or as otherwise required by law, court order, regulatory obligation, or legal process.

Athena may cooperate with courts, regulators, law enforcement agencies, and other competent authorities where required by law.

Information may be disclosed where necessary to comply with legal obligations, court orders, lawful regulatory requests, or ongoing investigations.

Athena may update this AML & KYC Policy from time to time.

Material changes may be communicated through the Platform or by other appropriate means.

Questions regarding this AML & KYC Policy may be directed to hello@myathena.app.