1 Purpose & Scope
AfricSpend Ltd ("AfricSpend") is committed to maintaining the highest standards of integrity in its financial operations. This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy") sets out the framework through which AfricSpend:
- Prevents its platform from being used for money laundering, terrorism financing, or any other financial crime;
- Identifies and verifies the identity of all users before granting access to financial services;
- Detects, reports, and escalates suspicious transactions in accordance with Nigerian law;
- Maintains adequate records to satisfy regulatory and law enforcement requirements.
This policy applies to all users of AfricSpend's platform, all employees and contractors, and all transactions processed through our Services.
2 Regulatory Framework
AfricSpend operates in compliance with the following Nigerian and international regulatory standards:
- Money Laundering (Prevention and Prohibition) Act 2022 (Nigeria);
- Terrorism (Prevention and Prohibition) Act 2022 (Nigeria);
- Central Bank of Nigeria (CBN) AML/CFT Regulations;
- Nigerian Financial Intelligence Unit (NFIU) Guidelines;
- Financial Action Task Force (FATF) Recommendations on virtual assets and virtual asset service providers;
- Securities and Exchange Commission (SEC) Nigeria — digital asset regulations where applicable.
AfricSpend reviews and updates this policy periodically to reflect regulatory developments.
3 Customer Identification (KYC)
AfricSpend applies a risk-based approach to customer identification. All users must complete identity verification before transacting on the platform. Identity verification is conducted using approved third-party verification services in line with regulatory requirements.
As part of the KYC process, users are required to submit:
- Bank account verification — a valid Nigerian bank account linked to the user's legal name, confirmed via name-match verification;
- Government-issued photo ID — one of the following: National Identification Number (NIN) slip, National ID card, International passport, or Driver's licence;
- Selfie / liveness check — a real-time facial comparison to confirm the submitted ID matches the account holder;
- NIN verification — National Identity Number verified against the NIMC government database for higher-tier access;
- Personal information — full legal name, date of birth, residential address, email, and phone number.
4 KYC Verification Tiers
AfricSpend operates a tiered verification model to balance user accessibility with regulatory compliance:
- Tier 0 — Unverified: Email registration only. No financial transactions permitted. Account may view platform information only.
- Tier 1 — Bank Verified: Bank account verified with legal name match. Basic transaction limits apply. Deposits and limited withdrawals to own verified accounts enabled.
- Tier 2 — Identity Verified: Tier 1 + government-issued ID + biometric liveness check. Higher transaction limits apply, including withdrawals and transfers within defined daily thresholds.
- Tier 3 — Government Record Verified: Tier 2 + National Identity Number (NIN) verified against the NIMC government database. Highest transaction limits apply. Full platform access enabled.
Transaction limits for each tier are defined within the application and may be updated in line with regulatory guidance.
5 Enhanced Due Diligence (EDD)
AfricSpend applies enhanced due diligence in the following situations:
- Politically Exposed Persons (PEPs): Users identified as current or former senior public officials, their immediate family members, or close associates are subject to additional scrutiny, senior management approval, and enhanced transaction monitoring.
- High-risk jurisdictions: Transactions involving counterparties from FATF-listed high-risk or monitored jurisdictions require additional verification.
- Large or unusual transactions: Transactions that are disproportionate to a user's stated purpose or account history trigger a manual review.
- Complex transaction structures: Multiple rapid transfers designed to obscure the source of funds.
6 Transaction Monitoring
AfricSpend maintains automated and manual transaction monitoring systems to identify patterns that may indicate money laundering, terrorism financing, or fraud. Our monitoring systems flag:
- Unusually large transactions relative to a user's profile and history;
- Rapid successive deposits and withdrawals (structuring / smurfing);
- Transactions to or from high-risk cryptocurrency wallet addresses;
- Multiple accounts receiving transfers from a single source in a short period;
- Account activity inconsistent with the user's stated occupation or income level;
- Transactions originating from IP addresses associated with sanctioned jurisdictions or VPN services;
- Round-number transactions repeated in patterns indicative of layering.
Flagged transactions are reviewed by our compliance team. Accounts may be temporarily suspended pending investigation without prior notice where immediate risk is identified.
