PAYMASTR AML/KYC POLICY
1. Introduction
The Anti-Money Laundering and Know Your Customer Policy (AML/KYC Policy) of Paymastr is designed to prevent and mitigate the risks of the service being used for illegal activities, including money laundering and terrorism financing, in compliance with Nigerian laws and regulations.
2. Purpose of Internal Regulation
Paymastr adheres to practices and measures in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism (AML). The purpose of these measures is to demonstrate that Paymastr takes seriously any attempt to use its service for illegal purposes.
3. Caution
Paymastr strictly prohibits the use of its service for money laundering, terrorism financing, fraud, or the purchase of prohibited goods and services, in accordance with the Money Laundering (Prohibition) Act and other relevant Nigerian laws. The Paymastr service, its administration, employees, and domain owners are not responsible for the misuse of the service by third parties, the actions of intruders, or any damage associated with such misuse.
4. Requirements
To prevent illegal transactions, Paymastr sets certain requirements for all applications created by the user:
4.1. All transactions must be conducted by the account holder only. Third-party transactions are strictly prohibited to comply with Nigerian AML regulations.
4.2. All contact and personal information provided by the user in the application, as well as other personal data transmitted to Paymastr, must be accurate and up-to-date.
4.3. Users are prohibited from creating applications using anonymous proxy servers, VPN, Tor, or any other anonymous internet connections.
5. Verification Procedures
Paymastr implements customer due diligence (Verification) as an international standard to prevent illegal activities, adhering to strict AML/KYC procedures in line with Nigerian regulations.
5.1. Paymastr will conduct customer due diligence by requiring users to provide valid identification documents, such as a Nigerian passport, National ID card, or driver’s license, and may request additional information to verify the source of funds. Required documents may include:
A photo with a passport where the photo and full name are clearly visible.
Scan or photo of the passport (first, second pages, and registration page).
Confirmation of the source of funds (photos, screenshots, extracts).
A video where the user, holding their passport, confirms the transaction details (e.g., application ID) and states that the funds are their personal property, mentioning the source of funds.
A video from the platform where funds were sent, showing the transaction hash, sender and recipient addresses, amount with ticker, and date (minimum 10 seconds).
5.2. In cases of high-risk transactions, blockages, or official investigations, funds will be held until verification or the investigation is completed. Paymastr reserves the right to collect identification information for AML/KYC compliance.
5.3. Paymastr will verify the authenticity of documents and information provided by users using all legal methods, including double verification, and reserves the right to investigate users identified as dangerous or suspicious.
5.4. Paymastr reserves the right to continuously verify user identity, especially if identification information changes or activities appear suspicious, and may request updated documents even if previously authenticated.
5.5. User identification information will be collected, stored, shared, and protected in accordance with Paymastr’s Privacy Policy and the Nigeria Data Protection Regulation (NDPR).
5.6. After identity confirmation, Paymastr may refuse services if they are being used for illegal activities.
5.7. Users using payment cards must pass card verification as per instructions on the Paymastr website.
5.8. Paymastr is required to verify the legality of the source of funds or cryptocurrency used for transactions.
6. Responsible Official
Paymastr shall appoint an AML Compliance Officer who will oversee the implementation of this policy, ensure compliance with Nigerian AML/CFT regulations, and liaise with regulatory bodies such as the NFIU and EFCC.
6.1. The officer’s duties include overseeing all AML activities, such as:
Collecting user identification information.
Developing and updating internal policies for report completion, review, submission, and storage as required by Nigerian laws.
Monitoring transactions and investigating deviations from normal activity.
Implementing a records management system for document storage and retrieval.
Regularly updating risk assessments.
Providing information to law enforcement as required by law.
6.2. The AML Compliance Officer is authorized to interact with Nigerian law enforcement agencies involved in preventing money laundering, terrorism financing, and other illegal activities.
7. System Functions
Paymastr employs a robust compliance system that includes transaction monitoring, customer screening against sanctions lists, and reporting suspicious activities to the NFIU as required by Nigerian law. System features include:
Daily checks of users against recognized blacklists (e.g., OFAC), aggregation of transfers, placement of users on watchlists or denial lists, case investigations, internal messaging, and mandatory reporting when applicable.
Case and document management.
8. Behavior Analysis
Paymastr verifies users not only through identity checks but also by analyzing transaction behavior to detect and prevent suspicious activities, using data analysis as a risk assessment tool.
9. Risk Assessments
Paymastr applies risk assessment practices to combat money laundering and terrorism financing, ensuring that preventive measures are proportionate to identified risks, in line with Nigerian and international requirements.
10. Performing Customer Checks
If Paymastr suspects a user is attempting to use the service for money laundering or other illegal operations, the administration may:
Suspend the user’s transaction.
Request identification documents and additional information for suspicious transactions.
Report suspicious activities to Nigerian authorities (e.g., NFIU) through the AML Compliance Officer.
11. Privacy
Paymastr is committed to protecting user privacy and confidentiality in compliance with the Nigeria Data Protection Regulation (NDPR) and other applicable laws.
11.1. Paymastr and its employees will maintain confidentiality regarding facts revealed in suspicious transactions. This obligation extends to users and third parties receiving transaction information.
11.2. The confidentiality obligation persists after employees leave Paymastr or change roles. Disclosure to government or law enforcement as required by law does not violate this obligation.
11.3. Confidentiality obligations may not apply to information shared between financial institutions in a consolidated group cooperating with Paymastr, provided the use is limited to preventing money laundering and terrorism financing.
12. Conclusion
Paymastr disclaims any liability for the misuse of its service for illegal activities, such as money laundering, terrorism financing, or purchasing prohibited goods and services. However, it commits to cooperating with Nigerian authorities, including the EFCC and NFIU, to prevent and report suspicious activities. By using Paymastr, users agree to comply with this policy and the service’s exchange rules.
