AML/CFT/CPF Policy

1. Introduction

NairaFlow is committed to maintaining a safe, secure and responsible digital financial services environment.

We maintain an Anti-Money Laundering, Combating the Financing of Terrorism and Countering Proliferation Financing (“AML/CFT/CPF”) framework designed to help prevent NairaFlow from being used for money laundering, terrorism financing, proliferation financing, fraud, sanctions evasion or other unlawful activities.

NairaFlow operates as a fintech and digital payment platform and is not a bank. Certain services may be provided through appropriately engaged third-party regulated or licensed providers.

This Policy explains, at a public level, the measures NairaFlow uses to identify, assess and manage financial crime risks.

This Policy should be read together with our Terms of Service, Privacy Policy, KYC requirements and other applicable policies.

2. Regulatory Framework

NairaFlow’s AML/CFT/CPF framework is designed with regard to applicable Nigerian laws, regulations, regulatory guidance and requirements relevant to our activities.

These may include, as applicable:

• Money Laundering (Prevention and Prohibition) Act, 2022
• Terrorism (Prevention and Prohibition) Act, 2022
• Nigerian Financial Intelligence Unit Act, 2018
• Applicable Central Bank of Nigeria requirements
• Applicable Nigerian Financial Intelligence Unit requirements
• Applicable EFCC and SCUML requirements
• Applicable sanctions and targeted financial sanctions requirements
• Other applicable laws, regulations, directives and regulatory guidance

NairaFlow will review and update its compliance framework as applicable requirements, products, services and risk exposures change.

3. Our Commitment

NairaFlow is committed to:

• Knowing and appropriately verifying our customers.
• Understanding customer activity and expected use of our services.
• Applying a risk-based approach to financial crime prevention.
• Monitoring transactions and account activity.
• Identifying unusual or potentially suspicious activity.
• Conducting appropriate sanctions and watchlist screening.
• Applying enhanced due diligence where necessary.
• Maintaining appropriate compliance records.
• Restricting or suspending activity where required.
• Cooperating with competent authorities where legally required.
• Protecting confidential compliance information.
• Maintaining appropriate compliance training and governance.
• Continuously improving our financial crime controls.

4. Risk-Based Approach

NairaFlow applies a risk-based approach to AML/CFT/CPF.

We may consider factors including:

• Customer identity and verification status
• Customer type and profile
• Nature and expected use of the account
• Transaction amounts and frequency
• Transaction patterns and velocity
• Products and services used
• Geographic exposure
• Counterparty information
• Sanctions and watchlist results
• Politically Exposed Person (PEP) status
• Source of funds or source of wealth where required
• Fraud indicators
• Unusual account behaviour
• Other relevant financial crime risk factors

Where increased risk is identified, NairaFlow may apply additional verification, monitoring or restrictions.

5. Customer Due Diligence and KYC

NairaFlow requires customers to complete appropriate identity verification before accessing services that require verification.

Depending on the service and applicable requirements, information may include:

• Full legal name
• Phone number
• Email address
• Date of birth where required
• National Identification Number (NIN)
• Bank Verification Number (BVN)
• Identity verification information
• Additional information required for higher-risk activities

NairaFlow may use appropriately engaged third-party verification providers to verify customer information.

Customers are responsible for providing accurate and current information.

Providing false, misleading, stolen or manipulated information may result in account restrictions, suspension or termination and may be escalated or reported where required.

6. Customer Verification Tiers

NairaFlow uses verification levels and transaction limits that may vary according to customer verification, product access, applicable requirements and risk controls.

Tier 1

Daily transaction limit: ₦50,000 Maximum account balance: ₦300,000

Tier 2

Daily transaction limit: ₦200,000 Maximum account balance: ₦500,000

Tier 3

Daily transaction limit: ₦5,000,000 Maximum account balance: No fixed maximum under the stated product tier

Higher limits or access to certain services may require additional verification.

All limits remain subject to applicable laws, regulatory requirements, provider restrictions, product rules, fraud controls and NairaFlow’s risk-management framework.

NairaFlow may apply lower limits where necessary.

7. Enhanced Due Diligence

NairaFlow may apply Enhanced Due Diligence (“EDD”) where a customer, transaction, product or relationship presents increased risk.

EDD may include:

• Additional identity verification
• Source-of-funds verification
• Source-of-wealth verification
• Additional documentation
• Verification of occupation or business activity
• Review of transaction purpose
• Increased transaction monitoring
• Additional screening
• Compliance approval or review

The level of additional information requested will depend on the circumstances and applicable requirements.

8. Politically Exposed Persons

NairaFlow may identify customers or relevant persons who qualify as Politically Exposed Persons (“PEPs”) under applicable requirements.

PEP status does not by itself mean that a customer has engaged in unlawful activity.

Where required, NairaFlow may apply enhanced due diligence and enhanced monitoring to PEP relationships.

