AML Policy

1. Policy Purpose
QUICKQUICK TECHNOLOGIES LTD (“the Company”) operates PayQuickQuick, a bill payment app, in full compliance with Nigerian anti-money laundering (AML) laws, including the Money Laundering (Prohibition) Act 2022, Central Bank of Nigeria (CBN) AML/CFT Regulations, and EFCC Guidelines. This policy ensures our platform is not used for illicit activities, including money laundering, terrorism financing, or fraud.

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2. Compliance Framework
– Regulatory Adherence: Full compliance with the Economic and Financial Crimes Commission (EFCC), CBN, and Nigerian Financial Intelligence Unit (NFIU).
– Risk-Based Approach: Regular risk assessments to identify vulnerabilities in user transactions, biller networks, and payment channels.
– Zero Tolerance: Strict prohibition of anonymous accounts, shell companies, or transactions lacking clear economic purpose.

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3. Customer Due Diligence (CDD)
– User Verification:
– Individuals: Valid government-issued ID (NIN, Driver’s License, International Passport), phone number, and address verification.
– Businesses: CAC registration documents, proof of address, and beneficial ownership disclosure.
– Enhanced Due Diligence (EDD): Triggered for:
– Transactions exceeding ₦5,000,000 (or equivalent in foreign currency).
– High-risk users (Politically Exposed Persons (PEPs), cross-border transactions).
– Suspicious activity patterns (e.g., rapid bulk payments without clear purpose).
– Ongoing Monitoring: AI-driven transaction tracking to flag anomalies (e.g., mismatched user profiles, round-number transfers).

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4. Transaction Monitoring & Reporting
– Threshold Alerts: Automatic flags for transactions exceeding ₦1,000,000 daily or ₦5,000,000 monthly.
– Suspicious Activity Reports (SARs): Mandatory reporting to NFIU within 24 hours of detecting unusual patterns (e.g., layering, structuring).
– Sanctions Screening: Real-time checks against UN Security Council, CBN, and EFCC sanctions lists.

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5. Record Keeping
– Retain user identification data, transaction records, and SARs for minimum 5 years post-account closure.
– Securely store records in encrypted databases accessible only to authorized AML personnel.

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6. Employee Training & Accountability
– Annual AML Training: Mandatory for all staff (customer support, developers, executives).
– Whistleblower Protections: Employees must report suspicious activity internally without fear of retaliation.
– Penalties: Termination and legal action for employees/contractors aiding money laundering.

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7. Third-Party Partnerships
– Biller Vetting: Verify legitimacy of all billers (e.g., DISCOs, CAC, telecoms) before integration.
– Audits: Annual third-party audits of AML controls by CBN-licensed firms.

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8. Technology & Tools
– AI Monitoring: Machine learning models detect high-risk transaction patterns.
– Geolocation Checks: Flag payments from IP addresses in high-risk jurisdictions.
– Biometric Authentication: Required for transactions above ₦500,000.

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9. Penalties for Non-Compliance
– User Accounts: Immediate suspension and reporting to EFCC for suspicious activity.
– Company Liability: Fines up to ₦25,000,000 or license revocation per CBN guidelines.

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10. Policy Review
Reviewed annually by the AML Compliance Officer and updated to reflect changes in Nigerian law or operational risks.

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AML Compliance Officer Contact:
Susan Otusanya | susanotusanya@gmail.com | 07062974098

QUICKQUICK TECHNOLOGIES LTD
“Committed to a secure, transparent financial ecosystem for Nigeria.”

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This policy is binding for all employees, contractors, and users of PayQuickQuick.