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.

Objectives

The primary objectives of this AML Policy are to:

• Prevent the use of Faveremit's platform for money laundering or terrorist financing activities.
• Detect, deter, and report suspicious transactions and activities.
• Ensure compliance with all applicable AML/CFT laws and regulations in Nigeria and internationally.
• Protect Faveremit's reputation by operating suspicious activities to relevant authorities.
• Educate employees and stakeholders about AML compliance.

Scope

This policy applies to all Faveremit employees, agents, consultants, and third-party service providers. It covers all transactions conducted via the Faveremit platform, including but not limited to:

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

Regulatory Framework

Faveremit's AML Policy is designed in compliance with the following Nigerian laws and regulations:

• Money Laundering (Prohibition) Act, 2011 (as amended).
• Central Bank of Nigeria (CBN) AML/CFT Guidelines.
• Economic and Financial Crimes Commission (EFCC) regulations.
• Financial Action Task Force (FATF) recommendations.
• Terrorism (Prevention) Act, 2011 (as amended).

Key Principles

Faveremit's AML compliance program is built on the following Nigerian laws and regulations:

Customer Due Diligence (CDD)

Faveremit implements a robust CDD process to verify customer identities and assess risks. The CDD measures include:

Know Your Customer (KYC)

Faveremit's KYC process ensures compliance with regulatory requirements. Customers must provide:

• Full name and date of birth.
• Valid government-issued ID (BVN, NIN, or International Passport).
• Proof of address (utility bill, bank statement).
• Phone number and email address.
• Selfie or biometric verification (where applicable).

Record Keeping

Faveremit maintains comprehensive records of all customer transactions, KYC documentation, and compliance activities. Records are retained for a minimum of five (5) years as required by Nigerian law and include:

• Customer identification documents.
• Transaction histories and receipts.
• Reports of suspicious activities.
• Correspondence with regulatory authorities.

Transaction Monitoring

Faveremit employs automated and manual systems to monitor transactions for unusual or suspicious activity. Red flags that trigger further investigation include:

• Transactions inconsistent with a customer's profile.
• Large or repetitive transactions.
• Transactions involving high-risk countries.
• Attempts to avoid reporting thresholds (structuring).

Reporting Suspicious Activities

Faveremit is committed to reporting suspicious transactions to the relevant authorities. Employees must report any activity that raises concerns about money laundering or terrorist financing, regardless of the transaction amount. Reports are submitted to:

• Nigerian Financial Intelligence Unit (NFIU).
• Economic and Financial Crimes Commission (EFCC), where necessary.

Prohibited Activities

Faveremit strictly prohibits the following activities:

• Engaging in or facilitating money laundering or terrorist financing.
• Conducting transactions with individuals or entities on sanctions lists.
• Processing payments for illegal goods or services.
• Structuring transactions to evade reporting requirements.
• Providing services to customers who fail to complete KYC verification.

Training and Awareness

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

• AML regulations and obligations.
• Identification of suspicious transactions and red flags.
• Procedures for reporting suspicious activities.
• Consequences of non-compliance.

Internal Controls and Audit

Faveremit has established internal controls to detect and prevent money laundering, including:

• Regular compliance audits.
• Periodic risk assessments.
• Review and updates to AML processes.
• Designation of a compliance officer responsible for overseeing AML activities.

Governance

Faveremit's Board of Directors oversees the implementation of this AML Policy. The Compliance Officer is responsible for ensuring adherence to AML regulations and serves as the primary contact for regulatory matters. Senior management is responsible for fostering a culture of compliance within the organization.

Penalties for Non-Compliance

Non-compliance with this AML Policy may result in disciplinary action, including termination of employment. Violations of AML laws may also lead to legal consequences, including fines, imprisonment, and reputational damage for Faveremit.

Review and Updates

This AML Policy will be reviewed periodically to ensure compliance with regulatory changes and evolving risks. Updates will be communicated to all stakeholders.

Contact Information

For questions, concerns, or to report suspicious activities, please contact our Compliance Officer at:

• Email: compliance@faveremit.com
• Phone: +234 [Insert Phone Number]
• Website: www.faveremit.com

Conclusion

Faveremit is dedicated to fostering a secure and compliant environment for all its users. By adhering to this AML Policy, we contribute to the global effort to combat money laundering and terrorist financing. We appreciate your cooperation in helping us maintain these high standards and protecting our platform.