KYC & AML Policy

Washermann Africa Ltd · Effective date: September 1, 2026

1. Purpose

This policy sets how Washermann verifies users and guards against fraud, money laundering, and terrorist financing, in line with applicable Nigerian law and our payment partners' requirements.

2. Scope

Applies to Vendors and Reps (who receive payouts) and, where relevant, high-value customer activity. Actual fund movement is performed by our licensed processor (Paystack), which applies its own regulated controls.

3. Customer/user due diligence (KYC)

  • Customers: account requires a verified phone/email; additional verification may be required for elevated activity.
  • Vendors: must provide business details, a valid government-issued ID, proof of address, photographs, and bank account details matched to the vendor before payout eligibility. Verification is reviewed by an administrator before activation.
  • Reps: must provide identity details and verified bank account details before payout.
  • We may re-verify at any time and may suspend or revert verification where information is incomplete, inconsistent, or suspicious.

4. Payout controls

  • Payouts go only to a verified bank account in the recipient's records.
  • We apply thresholds, review, and anti-fraud checks; we may hold, delay, or decline payouts pending checks, and reverse amounts linked to fraud, error, chargebacks, or disputes.

5. Monitoring & red flags

We monitor for indicators such as: mismatched account/identity details, rapid top-up-and-refund cycles, referral/reward abuse, multiple accounts controlled by one party, structuring, and unusual patterns. Flagged activity may trigger review, suspension, and reporting.

6. Record-keeping

KYC records and transaction histories are retained for the periods required by law and our processors.

7. Reporting & cooperation

We cooperate with lawful requests from regulators and law enforcement and will file reports required of us, including to the Nigerian Financial Intelligence Unit (NFIU) where applicable.

8. Sanctions

We do not knowingly transact with sanctioned persons/entities and screen where required.

9. Governance

This policy is owned by Washermann Africa Ltd management, reviewed periodically, and updated as the business and law evolve.