NILLAR
Compliance

KYC & AML Policy Summary

This document summarises how NillarPay identifies customers, monitors transactions, and complies with Nigeria's Anti-Money Laundering and Counter-Terrorism Financing laws.

Effective Date: June 2026|Governed by Nigerian Law|Product: NillarPay

Table of Contents

  1. 01Introduction & Regulatory Basis
  2. 02Customer Identification
  3. 03Customer Due Diligence (CDD)
  4. 04Ongoing Monitoring
  5. 05Suspicious Transaction Reporting
  6. 06Regulatory Cooperation
  7. 07Risk-Based Approach
  8. 08Politically Exposed Persons
  9. 09Sanctions Screening

1. Introduction and Regulatory Basis

Nillar Technology Limited is committed to full compliance with all applicable Nigerian laws and regulations governing Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF). This Policy Summary is provided for transparency and to inform our users of the compliance obligations that apply to their use of NillarPay.

1.1 Applicable Laws and Regulations

  • Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA).
  • Terrorism (Prevention and Prohibition) Act, 2022 (TPPA).
  • Central Bank of Nigeria (CBN) Know Your Customer (KYC) Regulations.
  • CBN Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Regulations, 2022.
  • CBN Regulatory Framework for Bank Verification Number (BVN) Operations.
  • Financial Action Task Force (FATF) Recommendations.
  • Nigerian Financial Intelligence Unit (NFIU) guidelines.

Our AML/CFT programme is overseen by our designated Compliance Officer and is reviewed at least annually to ensure continued regulatory compliance.

2. Customer Identification Procedures

Before providing Services, we collect and verify identifying information for every customer through a tiered KYC process:

2.1 Tier 1 — Basic Identification (Phone Verification)

  • Mobile phone number verified via OTP.
  • Name and date of birth collected.
  • Limited transaction limits apply (as prescribed by CBN).

2.2 Tier 2 — Standard Identification

  • BVN (Bank Verification Number) or NIN (National Identification Number) verified via NIBSS/NIMC.
  • Facial match verification (selfie vs. BVN/NIN photo).
  • Address information collected.
  • Standard transaction limits apply.

2.3 Tier 3 — Enhanced Identification

  • Government-issued photo ID verified (International Passport, National Driver's Licence, or Permanent Voter's Card).
  • Proof of address documentation (utility bill, bank statement).
  • Enhanced transaction limits apply.
KYC verification is performed through government-approved identity verification providers and directly with NIBSS and NIMC. We do not store your raw biometric data beyond the period required for verification.

3. Customer Due Diligence (CDD)

3.1 Standard CDD

Applied to all customers. Includes identity verification and understanding of the nature of expected account activity.

3.2 Enhanced Due Diligence (EDD)

Applied to higher-risk customers and situations, including:

  • Politically Exposed Persons (PEPs) and their close associates.
  • Non-resident Nigerians transacting in Nigeria.
  • Customers in high-risk business categories.
  • Accounts exhibiting unusual transaction patterns.
  • Customers flagged by third-party risk intelligence tools.

EDD involves collecting additional information, obtaining senior management approval, and conducting more frequent monitoring.

3.3 Simplified Due Diligence

Applied only in circumstances where risk is demonstrably low, as permitted by CBN guidelines.

4. Ongoing Transaction Monitoring

NillarPay monitors all transactions on an ongoing basis to detect suspicious patterns. Our monitoring system looks for:

  • Transactions inconsistent with a customer's profile or expected account activity.
  • Unusual velocity — a high number of transactions in a short period.
  • Structuring — breaking large transactions into smaller amounts to avoid reporting thresholds.
  • Dormant accounts that suddenly become active with large transactions.
  • Round-sum transactions with no clear economic purpose.
  • Transactions involving high-risk jurisdictions or sanctioned entities.
  • Multiple transactions to the same unfamiliar beneficiary in quick succession.

Flagged transactions are reviewed by our compliance team. We may temporarily hold transactions pending investigation and may contact you for clarification.

5. Suspicious Transaction Reporting (STR)

Under the Money Laundering (Prevention and Prohibition) Act 2022, we are legally required to report Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs) to the Nigerian Financial Intelligence Unit (NFIU) within the legally prescribed timeframes.

5.1 What Triggers an STR

  • Transactions that have no apparent lawful purpose.
  • Transactions inconsistent with the customer's known business or income.
  • Customer behaviour suggesting awareness that a transaction may be unlawful.
  • Attempts to circumvent reporting obligations.
  • Transactions linked to names, entities, or jurisdictions on sanction lists.

5.2 Tipping-Off Prohibition

We are legally prohibited from "tipping off" any person (including the account holder) that an STR has been submitted or that a money laundering investigation is underway. If your account is restricted as a result of an STR filing, we may not be able to provide the reason.

It is a criminal offence under Nigerian law to tip off a money laundering suspect. We are bound by strict confidentiality obligations regarding STR filings.

6. Regulatory Cooperation

NillarPay cooperates fully with all lawful requests from Nigerian regulatory and law enforcement authorities, including:

  • The Central Bank of Nigeria (CBN).
  • The Nigerian Financial Intelligence Unit (NFIU).
  • The Economic and Financial Crimes Commission (EFCC).
  • The Independent Corrupt Practices and Other Related Offences Commission (ICPC).
  • The Nigeria Police Force.
  • Courts of competent jurisdiction.

Upon receipt of a valid court order, subpoena, or official regulatory request, we will provide customer data and transaction records as required by law.

7. Risk-Based Approach

Our AML/CFT programme adopts a risk-based approach as recommended by the FATF and required by the CBN. We assign risk ratings to customers based on:

  • Geographic risk: Customer's location and the location of their counterparties.
  • Product/service risk: The types of transactions the customer performs.
  • Customer risk: Customer profile, occupation, source of funds, and PEP status.
  • Channel risk: Whether onboarding was face-to-face, agent-assisted, or fully digital.

Higher-risk customers are subject to enhanced controls, more frequent monitoring, and may have lower transaction limits until risk can be adequately mitigated.

8. Politically Exposed Persons (PEPs)

We apply Enhanced Due Diligence to customers identified as Politically Exposed Persons (PEPs) or their close associates and family members. A PEP is defined under Nigerian AML regulations as an individual who holds or has held a prominent public function, including:

  • Heads of state or government and senior politicians.
  • Senior government officials, judicial officers, and military officers.
  • Senior executives of state-owned enterprises.
  • Significant party officials.

Identifying as a PEP does not prevent you from opening a NillarPay account but does require senior management approval and ongoing enhanced monitoring.

9. Sanctions Screening

We screen all customers and transactions against applicable sanctions lists, including:

  • CBN/NFIU designated persons and entities list.
  • Nigerian Terrorism (Prevention and Prohibition) Act designated entities.
  • UN Security Council Consolidated Sanctions List.
  • Other internationally recognised sanctions lists as applicable.

Any match with a sanctions list will result in immediate account suspension and reporting to the relevant Nigerian authorities. Funds associated with sanctioned entities will be frozen as required by law.

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