Anti-Money Laundering Policy

Our comprehensive framework to prevent money laundering, terrorist financing, and other financial crimes.

Last updated: January 1, 2025

Policy Statement

Payyng is committed to maintaining the highest standards of compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. This policy establishes our framework for preventing, detecting, and reporting suspicious financial activities in accordance with Nigerian financial regulations and international best practices.

Zero Tolerance: We maintain a zero-tolerance approach to money laundering, terrorist financing, and all forms of financial crime. Violations will result in immediate account suspension and reporting to relevant authorities.

Customer Due Diligence (CDD)

Identity Verification

All customers must provide valid government-issued identification including National ID, International Passport, or Driver's License. We verify these documents through secure third-party verification services.

Address Verification

Customers must provide proof of address through utility bills, bank statements, or official correspondence dated within the last 3 months.

Enhanced Due Diligence

For high-risk customers or transactions exceeding ₦1,000,000, we conduct enhanced due diligence including source of funds verification and additional documentation requirements.

Ongoing Monitoring

We continuously monitor customer transactions and behavior patterns to identify suspicious activities and ensure compliance with regulatory requirements.

Transaction Monitoring

Automated Monitoring Systems

Our advanced AI-powered systems monitor all transactions in real-time, analyzing patterns, amounts, frequencies, and counterparties to detect suspicious activities.

Transaction Limits

Daily transaction limits are enforced based on customer verification levels: Tier 1 (₦50,000), Tier 2 (₦500,000), Tier 3 (₦5,000,000). Transactions exceeding these limits require additional verification.

Red Flag Indicators

We monitor for structured transactions, unusual transaction patterns, transactions to high-risk jurisdictions, and other indicators as defined by regulatory guidelines.

Reporting Mechanisms

Suspicious transactions are automatically flagged and reported to our compliance team for investigation and potential reporting to relevant authorities within 24 hours.

Prohibited Activities

Money Laundering

Any attempt to disguise the source of illegally obtained funds through our platform is strictly prohibited and will result in immediate account suspension and reporting to authorities.

Terrorist Financing

We maintain zero tolerance for any activities related to terrorist financing. All transactions are screened against international sanctions lists and terrorist financing databases.

Fraud and Financial Crimes

We prohibit all forms of fraud, including identity theft, account takeover, payment fraud, and any other financial crimes. Violators will face account termination and legal action.

Sanctions Violations

Transactions involving sanctioned individuals, entities, or jurisdictions are strictly prohibited. We maintain comprehensive sanctions screening procedures.

Compliance Framework

Regulatory Compliance

We comply with all applicable Nigerian financial regulations including CBN guidelines, NFIU requirements, and international standards such as FATF recommendations.

Staff Training

All employees receive comprehensive AML training upon joining and annual refresher training to ensure awareness of latest threats and regulatory requirements.

Independent Audits

Our AML program undergoes regular independent audits by certified compliance professionals to ensure effectiveness and regulatory compliance.

Record Keeping

We maintain detailed records of all transactions, customer due diligence documentation, and compliance activities for a minimum of 7 years as required by regulations.

Risk Assessment Categories

L

Low Risk

Standard KYC, domestic transactions under ₦100,000, verified customers with consistent patterns

M

Medium Risk

Enhanced monitoring, transactions ₦100,000-₦1,000,000, new customers, cross-border payments

H

High Risk

Enhanced due diligence, transactions over ₦1,000,000, PEPs, high-risk jurisdictions

Reporting Channels

Internal Reporting

[email protected]

Report suspicious activities directly to our compliance team

Anonymous Hotline

+234 (0) 700 COMPLY

24/7 anonymous reporting hotline for whistleblowing

Regulatory Reporting

NFIU Portal

Automatic reporting to Nigerian Financial Intelligence Unit

Law Enforcement

EFCC / Police

Direct cooperation with law enforcement agencies

Customer Obligations

Provide accurate and complete information during account registration and verification

Promptly update personal information when changes occur

Cooperate with additional verification requests and compliance procedures

Report any unauthorized or suspicious activities on your account immediately

Ensure all transactions comply with applicable laws and regulations

AML Compliance Contact

For AML-related inquiries, compliance concerns, or to report suspicious activities:

Compliance Officer

[email protected]

Emergency Hotline

+234 (0) 700 COMPLY

Business Hours

24/7 Monitoring & Response

Response Time

Within 24 hours