1. Introduction
Beezends Global Pay Services Limited (“BEEZENDS”) is committed to preventing the use of its financial technology platform for money laundering, terrorism financing, fraud, or other financial crimes.
This Anti-Money Laundering (AML) Policy establishes the framework through which BEEZENDS detects, prevents, and reports suspicious financial activities in compliance with the regulations of the Central Bank of Nigeria (CBN), the Money Laundering (Prevention and Prohibition) Act, Nigeria Financial Intelligence Unit (NFIU) guidelines, and international Financial Action Task Force (FATF) recommendations.
This policy applies to all employees, contractors, partners, merchants, and users of the BEEZENDS platform.
2. Objectives of the AML Policy
- Prevent the use of BEEZENDS services for money laundering or terrorist financing
- Ensure compliance with Nigerian financial regulations
- Implement robust Know Your Customer (KYC) and Know Your Business (KYB) procedures
- Monitor financial transactions for suspicious activity
- Report suspicious transactions to appropriate authorities
- Protect the integrity of the BEEZENDS financial ecosystem
3. Scope
This policy applies to all services offered by BEEZENDS including:
- Digital wallet services
- Peer-to-peer transfers
- Merchant payments
- POS and agent banking services
- QR code payments
- Ride-hailing payments (CitiCabz)
- Marketplace payments (EasyBuyz)
- Business wallet transactions
4. AML Governance Structure
Board Oversight
The Board of Directors provides strategic oversight for AML compliance and risk management.
Compliance Officer
BEEZENDS appoints a Chief Compliance Officer responsible for AML policy enforcement, regulatory liaison, suspicious activity reporting, and compliance monitoring.
AML Compliance Team
The AML team performs transaction monitoring, risk analysis, suspicious activity investigations, and regulatory reporting.
5. Customer Due Diligence (CDD)
Individual Users (KYC)
Users must provide full legal name, phone number, email address, valid government ID, biometric verification, and BVN or NIN where required.
Business Accounts (KYB)
Business accounts must provide CAC registration number, business registration documents, tax identification number, directors’ identification documents, and business address verification.
6. Risk-Based Customer Classification
Customers are classified based on risk levels:
Low Risk – Verified individuals with normal transaction activity.
Medium Risk – Businesses or merchants with moderate transaction volumes.
High Risk – Customers with large transaction volumes or cross-border activities.
Enhanced Due Diligence (EDD) will be applied to high-risk customers.
7. Transaction Monitoring
All financial transactions processed through BEEZENDS will be monitored using automated systems to detect unusual transaction patterns, rapid movement of funds, structuring to avoid reporting thresholds, abnormal transaction volumes, and suspicious merchant activity.
8. Suspicious Transaction Reporting
Where suspicious activity is detected, BEEZENDS will investigate the transaction, temporarily restrict the account if necessary, file a Suspicious Transaction Report (STR) with the relevant authority, and maintain records of all reported cases.
9. Record Keeping
BEEZENDS will retain AML records including customer identity information, transaction history, suspicious activity reports, and investigation documentation for the minimum period required by regulatory authorities.
10. Employee Training
Employees involved in financial operations will undergo periodic AML training covering money laundering typologies, fraud detection techniques, suspicious activity identification, and regulatory compliance obligations.
11. Internal Audit and Compliance Monitoring
Periodic internal audits will be conducted to assess effectiveness of transaction monitoring systems, adequacy of KYC/KYB procedures, and regulatory reporting compliance.
12. Policy Review
This policy will be reviewed periodically to reflect regulatory updates, emerging financial crime risks, and technological developments within the BEEZENDS platform.