Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Purpose

Help Me Nigeria ("Help Me Nigeria," "we," "our," or "us") is committed to preventing money laundering, terrorist financing, fraud, corruption, sanctions evasion, and other financial crimes.

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy ("Policy") describes the measures we use to identify users, monitor transactions, assess risk, and comply with applicable laws and regulations.

This Policy forms part of our Terms of Service and applies to all users of the Platform.

2. Scope

This Policy applies to:

• Campaign Organizers
• Beneficiaries
• Donors
• Business accounts
• Charitable organizations
• Non-profit organizations
• Corporate entities
• Authorized representatives
• Any individual or entity using the Platform

3. Compliance Commitment

Help Me Nigeria adopts a risk-based approach to AML and KYC compliance and seeks to comply with all applicable laws and regulations, including those relating to:

• Anti-money laundering
• Counter-terrorist financing
• Financial crime prevention
• Economic and trade sanctions
• Fraud prevention
• Customer due diligence
• Record retention
• Data protection and privacy

Where applicable, we cooperate with competent regulatory authorities and law enforcement agencies.

4. Risk-Based Approach

Not all users present the same level of risk.

We assess factors including:

• Country of residence
• Geographic risk
• Campaign category
• Transaction volume
• Donation frequency
• Withdrawal activity
• Payment methods
• Identity verification results
• Business type
• Source of funds
• Beneficiary profile
• Sanctions exposure
• Politically exposed person (PEP) status
• Adverse media where appropriate

Based on these factors, users may be classified as low, medium, or high risk.

5. Customer Identification (KYC)

Before permitting certain activities, Help Me Nigeria may require users to complete identity verification.

Verification requirements may include:

Individuals

• Full legal name
• Date of birth
• Residential address
• Phone number
• Email address
• Government-issued photo identification
• Selfie or liveness verification
• Proof of address
• Tax identification where applicable

Organizations

Organizations may be required to provide:

• Certificate of incorporation or registration
• Organization name
• Registered business address
• Registration number
• Tax identification number
• Authorized representative details
• Beneficial ownership information
• Corporate resolutions where applicable
• Bank account details

6. Beneficial Ownership

Where legally required, Help Me Nigeria may identify individuals who directly or indirectly own or control an organization or legal entity.

Additional documentation may be requested to determine ultimate beneficial ownership.

7. Campaign Verification

Campaign Organizers may be required to submit documentation supporting their fundraising purpose.

Depending on the campaign, we may request:

• Medical documentation
• Educational admission letters
• Charity registration certificates
• Invoices
• Emergency documentation
• Death certificates
• Disaster reports
• Business registration documents
• Letters of authorization
• Beneficiary consent

Submission of documents does not guarantee campaign approval.

8. Source of Funds

Help Me Nigeria may request information regarding the legitimate source of funds where circumstances warrant additional review.

Examples include:

• High-value donations
• Large fundraising campaigns
• Unusual donation patterns
• Cross-border fundraising
• Business fundraising
• Regulatory requirements

Acceptable supporting documents may include:

• Employment income records
• Business income records
• Financial statements
• Tax filings
• Grant documentation
• Bank statements
• Other reasonable evidence

9. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be conducted for higher-risk users or transactions.

EDD measures may include:

• Additional identity verification
• Additional supporting documentation
• Source of wealth verification
• Source of funds verification
• Manual compliance review
• Senior compliance approval
• Enhanced transaction monitoring
• Ongoing account reviews

10. Politically Exposed Persons (PEPs)

Users identified as Politically Exposed Persons, their close associates, or immediate family members may be subject to enhanced due diligence.

PEP status does not automatically prohibit use of the Platform but may require additional compliance procedures.

11. Sanctions Screening

Help Me Nigeria may screen users, beneficiaries, organizations, and transactions against applicable sanctions and watchlists.

Accounts associated with sanctioned individuals or entities may be:

• Restricted
• Suspended
• Terminated
• Reported to relevant authorities where required by law

12. Transaction Monitoring

We may monitor transactions to identify unusual or suspicious activity.

Monitoring may include:

• Donation frequency
• Donation size
• Withdrawal behavior
• Geographic patterns
• Device activity
• Multiple linked accounts
• Velocity checks
• Payment anomalies
• Suspicious behavioral indicators

Monitoring may be automated, manual, or both.

13. Suspicious Activity

Examples of potentially suspicious activity include:

• False identity information
• Multiple accounts used to avoid verification
• Structuring transactions to avoid thresholds
• Rapid donations followed by immediate withdrawals
• Unexplained high-value transactions
• Campaigns lacking supporting evidence
• Fraudulent documentation
• Use of stolen payment methods
• Attempts to evade sanctions
• Money mule activity
• Requests to transfer funds to unrelated third parties

Help Me Nigeria reserves the right to investigate any activity that appears suspicious.

14. Account Restrictions

To protect the Platform and its users, we may:

• Delay withdrawals
• Freeze campaign funds
• Suspend campaigns
• Limit transactions
• Request additional documentation
• Restrict account functionality
• Reject transactions
• Close accounts

These actions may be taken without prior notice where immediate action is reasonably necessary.

15. Reporting Obligations

Where required by applicable law, Help Me Nigeria may report suspicious activity to competent authorities.

We may also cooperate with:

• Financial intelligence units
• Law enforcement agencies
• Regulatory authorities
• Courts
• Payment service providers
• Banking institutions

Users will not necessarily be notified when disclosures are made if doing so would be prohibited by law or would compromise an investigation.

16. Record Retention

Help Me Nigeria may retain AML and KYC records for the period required by applicable law or for as long as reasonably necessary to:

• Demonstrate compliance
• Investigate fraud
• Resolve disputes
• Meet regulatory obligations
• Support law enforcement requests

Records may include identification documents, verification results, transaction histories, and compliance reviews.

17. User Responsibilities

Users agree to:

• Provide accurate information.
• Keep account information current.
• Cooperate with verification requests.
• Respond promptly to compliance inquiries.
• Use only payment methods they are authorized to use.
• Refrain from using the Platform for unlawful purposes.

Failure to cooperate may result in account restrictions or termination.

18. Privacy and Data Protection

Personal information collected for AML and KYC purposes will be handled in accordance with our Privacy Policy and applicable data protection laws.

Verification information may be shared with trusted service providers and competent authorities where required by law or necessary to perform compliance functions.

19. Third-Party Verification Providers

Help Me Nigeria may use independent service providers to perform:

• Identity verification
• Document authentication
• Biometric checks
• Sanctions screening
• Fraud detection
• Address verification
• Business verification

These providers are required to protect personal information in accordance with applicable contractual and legal obligations.

20. Policy Updates

We may revise this Policy from time to time to reflect changes in legal requirements, regulatory guidance, industry standards, or our business operations.

Material updates will be communicated through appropriate means, including publication on the Platform.

Continued use of the Platform after the effective date of an updated Policy constitutes acceptance of the revised terms.

21. Contact Information

Questions regarding this AML/KYC Policy or compliance matters may be directed to: