Know Your Customer (KYC) & Anti-Money Laundering (AML) Policy
Purpose
This policy describes the measures the business may use to identify customers, reduce fraud risks, protect its payment environment, and prevent the platform from being misused for unlawful financial activity.
Scope and Applicability
This policy applies to the extent that KYC/AML obligations are relevant to the business, its payment arrangements, products, services, or applicable Nigerian laws and regulatory requirements.
Important: CBN customer-due-diligence regulations specifically apply to financial institutions under CBN regulatory purview. A footwear retailer should not claim to be subject to financial-institution requirements unless those requirements actually apply to its business.
Customer Information
Where lawful and necessary, the business may request information such as: • Full name • Contact information • Delivery information • Account information • Identification information where legally required • Information necessary to investigate suspicious transactions
Customer Verification
Where verification is required, the business may verify customer information using appropriate and lawful procedures. For regulated financial institutions, CBN customer-due-diligence rules provide requirements concerning customer identification and verification.
Fraud and Suspicious Activity
The business may review transactions or account activity for indicators of fraud, unauthorized activity, identity misuse, payment abuse, or other suspicious conduct. Where legally required, suspicious activity should be handled and reported through the appropriate channels.
High-Risk Activity
Where a transaction or relationship presents elevated risk, additional verification or other appropriate controls may be applied where permitted or required by law
Third-Party Payments
Where a person other than the customer pays for an order, the business may request additional information where reasonably necessary to address fraud, payment disputes, or legal requirements
Record Keeping
Records relating to customer verification and transactions should be retained only for the period required by applicable law and legitimate business needs
Privacy
Personal information collected for KYC/AML or fraud-prevention purposes must be handled in accordance with the applicable privacy and data-protection requirements
Policy Review
This policy should be reviewed periodically and updated when applicable laws, payment arrangements, risks, or business operations change
