Anti-Money Laundering (AML) Policy

1. Purpose

This Anti-Money Laundering (AML) Policy establishes the framework by which DataGifting detects, prevents, and reports money laundering and terrorist financing activities on our platform. All users, agents, and staff are bound by this policy.

2. Know Your Customer (KYC) Requirements

We require identity verification before users can access certain services or exceed transaction thresholds. Accepted identity documents include:

• National Identification Number (NIN) / NIN slip
• Bank Verification Number (BVN)
• Valid government-issued photo ID (National ID card, Driver's licence, International passport, Voter's card)
• Proof of address (utility bill or bank statement not older than 3 months)

3. Customer Due Diligence (CDD)

We apply a risk-based approach to CDD:

• Simplified CDD: for low-risk transactions below regulatory thresholds
• Standard CDD: full identity and address verification for regular users
• Enhanced CDD: for high-value transactions, politically exposed persons (PEPs), or users from high-risk jurisdictions

4. Transaction Monitoring

Our platform implements automated monitoring for:

• Unusual transaction patterns or volumes inconsistent with a user's profile
• Rapid succession of large transactions designed to evade reporting thresholds (structuring)
• Transactions involving jurisdictions subject to FATF blacklists or Nigerian sanctions
• Multiple accounts sharing a device, IP address, or bank account

5. Suspicious Activity Reporting (SAR)

Where a transaction or user behaviour raises reasonable suspicion of money laundering or terrorist financing, we are legally obligated to file a Suspicious Transaction Report (STR) with the Nigerian Financial Intelligence Unit (NFIU). We will not "tip off" the subject of such a report.

6. Record Keeping

We retain all customer identification records, transaction records, and STR filings for a minimum of 5 years from the date of the transaction or account closure, in line with CBN AML/CFT Regulations.

7. Prohibited Persons & Entities

We will not onboard or process transactions for persons or entities that are:

• Subject to UN, OFAC, EU, or Nigerian government sanctions
• Listed as designated terrorists or persons of concern
• Shell companies with no identifiable beneficial owner

8. Employee & Agent Training

All agents and relevant staff receive AML/CFT awareness training. Failure to comply with this policy may result in account termination and reporting to authorities.

9. Non-Compliance Consequences

Users found to be in breach of this policy — including providing false identity documents or conducting structured transactions — will have their accounts immediately suspended, funds frozen pending investigation, and the matter reported to relevant law enforcement and regulatory authorities.

10. Contact

For compliance-related enquiries, contact our compliance team via the WhatsApp support button or live chat on our homepage.