AML/CFT Policy

[Opreet legal entity name: to be confirmed] (“Opreet”) is committed to preventing its services from being used for money laundering, terrorist financing, proliferation financing or any other financial crime. This policy sets out the principles Opreet follows and what customers can expect. It is a public summary: the detailed procedures, rules and thresholds that implement it are confidential.

Anti-money-laundering and counter-terrorist-financing (AML/CFT) obligations depend on the activities a business performs and the licences it holds. Opreet describes its position accurately here and does not claim any licence or approval that it does not hold.

Opreet complies with the Nigerian anti-money-laundering and counter-terrorist-financing laws and regulations that apply to it, and works with its regulated partners so that the obligations that apply to them are also met.

• A risk-based approach: our controls are proportionate to the risks of our customers, products, channels and the places involved.
• Know who we are dealing with: we identify customers as required, and do not knowingly serve anonymous or fictitious accounts.
• Vigilance: we watch for unusual or suspicious activity and act on it.
• Cooperation: we cooperate with lawful requests from regulators and law-enforcement authorities.
• Accountability: responsibility for AML/CFT sits with senior management, and staff are trained for their role.

Where the law or a regulated partner requires it, we identify and verify customers before, or soon after, they can use certain features, and we understand the purpose of the account. How this works for Opreet customers is explained in our KYC Policy.

We apply enhanced due diligence where the risk is higher, for example for certain high-risk relationships or activity, and may ask for more information or evidence before continuing.

Where required, customers and transactions are checked against applicable sanctions lists and other relevant watch-lists, including those that apply under Nigerian law and the lists our regulated partners are required to use. We do not open accounts for, or process transactions that involve, persons or entities that we are prohibited from dealing with.

We monitor accounts and transactions on a risk basis to spot activity that is inconsistent with what we know about a customer, or that may be unusual or suspicious. We do not publish the rules or thresholds we use, because doing so would help people avoid detection.

Where we know or suspect that a transaction or activity relates to money laundering, terrorist financing or other crime, we escalate it internally and report it to the competent authority as the law requires.

You must not use Opreet for any of the following. We may refuse, hold or reverse a transaction, and suspend or close an account, if we suspect it:

• money laundering, or handling the proceeds of crime;
• terrorist financing or proliferation financing;
• dealing with sanctioned persons, entities or places, or evading sanctions;
• fraud, including using stolen or compromised accounts, identities or payment details;
• using an account on behalf of someone else without our agreement, or splitting activity to avoid our controls.

See also our Acceptable Use Policy.

We keep customer identification information, transaction records and related correspondence for the periods the law requires, even after an account is closed. This is one of the reasons we cannot always delete everything when you ask. See Delete your account. Retention periods: [data retention periods: to be confirmed].

We respond to lawful requests from regulators, courts and law-enforcement agencies, and may share information with them where the law requires or permits it. We take care to disclose only what is needed.

Senior management is responsible for this policy. Staff who handle customer accounts or transactions receive AML/CFT training appropriate to their role, and the policy is reviewed regularly and whenever the law, our products or our risks change.

We will publish updates here with a new version number and date. For questions about this policy, contact [compliance email address: to be confirmed].