Anti-Money Laundering (AML) Policy

1. Regulatory Compliance

PayNest complies with:

• Money Laundering (Prohibition) Act, 2011 (as amended)
• Terrorism (Prevention) Act, 2011 (as amended)
• Central Bank of Nigeria (CBN) AML/CFT Regulations
• Nigerian Financial Intelligence Unit (NFIU) Guidelines

2. Customer Due Diligence (CDD)

We perform customer due diligence on all users through:

• Identity verification using BVN and government-issued ID
• Address verification for enhanced tier users
• Ongoing transaction monitoring
• Politically Exposed Persons (PEP) screening

3. Suspicious Activity Reporting

We monitor all transactions for suspicious patterns including:

• Unusually large transactions
• Structured transactions to avoid reporting thresholds
• Rapid buying and selling without economic purpose
• Transactions from high-risk jurisdictions

Suspicious activities are reported to the NFIU as required by law.

4. Record Keeping

We maintain records of all transactions and customer identification documents for a minimum of 5 years, as required by CBN regulations.

5. Prohibited Activities

The following are strictly prohibited on PayNest:

• Using stolen or fraudulently obtained gift cards
• Structuring transactions to avoid reporting limits
• Providing false or misleading KYC information
• Using the platform for money laundering or terrorist financing
• Creating multiple accounts to circumvent limits

6. Consequences of Violation

Violation of this AML Policy will result in:

• Immediate account suspension
• Forfeiture of pending transactions
• Reporting to relevant authorities (NFIU, EFCC, CBN)
• Potential criminal prosecution

7. Contact

For questions about our AML Policy, contact our Compliance Officer at compliance@paynest.ng.