1. Introduction
Payburse Financial Services Limited is committed to preventing money laundering, terrorist financing, and other financial crimes. This AML/KYC Policy outlines our procedures for customer due diligence, transaction monitoring, and regulatory compliance.
All employees, contractors, and users are required to comply with this policy.
2. Regulatory Framework
Our AML/KYC program complies with:
- Money Laundering (Prohibition) Act 2011 (as amended)
- Terrorism (Prevention) Act 2011 (as amended)
- Central Bank of Nigeria (CBN) AML/CFT Regulations
- Economic and Financial Crimes Commission (EFCC) Guidelines
- Financial Action Task Force (FATF) Recommendations
- Nigeria Data Protection Regulation (NDPR) 2019
3. KYC Requirements
3.1 Individual Accounts
To open an individual account, you must provide:
- Full Name: As it appears on government-issued ID
- Date of Birth: Must be 18 years or older
- Residential Address: Verifiable physical address
- Phone Number: Active Nigerian mobile number
- Email Address: Valid email for communication
- BVN (Bank Verification Number): Mandatory for all users
- Government-Issued ID: National ID, International Passport, or Driver's License
- Selfie/Liveness Check: For facial recognition verification
3.2 Business Accounts
Business accounts require additional documentation:
- Certificate of Incorporation (CAC)
- Tax Identification Number (TIN)
- Memorandum and Articles of Association
- Board Resolution authorizing account opening
- Identification of beneficial owners (owning 10% or more)
- Identification of authorized signatories
- Proof of business address
3.3 High-Risk Customers
Enhanced Due Diligence (EDD) is required for:
- Politically Exposed Persons (PEPs)
- High-net-worth individuals
- Businesses in high-risk industries (e.g., money services, casinos)
- Customers from high-risk jurisdictions
4. Verification Process
4.1 Automated Verification
We use AI-powered systems to verify:
- BVN against NIBSS database
- NIN against NIMC database
- Document authenticity (ID cards, passports)
- Facial recognition match
- Address verification via utility bills
4.2 Manual Review
Our compliance team manually reviews:
- Flagged or incomplete verifications
- High-value transactions (above ₦1,000,000)
- Suspicious activity patterns
- PEP and sanctions screening results
4.3 Verification Levels
- Level 1 (Basic): Email + Phone verification. Daily limit: ₦50,000
- Level 2 (Standard): BVN + ID verification. Daily limit: ₦500,000
- Level 3 (Enhanced): Full KYC + address verification. Daily limit: ₦5,000,000
- Level 4 (Business): Corporate KYC. No daily limit
5. Transaction Monitoring
We monitor all transactions in real-time using AI and rule-based systems to detect:
- Unusual Patterns: Sudden spikes in transaction volume or frequency
- Structuring: Multiple transactions just below reporting thresholds
- Round-Tripping: Funds moving in circles between accounts
- High-Risk Countries: Transactions involving sanctioned jurisdictions
- Velocity Checks: Too many transactions in a short period
- Mismatch: Transaction type inconsistent with customer profile
5.1 Reporting Thresholds
- Single transactions ≥ ₦5,000,000 are automatically flagged
- Cumulative daily transactions ≥ ₦10,000,000 trigger review
- Cash transactions ≥ ₦2,000,000 require additional documentation
6. Suspicious Activity Reporting
We are legally obligated to report suspicious transactions to:
- Nigerian Financial Intelligence Unit (NFIU)
- Economic and Financial Crimes Commission (EFCC)
- Central Bank of Nigeria (CBN)
6.1 Suspicious Indicators
We report transactions that involve:
- Funds from unknown or unverified sources
- Transactions with no apparent economic purpose
- Customers who refuse to provide information
- Use of multiple accounts to obscure fund sources
- Transactions linked to known criminal activity
6.2 Tipping Off
Important: We are prohibited by law from informing customers that we have filed a Suspicious Transaction Report (STR). Asking about STR filings may result in account suspension.
7. Record Keeping
We maintain records for a minimum of 5 years, including:
- Customer identification documents
- Transaction records and receipts
- Account opening forms
- Correspondence with customers
- Internal investigation reports
- STR filings and supporting documentation
Records are stored securely in encrypted databases and are accessible only to authorized personnel and regulators.
8. Sanctions Screening
We screen all customers and transactions against:
- United Nations Security Council Sanctions List
- Office of Foreign Assets Control (OFAC) List
- European Union Sanctions List
- Nigerian Government Sanctions List
- Interpol Wanted Persons List
Matches result in immediate account freeze and regulatory reporting.
9. Staff Training
All Payburse employees receive:
- Mandatory AML/CFT training upon hiring
- Annual refresher courses
- Updates on new regulations and typologies
- Role-specific compliance training
10. Contact
For AML/KYC inquiries, contact our Compliance Officer:
- Email: compliance@payburse.com
- Phone: +234 801 234 5678
- Address: 15 Admiralty Way, Lekki Phase 1, Lagos, Nigeria
To report suspicious activity: suspicious@payburse.com (confidential)