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AML / KYC Policy

How Naya handles identity checks and financial crime prevention.

Last Updated: June 2026

1. Purpose and Scope

This Anti-Money Laundering, Counter-Financing of Terrorism, and Counter-Proliferation Financing (AML/CFT/CPF) Policy sets out the obligations of Usenaya Ltd ("Naya") and its users in relation to financial crime prevention. This policy applies to all users of the Naya platform across all supported markets.

Naya is committed to full compliance with:

  • The Money Laundering (Prevention and Prohibition) Act, 2022 (Nigeria)
  • The Terrorism (Prevention and Prohibition) Act, 2022 (Nigeria)
  • CBN AML/CFT/CPF Regulations and Compliance Framework (2023)
  • Nigeria Financial Intelligence Unit (NFIU) guidelines and directives
  • Financial Action Task Force (FATF) Recommendations
  • Applicable AML/CFT regulations in all markets where Naya operates

2. Know Your Customer (KYC)

2.1 KYC Requirements

All users must complete a KYC verification process before accessing Naya's full transaction capabilities. KYC is conducted entirely via WhatsApp and requires:

  • Full legal name matching government ID
  • Date of birth
  • Phone number
  • Bank Verification Number (BVN) or National Identification Number (NIN)
  • A valid government-issued photo ID

2.2 Tiered KYC and Transaction Limits

  • Tier 1 (Phone number only): Limited functionality for airtime top-ups and low-value bill payments only
  • Tier 2 (BVN/NIN verified): Access to bank transfers and bill payments up to applicable CBN daily limits
  • Tier 3 (Full KYC): Access to full platform features including crypto transactions and higher transaction limits

2.3 Ongoing KYC

KYC is not a one-time process. Naya may request updated documentation or additional information at any time to ensure ongoing compliance with regulatory requirements. Failure to provide requested information within the specified timeframe may result in account suspension.

3. Customer Due Diligence (CDD)

Naya applies a risk-based approach to Customer Due Diligence:

  • Standard CDD is applied to all users during onboarding
  • Enhanced Due Diligence (EDD) is applied to high-risk users, including PEPs, users in high-risk jurisdictions, or users whose transaction patterns trigger risk flags
  • Simplified CDD may be applied to low-risk, low-value transactions within regulatory parameters

Naya screens all users against applicable sanctions lists including OFAC, UN Security Council sanctions, EU consolidated list, and CBN-designated lists. Screening is conducted at onboarding and on an ongoing basis.

4. Transaction Monitoring

Naya employs real-time transaction monitoring to detect unusual or suspicious activity. Patterns that may trigger review include:

  • Transactions inconsistent with a user's declared source of funds or income level
  • Rapid sequential transactions designed to structure amounts below reporting thresholds
  • Transfers to or from high-risk jurisdictions
  • Unusual frequency or volume of cryptocurrency purchases
  • Sudden changes in transaction behaviour inconsistent with established patterns
  • Multiple accounts with similar identifying characteristics

5. Suspicious Transaction Reporting

Where Naya identifies a transaction or activity that gives rise to reasonable grounds for suspicion of money laundering, terrorist financing, or proliferation financing, we are legally required to file a Suspicious Transaction Report (STR) with the Nigeria Financial Intelligence Unit (NFIU) without tipping off the user.

Naya's compliance team reviews all flagged transactions within 24 hours. Transactions may be delayed, blocked, or referred to the relevant authorities pending investigation.

6. Prohibited Activities

The following activities are strictly prohibited on the Naya platform:

  • Using Naya to launder proceeds of crime
  • Financing terrorism, proliferation of weapons, or any designated organisation
  • Structuring transactions to evade regulatory reporting thresholds
  • Providing false information during KYC or any other compliance process
  • Using another individual's identity or credentials
  • Conducting transactions on behalf of sanctioned individuals or entities
  • Any other activity that constitutes a financial crime under Nigerian or applicable international law

7. Politically Exposed Persons (PEPs)

Users who are, or are related to, a Politically Exposed Person as defined by FATF and CBN guidelines must disclose this during onboarding. PEPs are subject to Enhanced Due Diligence and may be required to provide additional documentation regarding source of funds and wealth. Senior management approval is required before onboarding a PEP.

8. Record Keeping

Naya retains all KYC documentation, transaction records, and compliance-related correspondence for a minimum of five (5) years from the date of the transaction or account closure, whichever is later, in accordance with the Money Laundering (Prevention and Prohibition) Act, 2022.

9. Staff Training and Compliance Culture

All Naya team members with access to user data or transaction systems receive mandatory AML/CFT training. This training covers recognition of suspicious activity, reporting obligations, and regulatory requirements. Training is refreshed annually and updated when regulatory frameworks change.

10. Consequences of Non-Compliance

Users who violate this policy or applicable AML/CFT laws may face:

  • Immediate account suspension or termination
  • Blocking or reversal of pending transactions
  • Reporting to the NFIU, EFCC, or other competent authorities
  • Civil or criminal prosecution

11. Contact — Compliance

AML / Compliance queries: support@usenaya.com

To report suspected financial crime involving the Naya platform: support@usenaya.com