Anti-Money Laundering (AML) Policy

Introduction

Faveremit is committed to maintaining the highest standards of integrity and transparency in its operations. As a financial services provider offering virtual card generation, trading of gift cards, utility payment, electricity, internet services, and betting platform funding, we recognize the critical importance of preventing money laundering, terrorist financing, and other illicit activities. This Anti-Money Laundering (AML) Policy outlines our commitment to compliance with all relevant laws and regulations in Nigeria, including the Money Laundering (Prohibition) Act, 2011 (as amended), and any subsequent updates to applicable legislation.

2. Objectives

• To ensure compliance with all applicable AML laws and regulations in Nigeria.
• To prevent the use of Faveremit’s platform for money laundering or terrorist financing activities.
• To identify, mitigate, and manage risks associated with money laundering and other illicit financial activities
• To establish a framework for reporting suspicious activities to relevant authorities.

3. Scope

This policy applies to all Faveremit employees, agents, consultants, and third-party service providers. It covers all products and services provided by Faveremit, including but not limited to:

• Virtual card generation.
• Buying and selling of gift cards.
• Funding of betting platforms.
• Foreign exchange transactions (USD to Naira and vice versa).

4. Regulatory Framework

Faveremit’s AML Policy aligns with the following Nigerian laws and regulations:

• Money Laundering (Prohibition) Act, 2011 (as amended).
• Central Bank of Nigeria (CBN) AML/CFT Regulations.
• Economic and Financial Crimes Commission (EFCC) guidelines.
• Nigerian Financial Intelligence Unit (NFIU) reporting requirements.
• Terrorism (Prevention) Act, 2011 (as amended).

5. Key Principles

Faveremit’s AML Policy aligns with the following Nigerian laws and regulations:

• 5.1. Customer Due Diligence (CDD):

  Faveremit adopts a risk-based approach to customer due diligence, which includes:

  • Verifying the identity of all customers using valid identification documents (e.g., NIN and BVN)
  • Verifying the source of funds where applicable.
  • Conducting Enhanced Due Diligence (EDD) for high-risk customers and transactions.
• 5.2. Know Your Customer (KYC):

  All customers must complete KYC procedures before accessing Faveremit’s services. This includes:

  • Personal details: Full name, address, date of birth, phone number, and email address.
  • Verification of identity through government-issued IDs.
  • Proof of address through utility bills or bank statements.
• Record Keeping:

  Faveremit maintains accurate records of all customer transactions, KYC documentation, and communications for a minimum of five (5) years, in compliance with Nigerian law.

• 5.4. Transaction Monitoring:

  We monitor transactions for unusual or suspicious activities, including:

  • Transactions inconsistent with a customer’s profile.
  • Large or repetitive transactions.
  • Transactions involving high-risk countries or jurisdictions.

6. Reporting Suspicious Activities

Faveremit complies with all requirements to report suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) and other relevant authorities. Suspicious Transaction Reports (STRs) will be filed promptly where necessary.

7. Prohibited Activities

Faveremit strictly prohibits:

• Transactions involving proceeds of crime.
• Transactions intended to finance terrorism.
• Transactions with sanctioned individuals or entities.
• Misrepresentation or falsification of information by customers.

8. Training and Awareness

Faveremit provides regular AML training to all employees and relevant stakeholders to ensure:

• Awareness of AML regulations and obligations.
• Understanding of red flags and how to identify suspicious activities.
• Proper implementation of CDD, KYC, and reporting procedures.

9. Internal Controls and Audit

Faveremit has implemented robust internal controls to detect and prevent money laundering. These include:

• Periodic risk assessments.
• Regular independent audits of AML processes.
• Appointment of a Compliance Officer responsible for overseeing AML activities.

10. Governance

Faveremit’s Board of Directors oversees the implementation of this AML Policy. The Compliance Officer reports directly to the Board on all AML matters and ensures the policy remains up to date with regulatory changes.

11. Penalties for Non-Compliance

Non-compliance with this policy will result in disciplinary action, including termination of employment or business relationships. Violations of AML laws may also lead to legal consequences, including fines and imprisonment, as prescribed under Nigerian law.

12. Review and Updates

This policy is reviewed annually or as required to ensure compliance with regulatory changes and operational needs.

13. Contact Information

For questions regarding this policy or to report suspicious activities, please contact our Compliance Officer at support@faveremit.com

14. Conclusion

Faveremit is dedicated to ensuring a secure and compliant environment for all its users. By adhering to this AML Policy, we aim to protect our customers, partners, and stakeholders from the risks associated with financial crimes.