Effective Date: July 20, 2023
Last Updated: May 26, 2026
Approved by: Chiagozie Flavius Ejiofor (CEO)
1. Introduction
This policy outlines the approach of PowerPay to ensure compliance with the Anti-Money Laundering (AML) regulations as mandated by Nigerian law, including the Money Laundering (Prevention and Prohibition) Act, 2022 and other applicable international standards such as the Financial Action Task Force (FATF) guidelines. PowerPay is committed to preventing the use of its services for money laundering and the financing of terrorism.
The purpose of this policy is to:
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Detect and prevent the use of PowerPay’s services for illegal purposes.
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Establish procedures for identifying suspicious activities.
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Ensure compliance with regulatory requirements.
2. Scope
This AML policy applies to all employees, agents, contractors, and directors of PowerPay. It covers all products, services, and transactions provided by PowerPay and extends to all customers, whether individuals or businesses.
3. Roles and Responsibilities
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AML Compliance Officer: The Board of Directors shall appoint an AML Compliance Officer responsible for the implementation, supervision, and enforcement of this policy. The officer will report directly to senior management and the Board.
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Employees: All employees are required to adhere to this policy and report any suspicious activities to the AML Compliance Officer.
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Management: Senior management is responsible for ensuring the policy is implemented effectively across the organization.
4. Customer Due Diligence (CDD) and Know Your Customer (KYC)
PowerPay shall conduct due diligence to verify the identity of all customers before establishing a business relationship. The process includes:
Basic KYC: Customers must provide the following:
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Valid government-issued identification (e.g., National Identity Card, NIN, BVN).
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Proof of address (e.g., utility bill, bank statement).
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For corporate entities: business registration documents (Certificate of Incorporation, Memorandum & Articles of Association) and the names of directors and beneficial owners.
Enhanced Due Diligence (EDD): For high-risk customers, such as Politically Exposed Persons (PEPs), additional verification steps may include:
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Verification of the source of funds.
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Frequent and rigorous monitoring of account activity.
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Verification through external databases or third-party verification services.
PowerPay strictly prohibits the creation, maintenance, or processing of anonymous or fictitious accounts under any circumstances.
5. Transaction Monitoring
PowerPay will monitor customer transactions for unusual patterns that may indicate money laundering or terrorism financing. The following types of transactions will trigger review:
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Transactions that are significantly larger than typical transactions for that specific customer.
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Repeated transfers to or from high-risk jurisdictions.
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Transactions involving high-risk customers, including PEPs or sanctioned individuals.
An automated monitoring system will be used to flag suspicious activities, and flagged transactions will be reviewed by the AML Compliance Officer.
6. Reporting Suspicious Activities
All employees are required to report any suspicious transactions or behavior to the AML Compliance Officer immediately. The AML Compliance Officer will:
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Investigate the report securely.
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File a Suspicious Activity Report (SAR) with the Nigerian Financial Intelligence Unit (NFIU) if necessary.
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Maintain strict confidentiality of the reporting process.
PowerPay will not disclose to the customer that a SAR has been filed (“tipping off”), in compliance with national statutory mandates.
7. Record-Keeping
PowerPay will maintain records of customer identification (KYC), transaction data, and communications for a minimum of five years after the conclusion of the business relationship or the completion of a transaction. These records must be readily accessible to the relevant authorities and regulators, such as the Central Bank of Nigeria (CBN) and the NFIU.
8. Employee Training
PowerPay will provide ongoing AML training to all employees. This training will include understanding of money laundering risks and typologies, recognizing suspicious transactions and activities, and standard reporting procedures. New hires must undergo AML training as part of their onboarding process, and all employees will participate in annual refresher courses.
9. Internal Controls and Audits
PowerPay will implement robust internal controls to monitor adherence to this AML policy, including regular audits of transaction data and independent reviews of the effectiveness of policy procedures. PowerPay will also engage external auditors to assess the adequacy of its AML controls periodically.
10. Penalties for Non-Compliance
Non-compliance with this AML policy may result in internal disciplinary action (including termination of employment) and immediate reporting to regulatory authorities, which may result in statutory penalties or legal action. PowerPay takes violations of its AML policy seriously and will cooperate fully with law enforcement and regulatory agencies.
11. Data Protection and Confidentiality
PowerPay is committed to safeguarding customer data in accordance with the Nigeria Data Protection Act (NDPA) 2023. All personal and transactional data collected under this AML policy will be handled confidentially and securely, and shared only with authorized law enforcement or regulatory parties as strictly required by law.
12. Approval and Review
This AML policy has been formally approved by the Board of Directors of ODDVPN TECHNOLOGY LIMITED and will be reviewed annually to ensure compliance with evolving regulations and international fintech best practices.