AML Policy

Anti-Money Laundering & Counter-Terrorism Financing Policy — Last updated: 1 January 2025

Important: EspeesConnect maintains a zero-tolerance policy towards money laundering, fraud, and any financial crime. All users are subject to this policy and applicable Nigerian law.
Table of Contents
  1. Purpose & Scope
  2. Key Definitions
  3. Know Your Customer (KYC)
  4. Transaction Monitoring
  5. Red Flags & Suspicious Activity
  6. Reporting Obligations
  7. Record Keeping
  8. Sanctions & Enforcement
  9. User Responsibilities
  10. Contact

1. Purpose & Scope

This Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy sets out EspeesConnect's commitment to preventing its platform from being used for money laundering, terrorist financing, or any other financial crime.

This Policy applies to all users of the EspeesConnect platform, all transactions facilitated through the Platform, and all employees and contractors of EspeesConnect. It has been developed in accordance with the Money Laundering (Prohibition) Act and other applicable Nigerian financial regulations.

2. Key Definitions

  • Money Laundering: The process of making illegally obtained funds appear legitimate by passing them through a series of transactions.
  • Terrorism Financing: Providing or collecting funds with the intention or knowledge that they may be used for terrorist activities.
  • Suspicious Activity: Any transaction or behaviour that raises reasonable grounds to suspect involvement in money laundering or other financial crime.
  • KYC (Know Your Customer): The process of verifying the identity of users to prevent fraud and financial crime.

3. Know Your Customer (KYC)

EspeesConnect collects and verifies user information at registration including full name and valid email address. Bank accounts are verified through Flutterwave to confirm account ownership. We reserve the right to request additional identity documentation from any user at any time, including government-issued ID, proof of address, or source-of-funds declarations, particularly for high-value or high-frequency transactions.

Users who fail to provide requested documentation may have their accounts restricted or suspended.

4. Transaction Monitoring

EspeesConnect monitors all transactions on the Platform for patterns that may indicate money laundering or financial crime. Monitoring activities include:

  • Review of unusually large or structured transactions.
  • Detection of repeated transactions below reporting thresholds (structuring).
  • Identification of inconsistencies between user profiles and transaction behaviour.
  • Screening of users against sanctions lists and politically exposed persons (PEP) databases.

5. Red Flags & Suspicious Activity

The following are examples of behaviour that may be flagged for review:

  • Multiple accounts registered to the same individual or device.
  • Transactions with no apparent commercial purpose or explanation.
  • Requests to process funds on behalf of third parties.
  • Inconsistencies in payment details or counterparty information.
  • Unusual urgency or pressure to complete transactions quickly.
  • Users who refuse to provide identity documentation when requested.
  • Transactions involving jurisdictions with high risk of money laundering.

6. Reporting Obligations

EspeesConnect will report suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) and any other relevant authorities as required by law. We may freeze or suspend accounts and associated transactions pending investigation without prior notice to the user where legally required.

Users who become aware of suspicious activity by other users are encouraged to report it through our Report Issue page.

7. Record Keeping

We maintain records of all user identification information and transaction data for a minimum of five (5) years in compliance with Nigerian law. These records may be made available to regulatory authorities upon lawful request.

8. Sanctions & Enforcement

Any user found to be engaged in money laundering, fraud, terrorism financing, or any violation of this Policy will have their account immediately and permanently suspended. We will cooperate fully with law enforcement and regulatory agencies in any investigation. EspeesConnect reserves the right to withhold funds associated with suspected criminal activity pending resolution.

9. User Responsibilities

All users of EspeesConnect bear personal responsibility for ensuring that their use of the Platform complies with applicable law. By using the Platform, you confirm that:

  • Funds used in transactions are from legitimate sources.
  • You are not acting on behalf of a sanctioned entity or individual.
  • You will cooperate with any KYC or compliance request from EspeesConnect.
  • You will promptly report any suspicious activity you become aware of.

10. Contact

For AML or compliance-related enquiries, please contact us: