Anti-Money Laundering (AML) Policy

1.Introduction & Purpose

TrybePay is an intermediary payment company that facilitates both domestic and cross-border payments for small and large businesses, including traders who import goods from Dubai, China, UK, European countries and other African countries.

TrybePay is committed to:

• Preventing its platform from being used for money laundering, terrorist financing, or other illegal financial activities.
• Protecting the integrity of the Nigerian and international financial system.
• Complying with applicable laws and regulatory requirements.

This AML & KYC Policy outlines how TrybePay conducts due diligence, monitors transactions, and reports suspicious activities.

2.Regulatory Framework

This policy is guided by:

• The Money Laundering (Prevention and Prohibition) Act, 2022 (Nigeria)
• CBN AML/CFT Regulations
• Nigerian Financial Intelligence Unit (NFIU) Guidelines
• Financial Action Task Force (FATF) Recommendations
• AML/CTF requirements of our licensed banking and fintech partners

3.Scope

This policy applies to:

• All customers (individuals and businesses).
• All TrybePay services, including domestic transfers, cross-border remittances, and business payments.
• All employees, agents, and partners involved in handling transactions.

4.Know Your Customer (KYC) Requirements

4.1 Individual Customers (Traders / Personal Accounts)

Customers must provide:

• Valid government-issued ID (NIN, Passport, Driver's License, or Voter's Card)
• BVN (Bank Verification Number)
• Proof of address (utility bill or tenancy agreement not older than 3 months)
• Live selfie or biometric verification (where applicable)

4.2 Business / Corporate Customers

Businesses must provide:

• CAC Certificate / RC Number
• Tax Identification Number (TIN)
• Details and IDs of directors/beneficial owners
• Source of Inflow (proof of business operations and income): invoices, purchase orders, contracts, bank statements, trade licenses, or other documents showing the origin of funds being used in transactions
• Board resolution/authorization for account opening (if applicable)

4.3 Source of Inflow / Source of Funds

All customers must provide information on the origin of their funds to ensure legitimacy. This may include:

• For traders: invoices, purchase orders, or receipts for goods being imported/exported.
• For businesses: contracts, trade agreements, or bank statements showing business income.
• For individuals: evidence of employment, salary slips, or bank statements.

Where the source of inflow is unclear or inconsistent with the customer’s profile, the transaction will be subject to Enhanced Due Diligence (EDD) before approval.

4.4 Politically Exposed Persons (PEPs)

Customers identified as PEPs or related to PEPs are subject to Enhanced Due Diligence (EDD).

• Senior management approval is required before onboarding.
• Source of inflow must be independently verified for PEPs.

5.Risk-Based Approach

5.1 Standard Due Diligence (SDD)

Applied to:

• Domestic transfers of moderate value.
• SMEs with transparent and consistent activity.

5.2 Enhanced Due Diligence (EDD)

Applied when risk is higher, such as:

• Large international transactions (e.g., imports from Dubai).
• Customers with inconsistent or unusual transaction behavior.
• Transactions involving high-risk jurisdictions or industries.
• Customers with unclear or unverifiable source of inflow.

EDD may include:

• Additional verification documents.
• Proof of source of funds (invoices, contracts).
• Extra approval from the Compliance Officer.

6.Transaction Monitoring

TrybePay continuously monitors customer activity to detect and prevent suspicious behaviour. Monitoring includes:

• Automated alerts (via partner banks/fintechs) for red flags.
• Manual reviews by the Compliance Team.

Examples of red flags:

• Transactions inconsistent with customer profile.
• Splitting payments to avoid reporting thresholds (structuring).
• Third-party transactions without clear business purpose.
• Fast in-and-out fund movements (layering).

7.Reporting Obligations

• All suspicious transactions are reported to partner institutions and, where required, to the NFIU through Suspicious Transaction Reports (STRs).
• Employees are prohibited from "tipping off" customers about reports or investigations.

8.Record Keeping

• All customer KYC records and transaction data must be retained for a minimum of 5 years after the business relationship ends.
• Source of inflow documentation (e.g., invoices, contracts, bank statements) must also be retained for at least 5 years.
• Records must be securely stored and retrievable on request by regulators or partners.

9.Governance & Compliance Officer

• TrybePay will appoint a Compliance Officer / MLRO (Money Laundering Reporting Officer) responsible for implementing this policy.
• The Compliance Officer ensures communication with regulators and partner institutions.
• Staff must report suspicious activity to the Compliance Officer immediately.

10.Training

• All TrybePay staff will undergo AML/KYC training upon onboarding and at least once annually.
• Training will cover recognising suspicious activities, proper KYC procedures, and reporting obligations.

11.Sanctions & Screening

All customers and transactions will be screened against:

• CBN lists
• Nigerian government watchlists
• United Nations sanctions list
• OFAC (U.S.) list

Transactions involving sanctioned individuals, entities, or countries will be blocked and reported.

12.Policy Review

This AML & KYC Policy will be reviewed at least annually, or earlier if:

• New laws or regulations are introduced.
• TrybePay adds new services (e.g., wallets, FX, POS).
• Feedback from regulators or partners requires updates.