AML / CTF Compliance Manual

1. Introduction

1.1 Purpose

This Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Compliance Manual establishes the policies, procedures, and internal controls implemented by 91 Payments to prevent, detect, and report money laundering, terrorist financing, fraud, and other financial crimes.

The objective of this manual is to ensure compliance with applicable regulatory obligations and international financial crime prevention standards.

1.2 Regulatory Framework

91 Payments operates in compliance with regulatory frameworks administered by:

• Central Bank of Nigeria
• Financial Crimes Enforcement Network
• Financial Transactions and Reports Analysis Centre of Canada

The AML/CTF program is designed to align with international standards for financial crime prevention and regulatory compliance.

2. AML / CTF Policy Statement

91 Payments maintains a zero-tolerance policy toward financial crime.

The company is committed to:

• Preventing misuse of its services for illegal activities
• Maintaining robust customer verification procedures
• Monitoring transactions for suspicious behavior
• Reporting suspicious activities to regulatory authorities
• Cooperating with law enforcement agencies

All employees, contractors, and agents must comply with these policies.

3. AML Governance Structure

3.1 Compliance Officer

91 Payments' AML Compliance Officer is responsible for:

• Implementing the AML/CTF program
• Monitoring regulatory compliance
• Investigating suspicious transactions
• Filing regulatory reports
• Liaising with regulators and financial institutions

3.2 Responsibilities of the Compliance Officer

The Compliance Officer:

• Maintains AML policies and procedures
• Conducts risk assessments
• Ensures staff training
• Monitors transaction activity
• Maintains compliance records
• Reports suspicious activities where required

4. Risk-Based Approach

91 Payments applies a risk-based approach to AML compliance.

Risk factors include:

Customer Risk

• Politically exposed persons (PEPs)
• High net worth individuals
• Corporate structures with complex ownership

Geographic Risk

Higher risk jurisdictions may include:

• Sanctioned countries
• High corruption risk countries
• Countries with weak AML regulation

Transaction Risk

Indicators include:

• Unusual transaction patterns
• Large transfers inconsistent with customer profile
• Multiple rapid transfers

5. Customer Due Diligence (CDD)

5.1 Identity Verification Requirements

Before allowing transactions, 91 Payments will verify the identity of customers.

Information collected may include:

• Full legal name
• Date of birth
• Residential address
• Phone number
• Government-issued ID

5.2 Identity Documents

Acceptable documents may include:

• Passport
• National ID card
• Driver's license

Additional documents may be required for verification.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is required for higher-risk customers, including:

• Politically exposed persons (PEPs)
• Customers from high-risk jurisdictions
• High-value transactions

EDD measures may include:

• Additional identification documents
• Source of funds verification
• Increased transaction monitoring

7. Sanctions Screening

All customers and transactions must be screened against international sanctions lists.

These include sanctions programs issued by:

• United Nations
• OFAC (United States)
• United Kingdom sanctions authority
• European Union sanctions programs

Transactions involving sanctioned parties must be blocked.

8. Transaction Monitoring

91 Payments uses automated and manual monitoring systems to detect suspicious activity.

Indicators may include:

• Rapid transfers between multiple recipients
• Structuring transactions below reporting thresholds
• Transfers inconsistent with customer behavior

9. Suspicious Activity Reporting

When suspicious activity is identified, the Compliance Officer may submit reports to relevant authorities.

These reports may include:

• Suspicious Activity Reports (SARs)
• Suspicious Transaction Reports (STRs)

Reports are filed in accordance with applicable regulatory requirements.

10. Record Keeping

91 Payments retains customer records and transaction information for a minimum period required by applicable regulations. Typical retention period is 5–7 years.

Records maintained include:

• Customer identification records
• Transaction records
• Compliance reports

11. Employee Training

All employees must receive AML training upon hiring and periodically thereafter.

Training topics include:

• Money laundering typologies
• Suspicious activity identification
• Regulatory obligations
• Internal reporting procedures

12. Internal Reporting Procedures

Employees who identify suspicious activity must report it immediately to the Compliance Officer.

Internal reports must include:

• Customer details
• Transaction information
• Description of suspicious activity

13. Independent Audit

The AML program must undergo independent review or audit periodically to ensure effectiveness.

Audits may assess:

• Policy compliance
• Transaction monitoring effectiveness
• Reporting procedures

14. Data Protection

Customer data collected for AML compliance must be handled securely.

Security measures include:

• Encryption
• Secure storage
• Restricted access controls

15. Program Review

The AML/CTF program must be reviewed regularly to ensure continued effectiveness and compliance with regulatory requirements.