AML/KYC Policy

1.1 Purpose: This AML/KYC Policy (“Policy”) sets out Pairgate Venture's commitment to preventing money laundering, terrorism financing, proliferation financing, and other financial crimes, and to complying with all applicable Nigerian AML/CFT laws.

1.2 Scope: This Policy applies to:

• All users of the Pairgate Platform.
• All resellers, sub-agents, and API partners.
• All directors, employees, contractors, and agents of Pairgate Venture.
• All transactions, deposits, withdrawals, and Virtual Top-Up Services facilitated through the Platform.

1.3 Incorporation: This Policy is incorporated into and forms part of our Terms and Conditions.

Pairgate operates within the following legal and regulatory framework:

• Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA).
• Terrorism (Prevention and Prohibition) Act, 2022.
• Central Bank of Nigeria (CBN) AML/CFT Regulations.
• Nigeria Financial Intelligence Unit (NFIU) Guidelines and Reporting Requirements.
• Nigeria Data Protection Act, 2023 (NDPA).
• Cybercrimes Act, 2015 (as amended).
• United Nations Security Council (UNSC) Sanctions Lists.
• Other applicable Nigerian and international AML/CFT frameworks.

3.1 Board Oversight: The Board of Directors of Pairgate Venture has ultimate responsibility for AML/CFT compliance and approves this Policy.

3.2 Compliance Officer: A designated Compliance Officer is responsible for the day-to-day implementation of this Policy, including KYC, transaction monitoring, reporting, and training.

3.3 Staff Responsibility: All directors, employees, and contractors are required to comply with this Policy, complete AML training, and report suspicious activity promptly.

3.4 Independent Review: The Policy and its implementation may be independently audited periodically.

4.1 Identity Verification: Before activating a wallet or allowing significant transactions, Pairgate may verify the identity of every user by collecting:

• Full name, phone number, email address, date of birth, and residential address.
• Bank Verification Number (BVN).
• National Identification Number (NIN).
• Government-issued ID (National ID, Driver's License, or Passport).
• Proof of address (utility bill or bank statement).
• Live selfie for liveness and facial match.

4.2 Tiered KYC: Pairgate applies tiered KYC levels:

• Tier 1 (Basic): Name, phone, email — limited transaction limits.
• Tier 2 (Standard): BVN or NIN verification — higher limits.
• Tier 3 (Enhanced): Full ID, address, selfie — highest limits and reseller/API eligibility.

4.3 Ongoing Monitoring: CDD is not a one-time process. We may re-verify identity, request updated documents, and update KYC information periodically.

4.4 Beneficial Ownership: Where a user is a company or entity, we may identify and verify the beneficial owners.

Enhanced Due Diligence is applied in higher-risk situations, including:

• Politically Exposed Persons (PEPs) or their family members and close associates.
• Users in or transacting with high-risk jurisdictions.
• Unusually large or complex transactions.
• Inconsistent transaction patterns.
• Users flagged by fraud detection systems.

EDD measures may include source-of-funds verification, source-of-wealth documentation, senior management approval, and increased transaction monitoring.

6.1 PEP Screening: Pairgate screens users against PEP databases. Users identified as PEPs are subject to Enhanced Due Diligence.

6.2 Sanctions Screening: Users and transactions are screened against Nigerian, UN, OFAC, EU, UK, and other applicable sanctions lists.

6.3 Blocked Accounts: Accounts matching sanctions lists are blocked immediately, and the matter is reported to the NFIU and relevant authorities.

6.4 No Circumvention: Attempts to circumvent PEP or sanctions screening (e.g., by using proxies or shell entities) are strictly prohibited and may result in account termination and reporting to law enforcement.

7.1 Automated Monitoring: Pairgate uses automated and manual systems to monitor transactions for suspicious patterns.

7.2 Red Flags: Red flags include:

• Unusually large deposits or rapid movement of funds.
• Multiple accounts with shared identifiers (IP, device, BVN, bank account).
• Frequent deposits followed by immediate withdrawal attempts.
• Transactions to/from high-risk jurisdictions.
• Betting wallet funding patterns inconsistent with normal usage.
• Rapid funding and depletion of wallet balances.
• Structuring (breaking up transactions to avoid thresholds).

7.3 Escalation: Flagged transactions are escalated to the Compliance Officer for review and possible STR filing.

8.1 Obligation to Report: Pairgate is legally obligated to file Suspicious Transaction Reports (STRs) and other reports with the NFIU in accordance with the MLPPA 2022 and NFIU guidelines.

8.2 Timing: STRs are filed as soon as reasonably practicable after detection of suspicious activity.

8.3 Tipping Off: Pairgate will not disclose the existence of an STR or related investigation to the subject or any third party, except as required by law.

8.4 Threshold Reports: Cash or transaction threshold reports (e.g., CTRs) may be filed where required by NFIU rules.

8.5 Cooperation: Pairgate cooperates fully with the NFIU, CBN, law enforcement, and judicial authorities.

9.1 Retention: Pairgate retains KYC and transaction records for a minimum of five (5) years after the end of the business relationship, or longer where required by law.

9.2 Scope: Records include identity documents, KYC data, transaction logs, screening results, internal reports, and STR filings.

9.3 Confidentiality: Records are stored securely with access restricted to authorized personnel.

9.4 Data Protection: Record-keeping complies with the Nigeria Data Protection Act, 2023.

10.1 Staff Training: All Pairgate staff complete AML/CFT training upon onboarding and periodically thereafter.

10.2 Awareness: Staff are trained on red flags, reporting obligations, and the legal consequences of non-compliance.

10.3 User Education: Pairgate educates users and resellers on AML/CFT obligations and prohibited conduct via our Acceptable Use Policy.

11.1 User Consequences: Failure to comply with KYC or AML requirements may result in:

• Restriction or suspension of your account.
• Freezing of wallet balances and transaction value.
• Termination of your account and reseller/API access.
• Reporting to the NFIU, CBN, and law enforcement.

11.2 Staff Consequences: Staff who violate this Policy may face disciplinary action, including termination and referral to law enforcement.

11.3 Legal Consequences: Money laundering and terrorism financing are criminal offences under Nigerian law and carry severe penalties including imprisonment and asset forfeiture.

Pairgate Venture (RC: 3687598)
Compliance: [email protected]
Legal: [email protected]
Website: https://pairgate.com