1. Policy statement
Billturex operates a zero-tolerance policy against money laundering, terrorism financing, proliferation financing, and sanctions evasion. Our AML/CTF programme is aligned with the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention) Act, the Central Bank of Nigeria AML/CFT Regulations, and Financial Action Task Force (FATF) recommendations.
2. Governance
An appointed Money Laundering Reporting Officer (MLRO) oversees the programme, files Suspicious Activity Reports (SARs) with the NFIU where required, and reports to the board. Staff receive annual AML training and periodic refreshers.
3. Customer due diligence (CDD)
Every user completes identity verification proportionate to their transaction limits. Simplified CDD applies to Tier 1 accounts (low value). Standard CDD applies to Tier 2 (government-ID verified). Enhanced CDD applies to Tier 3 and to Politically Exposed Persons (PEPs), high-risk jurisdictions, and unusual account behaviour.
4. Ongoing monitoring
Transactions are monitored in real-time and post-facto against risk-based rules and typologies (structuring, layering, unusual velocity, mismatched geographies, sanctioned counterparties). Alerts are reviewed by trained analysts.
5. Sanctions screening
Customers are screened at onboarding and periodically thereafter against UN, EU, OFAC, UK HMT, and Nigerian sanctions lists. Confirmed matches result in account restriction and, where required, a report to the appropriate authority.
6. Record keeping
KYC documents, transaction records, and monitoring alerts are retained for at least five (5) years after account closure and made available to regulators on lawful request.
7. Cooperation with authorities
Billturex cooperates fully with lawful requests from the CBN, NFIU, EFCC, NDLEA, and comparable authorities in other jurisdictions, subject to due-process safeguards.
This document is informational and does not constitute legal advice. In case of conflict, the version filed with regulators prevails.