Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy
Effective Date: 2023-10-30
1. Introduction
Padlock.ng is dedicated to maintaining the highest standards of integrity, transparency, and compliance with Nigerian anti-money laundering (AML) regulations. This policy outlines our commitment to preventing and detecting money laundering activities, and it establishes the role of the Economic and Financial Crimes Commission (EFCC) as our designated AML Compliance Officer.
2. Definitions
Buyer: The party utilizing Padlock.ng's escrow services for the purpose of purchasing goods or services.
Seller: The party utilizing Padlock.ng's escrow services to facilitate the sale of goods or services.
Broker: An intermediary entity engaged in transactions conducted through Padlock.ng's platform.
EFCC: The Economic and Financial Crimes Commission, designated as the AML Compliance Officer for Padlock.ng
3. Customer Due Diligence (CDD)
Padlock.ng is committed to conducting thorough Customer Due Diligence (CDD) for all customers, including buyers, sellers, and brokers, as mandated by Nigerian law. This process involves verifying the identity of customers and gaining an understanding of the nature and purpose of their transactions.
4. Suspicious Activity Reporting
Padlock.ng insists on a proactive approach to reporting any suspicious transactions or activities by its employees, customers, and business partners. Suspicious activities may encompass transactions of unusual size, frequency, or complexity, or those originating from or involving high-risk jurisdictions. All reports are to be promptly submitted to the EFCC.
5. Transaction Monitoring
Padlock.ng will maintain robust transaction monitoring systems to detect and assess unusual or potentially suspicious patterns. Records of all transactions, along with the identities of parties involved, will be retained. Any transactions arousing suspicion will be escalated to the EFCC.
6. Record Keeping
Padlock.ng will retain customer information, transaction data, and records of reported suspicious activity for a minimum of five years. These records will be made readily accessible for inspection by the EFCC and other relevant regulatory authorities.
7. Training and Awareness
Padlock.ng is committed to ensuring that all its employees receive regular training on AML and KYC procedures, enabling them to recognize and report suspicious activities in a timely and efficient manner.
8. Communication with EFCC
Padlock.ng will maintain open and transparent communication channels with the EFCC to facilitate the exchange of pertinent information and updates regarding AML regulations and industry best practices.
9. Sanctions and Cooperation
Padlock.ng reserves the right to take appropriate actions, including the termination of customer accounts, in cases of money laundering or illicit activities. We are fully committed to cooperating with law enforcement agencies and the EFCC in any investigation.
10. Regular Review
This AML and KYC policy will be subjected to periodic review, at least annually, or as necessitated by amendments to Nigerian regulations and laws.
11. Compliance Officer
The EFCC has been designated as Padlock.ng's AML Compliance Officer. All concerns, reports, or queries pertaining to AML and KYC should be directed to this authority.
12. Conclusion
Padlock.ng is dedicated to upholding the highest standards of AML and KYC compliance and will work in close collaboration with the EFCC and other relevant authorities to ensure the integrity of our escrow services.