9. Sanctions and Targeted Financial Sanctions

NairaFlow maintains controls designed to identify and manage applicable sanctions and targeted financial sanctions risks.

Where appropriate, screening may be conducted against relevant sanctions, terrorist-financing, proliferation-financing and other applicable watchlists.

Where a potential match is identified, NairaFlow may:

• Restrict or delay relevant activity
• Request additional information
• Conduct additional verification
• Escalate the matter for compliance review
• Prevent a transaction where legally required
• Restrict or freeze funds where legally required
• Notify or report to an appropriate authority where required

A potential screening match does not automatically establish that a customer or transaction is a confirmed match. Appropriate review may be conducted.

10. Transaction Monitoring

NairaFlow maintains transaction-monitoring controls designed to identify unusual or potentially suspicious activity.

Monitoring may consider:

• Transaction amount
• Transaction frequency
• Transaction velocity
• Changes in normal customer behaviour
• Attempts to circumvent transaction limits
• Rapid movement of funds
• Unusual inflows or outflows
• Repeated transaction patterns
• Beneficiary behaviour
• Account and device activity
• Suspicious funding patterns
• Activity inconsistent with customer information
• Other relevant risk indicators

Transaction monitoring may involve automated controls, manual reviews or a combination of both.

A monitoring alert does not automatically mean that a customer has committed an offence. Appropriate review may be conducted before further action is taken, subject to applicable requirements.

11. Suspicious Activity

Activity may be subject to further review where it appears inconsistent with a customer’s profile or presents potential financial crime concerns.

Examples may include:

• Unusual transaction patterns
• Attempts to circumvent transaction limits
• Rapid movement of funds without an apparent legitimate purpose
• Suspicious account relationships
• False or inconsistent identity information
• Attempts to bypass KYC requirements
• Suspicious sources of funds
• Suspected fraud
• Potential sanctions concerns
• Potential terrorism-financing concerns
• Potential proliferation-financing concerns
• Other activity that creates reasonable grounds for concern

These examples are not exhaustive.

12. Regulatory Reporting

Where NairaFlow identifies activity that is required to be reported under applicable law or regulatory requirements, the appropriate report may be submitted to the relevant competent authority.

This may include reporting to the Nigerian Financial Intelligence Unit (“NFIU”) where applicable.

NairaFlow will maintain appropriate procedures for identifying, reviewing and escalating potentially reportable activity.

NairaFlow will not disclose confidential regulatory reports or investigation information where such disclosure is prohibited by law.

13. Fraud Prevention

NairaFlow’s AML/CFT/CPF controls operate alongside our fraud-prevention and account-security controls.

We may monitor for indicators including:

• Account takeover
• Identity fraud
• Credential abuse
• Suspicious login behaviour
• Transaction manipulation
• Unusual device activity
• Social-engineering indicators
• Repeated authentication failures
• Suspicious account creation
• Other potentially fraudulent activity

Where necessary, transactions or accounts may be temporarily restricted while appropriate security or compliance checks are conducted.

14. Source of Funds and Source of Wealth

NairaFlow may request information concerning the source of funds or source of wealth where required by customer risk, transaction activity, product usage or applicable requirements.

Customers may be asked to provide reasonable supporting information.

Depending on the circumstances, this may include:

• Employment or income documentation
• Bank statements
• Business records
• Invoices
• Contracts
• Asset-sale documentation
• Tax or business records
• Other relevant supporting documents

Information requested will depend on the circumstances.

15. Account and Transaction Restrictions

NairaFlow may restrict, delay, reject, suspend or terminate an account or transaction where:

• Required KYC information cannot be verified
• Information provided appears false or misleading
• Financial crime risk is identified
• A sanctions concern is identified
• Fraud is suspected
• A customer attempts to circumvent controls
• The activity violates NairaFlow’s Terms of Service
• A provider restriction applies
• A competent authority requires action
• Applicable law requires action
• Continued activity presents unacceptable risk

Where legally permitted, NairaFlow may provide appropriate information regarding a restriction.

Certain investigation or regulatory information may remain confidential.

16. Restriction or Freezing of Funds

NairaFlow may restrict access to funds where required or permitted by:

• Applicable law
• A lawful order
• A competent regulatory or law-enforcement authority
• Applicable sanctions requirements
• Fraud or security controls
• Applicable provider compliance requirements

An internal compliance review does not by itself establish that a customer has committed a criminal offence.

17. Third-Party Providers

NairaFlow may work with appropriately engaged third-party providers for services including:

• Identity verification
• NIN/BVN verification
• AML screening
• Payment processing
• Virtual account services
• Transfers
• Bill payments
• Gift card services
• Other digital or financial services

NairaFlow expects relevant providers to maintain appropriate security and compliance controls consistent with their contractual and regulatory responsibilities.

