AML Policy

1. Compliance Commitment

Greendot Technology is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) compliance. We actively assist regulatory and law enforcement authorities in Nigeria, operating in alignment with the Money Laundering (Prevention and Prohibition) Act, the Terrorism (Prevention and Prohibition) Act, and the guidelines of the Central Bank of Nigeria (CBN).

2. Know Your Customer (KYC) & Verification

To prevent financial crime and ensure the integrity of our vending platform, we implement KYC controls based on transactional volumes and user roles:

• Transaction Limits: Daily and single purchase limits are actively enforced. Customers exceeding designated transaction thresholds are required to provide additional verification (e.g., BVN, government-issued identification, or address verification).
• Meter Verification: All vending operations are verified against active utility provider databases, ensuring tokens are only issued to genuine meters associated with verified residential or commercial accounts.
• Records Retention: We retain customer identification, verification records, and transaction history for a minimum of five (5) years in compliance with local regulations.

3. Transaction Monitoring & Detection

We employ automated systems and manual audits to monitor transaction patterns on our platform. We look for indicators of suspicious activity, including unusually large or frequent transactions, structured deposits (splitting payments to evade limits), and accounts linked to unauthorized payment methods.

4. Suspicious Activity Reporting (SAR)

Where suspicious transactions are identified, Greendot Technology reserves the right to suspend the user account and freeze pending purchases. In compliance with the law, we will file Suspicious Activity Reports (SAR) with the Nigerian Financial Intelligence Unit (NFIU) and other relevant regulatory bodies. We are legally prohibited from disclosing to the customer that a report has been filed (the "tipping-off" rule).

5. Sanctions Screening

We monitor and check transaction details against national and international sanctions lists (such as the Office of Foreign Assets Control (OFAC) and local regulatory blacklists). We do not facilitate transactions for, or provide services to, individuals or entities identified on these sanctions registers.

6. Policy Updates & Training

Our compliance program includes regular staff training on identifying financial crime, auditing transaction logs, and updating verification protocols. This policy is reviewed regularly to adapt to emerging regulatory standards and legal developments.

7. Contact Information

If you have questions regarding our compliance measures, KYC requirements, or wish to report suspicious activities on our platform, please contact our compliance officer at info@greendot.com.ng.