7 Suspicious Activity Reporting
AfricSpend is legally required to report suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) under the Money Laundering (Prevention and Prohibition) Act 2022. We file:
- Suspicious Transaction Reports (STRs) — where we have reasonable grounds to suspect that a transaction is related to money laundering, terrorism financing, or other financial crime;
- Currency Transaction Reports (CTRs) — for cash or cash-equivalent transactions above thresholds prescribed by the NFIU;
- Terrorist Financing Reports — where funds may be linked to designated terrorist entities.
AfricSpend reserves the right to freeze funds associated with a suspicious transaction pending investigation and/or instruction from a competent authority.
8 Prohibited Activities
The following activities are strictly prohibited on the AfricSpend platform and will result in immediate account termination and reporting to relevant authorities:
- Using AfricSpend to launder proceeds of crime or illegal activity;
- Providing funds or financial services to designated terrorist organisations or individuals;
- Using stolen, fraudulently obtained, or third-party payment credentials;
- Structuring transactions to evade reporting thresholds (smurfing);
- Creating multiple accounts to circumvent transaction limits or compliance controls;
- Using AfricSpend to facilitate ransomware payments, darknet market transactions, or Ponzi/pyramid schemes;
- Operating an unlicensed money service business through the AfricSpend platform;
- Using AfricSpend for unauthorised foreign exchange dealings or capital flight in violation of CBN regulations.
9 Sanctions Screening
AfricSpend screens all users and transactions against applicable sanctions lists, including:
- The Nigerian Sanctions List maintained by the Office of the National Security Adviser (ONSA);
- United Nations Security Council (UNSC) consolidated sanctions list;
- OFAC (U.S. Office of Foreign Assets Control) Specially Designated Nationals (SDN) list;
- EU consolidated sanctions list;
- FATF blacklisted and grey-listed jurisdictions.
Users or transactions matching a sanctions list entry will be blocked. Funds associated with sanctioned entities may be frozen pending regulatory guidance. AfricSpend will not process transactions involving individuals, entities, or jurisdictions subject to applicable sanctions.
10 Record Keeping
In accordance with Nigerian AML regulations, AfricSpend maintains records of:
- All user identity documents and KYC verification records — retained for a minimum of 5 years after the end of the business relationship;
- All transaction records, including amounts, dates, counterparties, and blockchain references — retained for a minimum of 5 years from the date of transaction;
- All suspicious transaction reports (STRs) and supporting investigation documentation — retained for a minimum of 5 years;
- Internal compliance audit logs and risk assessments.
These records are available to regulatory authorities and law enforcement upon lawful request. Records are stored securely with access restricted on a need-to-know basis.
11 Staff Training & Awareness
AfricSpend ensures that all employees and contractors who handle user data or financial transactions receive:
- Initial AML/KYC training upon onboarding;
- Periodic refresher training on regulatory updates and emerging typologies;
- Training on identifying red flags and escalation procedures;
- Awareness of legal obligations including tipping-off prohibitions and reporting duties.
12 Enforcement
Violation of this AML/KYC Policy may result in one or more of the following actions:
- Immediate account suspension — pending investigation;
- Permanent account termination — where a violation is confirmed;
- Fund restriction or forfeiture — where funds are linked to criminal activity;
- Reporting to authorities — including the NFIU, Nigerian Police Force Economic and Financial Crimes Commission (EFCC), or other relevant agencies;
- Civil or criminal referral — where evidence of criminal conduct exists.
AfricSpend cooperates fully with all lawful requests from regulatory bodies and law enforcement agencies.
13 Policy Review
This AML/KYC Policy is reviewed at least annually by AfricSpend's compliance function, or sooner where there is a material change in applicable law, regulatory guidance, or our risk profile. Updates will be published on this page with a revised effective date.
14 Contact & Reporting
If you have concerns about potential financial crime, suspicious activity, or compliance matters relating to AfricSpend, please contact our compliance team:
To report financial crime directly to Nigerian authorities, contact the NFIU at nfiu.gov.ng or the EFCC at efcc.gov.ng.