2.1 Central Bank of Nigeria (CBN) Regulations

• CBN Act, 2007
• Guidelines on Electronic Banking in Nigeria
• Guidelines on Point of Sale (POS) Card Acceptance Services
• Regulation on Card Issuance and Usage in Nigeria
• CBN Guidelines for Mobile Money Services in Nigeria
• Consumer Protection Framework
• Cash-less Policy requirements
• Foreign Exchange Regulations and Guidelines

2.2 Anti-Money Laundering and Counter-Financing of Terrorism

• Money Laundering (Prevention and Prohibition) Act 2022
• Terrorism (Prevention and Prohibition) Act 2022
• Nigeria Financial Intelligence Unit (NFIU) Regulations
• Economic and Financial Crimes Commission (EFCC) Guidelines
• Special Control Unit Against Money Laundering (SCUML) Requirements

2.3 Data Protection and Privacy

• Nigeria Data Protection Act (NDPA) 2023
• Nigeria Data Protection Regulation (NDPR) 2019
• Guidelines for Data Protection Compliance Audit
• Nigeria Data Protection Commission (NDPC) Directives

2.4 Other Applicable Laws and Regulations

• Companies and Allied Matters Act (CAMA) 2020
• Federal Competition and Consumer Protection (FCCPC) Act 2018
• Finance Act and Tax Regulations
• Cybercrime (Prohibition, Prevention, etc.) Act 2015
• Nigerian Communications Commission (NCC) Regulations

3.1 KYC Requirements

All customers must complete robust identity verification before accessing financial services. Our tiered KYC framework includes:

• Tier 1 (Basic): Phone number verification, BVN validation, basic personal information - Limited transaction amounts
• Tier 2 (Intermediate): Government-issued ID, facial verification, proof of address - Standard transaction limits
• Tier 3 (Full): Complete documentation, Enhanced Due Diligence, business verification for merchants - Maximum transaction limits

3.2 Enhanced Due Diligence (EDD)

We conduct Enhanced Due Diligence for:

• High-value transactions or account holders
• Politically Exposed Persons (PEPs) and their close associates
• Merchants with unusual transaction patterns
• Customers from high-risk jurisdictions
• Complex corporate structures or beneficial ownership arrangements
• Accounts flagged by transaction monitoring systems

3.3 Ongoing Customer Monitoring

• Periodic KYC reviews every 12-24 months depending on risk level
• Continuous screening against sanctions lists, PEP databases, and adverse media
• Real-time transaction monitoring for unusual activity
• Behavioral analytics to detect account takeover or fraud
• Mandatory re-verification upon significant changes (address, bank details, business structure)

4.1 AML/CFT Program

Our comprehensive AML/CFT program includes:

• Risk-based approach to customer and transaction risk assessment
• Automated transaction monitoring systems with configurable rules
• Sanctions screening against OFAC, UN, EU, and local lists
• Adverse media screening for reputational risk
• PEP identification and monitoring
• Suspicious Activity Report (SAR) procedures
• Currency Transaction Report (CTR) filing as required
• Regular AML/CFT training for all personnel

4.2 Suspicious Activity Detection and Reporting

We maintain vigilance for indicators of money laundering and terrorist financing, including:

• Structuring of transactions to avoid reporting thresholds
• Unusually large or frequent cash transactions
• Transactions inconsistent with customer profile or business
• Multiple accounts used by same individual without clear purpose
• Rapid movement of funds through accounts
• Customer reluctance to provide required documentation
• Geographic anomalies suggesting higher risk

Suspicious activity is reported to the Nigeria Financial Intelligence Unit (NFIU) within 48 hours of detection as required by law.

4.3 Record Keeping

• All KYC documentation retained for minimum 5 years after account closure
• Transaction records maintained for minimum 5 years
• AML/CFT investigation files retained for minimum 7 years
• SAR and CTR filings documented and archived
• Audit trails for all access to customer data and transaction records

5.1 Transparency and Disclosure

• Clear disclosure of all fees, charges, and transaction costs upfront
• Plain language Terms of Service accessible to all users
• Transaction confirmation and receipts provided immediately
• Monthly account statements available on demand
• Advance notice of fee changes (minimum 30 days)

5.2 Fair Treatment and Non-Discrimination

• Equal access to services regardless of ethnicity, religion, gender, or background
• Risk-based rather than discriminatory account restrictions
• Reasonable accommodations for customers with disabilities
• Multilingual customer support where feasible

5.3 Dispute Resolution

• Clear dispute resolution procedures accessible via customer support
• Investigation of customer complaints within 14 business days
• Escalation path to senior management for unresolved issues
• Cooperation with FCCPC and CBN consumer protection departments