Third-party providers do not remove the need for NairaFlow to maintain appropriate internal governance and oversight for activities within its control.

18. Compliance Governance

NairaFlow maintains compliance responsibilities appropriate to the size, nature and risk profile of its operations.

Management

Management provides oversight, resources and support for the AML/CFT/CPF framework.

Compliance

The compliance function is responsible for relevant activities including:

• Customer due diligence
• Risk assessment
• Transaction monitoring
• Screening
• Compliance reviews
• Suspicious activity escalation
• Regulatory reporting where applicable
• Record keeping
• Compliance training
• Policy maintenance

Operations

Operations personnel are expected to follow applicable KYC, transaction, fraud and compliance procedures and escalate unusual activity appropriately.

Employees and Contractors

Employees and contractors must comply with applicable financial crime controls and must not knowingly assist customers in circumventing compliance requirements.

19. Employee Training

Relevant NairaFlow personnel receive AML/CFT/CPF training appropriate to their responsibilities.

Training may cover:

• Money laundering
• Terrorism financing
• Proliferation financing
• Customer due diligence
• Enhanced due diligence
• Sanctions
• Transaction monitoring
• Fraud
• Suspicious activity
• Regulatory reporting
• Confidentiality
• Tipping-off risks
• Internal escalation procedures

Training may be updated when significant regulatory, operational or risk changes occur.

20. Record Keeping

NairaFlow maintains appropriate records relating to customer identification, verification, transactions, compliance reviews, monitoring and reporting in accordance with applicable requirements.

Records may include:

• Customer identification information
• Verification results
• Transaction records
• Compliance review records
• Risk assessments
• Screening results
• Investigation records
• Regulatory reports
• Training records
• Audit records

Records are protected using appropriate security and access controls.

Retention periods will follow applicable legal and regulatory requirements.

21. Confidentiality and Tipping-Off

AML/CFT/CPF investigations and regulatory reports may contain confidential information.

NairaFlow personnel must not improperly disclose information that could compromise a compliance investigation or regulatory process.

This may include:

• Suspicious transaction reports
• Internal investigation information
• Compliance alerts
• Regulatory requests
• Law-enforcement requests
• Confidential monitoring information

Information will be disclosed only where permitted or required by law.

22. Customer Responsibilities

Customers are expected to:

• Provide accurate information
• Keep account information current
• Complete required KYC
• Protect their account credentials
• Use their account lawfully
• Provide requested compliance information
• Not allow improper third-party use of their account
• Not circumvent transaction limits
• Not provide false documents
• Not use NairaFlow for unlawful purposes
• Promptly report suspected unauthorised activity

23. Financial Crime Risk Assessment

NairaFlow maintains a financial crime risk assessment appropriate to its business and activities.

The assessment may consider risks relating to:

• Customers
• Products
• Services
• Transactions
• Delivery channels
• Geographic exposure
• Technology
• Fraud
• Third-party providers
• Emerging financial crime threats

The risk assessment may be reviewed when significant changes occur, including new products, providers, payment rails, customer segments, transaction volumes, regulatory requirements or financial crime threats.

24. Independent Review and Testing

NairaFlow may conduct appropriate internal reviews, control testing, audits or independent assessments of its AML/CFT/CPF framework.

Where weaknesses are identified, appropriate remediation measures may be implemented.

25. Prohibited Activities

NairaFlow must not knowingly be used for:

• Money laundering
• Terrorism financing
• Proliferation financing
• Fraud
• Sanctions evasion
• Proceeds of crime
• Identity theft
• Account takeover
• Unlawful financial activity
• Other activities prohibited by applicable law

NairaFlow may take appropriate action where prohibited or suspicious activity is identified.

26. Policy Review

This Policy will be reviewed periodically and updated where necessary.

Updates may be made following:

• Changes in applicable law
• Regulatory guidance
• Changes to NairaFlow products or services
• New providers
• Changes in financial crime risks
• Audit or compliance findings
• Significant operational changes
• Emerging financial crime typologies

27. Contact

For AML/CFT/CPF compliance matters:

NairaFlow Compliance Team For compliance matters, use the support channels listed on this website.

For general customer support, customers should use NairaFlow’s designated support channels.

28. Important Notice

This Policy provides a public overview of NairaFlow’s AML/CFT/CPF framework.

Certain internal controls, monitoring rules, screening methodologies, detection thresholds, investigation procedures and security measures are not publicly disclosed because doing so could facilitate attempts to circumvent NairaFlow’s financial crime controls.

NairaFlow may apply additional controls or take additional measures where required by applicable law, regulation, contractual obligations, provider requirements or its risk-management framework.

NairaFlow does not represent itself as a bank.

Where services are provided through third-party regulated or licensed providers, those providers operate under their respective regulatory and contractual frameworks.

NairaFlow will continue to review and strengthen its AML/CFT/CPF framework as its services, operations and applicable requirements evolve.