AML Policy

This AML policy was last updated on July 5th, 2022. If there will be any update, amendment, or changes to our AML policy then these will be posted on this page

PurplePay Approach To Anti Money Laundering (AML)

Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it gives an impression of legitimate income. Criminals often target financial services firms through which they attempt to launder criminal proceeds without the firms’ knowledge or suspicion.

In order to combat money laundering and counter terrorist financing (CTF), Nigeria has implemented The Money Laundering (Prevention and Prohibition) Act, 2022 (the Act or MLA 2022) which repeals the Money Laundering (Prohibition) Act, No. 11, 2011 which imposes obligations on financial service providers.

 

The key components of our AML policy and CTF framework include:

  • Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;
  • Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;
  • Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • Maintaining appropriate records for the minimum prescribed periods;
  • Providing training for and raising awareness among all relevant employees.

 

 

Sanctions Policy

PurplePay is prohibited from transaction with individuals and countries that are on prescribed sanctions lists. PurplePay will therefore screen against over 1000 sanctions lists including OFAC, FBI Most Wanted, FinCEN & Interpol. Clients are also screened against Domestic Prominent Influenceable Person (DPIP) & Foreign Prominent Public Official (FPPO) sources.

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