Know Your Customer (KYC) Policy

Effective Date: 31st August, 2025

Billpago Digital Integrated Limited (“CIPAGO”) is committed to implementing and enforcing robust Know Your Customer (KYC) standards in line with Nigerian regulatory requirements and global best practices. This KYC Policy aligns with the Central Bank of Nigeria (CBN) AML/CFT Regulations, the Money Laundering (Prevention and Prohibition) Act, 2022, EFCC SCUML directives, and Financial Action Task Force (FATF) recommendations.

1. Purpose

This KYC Policy establishes the minimum standards to identify, verify, and understand our customers and their financial dealings. It aims to prevent the misuse of CIPAGO’s services for money laundering, terrorist financing, fraud, and other illicit activities.

2. Scope

This policy applies to all directors, employees, agents, partners, and third parties acting on behalf of CIPAGO. It covers onboarding, monitoring, and management of both individual and corporate customers.

3. Key Principles

• Customer Identification Program (CIP): Ensure accurate identification of all customers prior to establishing any relationship.
• Customer Due Diligence (CDD): Verify identities using reliable, independent documents and data.
• Enhanced Due Diligence (EDD): Apply stricter measures for Politically Exposed Persons (PEPs), high-risk clients, and unusual transactions.
• Ongoing Monitoring: Continuously monitor transactions to detect suspicious or unusual behavior.
• Record Keeping: Retain KYC documentation and transaction records for at least 5 years.
• Risk-Based Approach: Assess and manage risks according to the nature of the customer, business relationship, and geographic exposure.

4. Governance & Responsibilities

• Board of Directors: Approves this KYC Policy and oversees its implementation.
  • Ayoola Awosemo, Director
• AML Compliance Officer (AMLCO): Ensures KYC compliance, training, and reporting to regulators.
  
• Employees: Must adhere to KYC procedures, perform due diligence, and escalate suspicious activities.

5. Customer Identification & Verification

Before onboarding, customers must provide valid and verifiable information:

• Individuals: Government-issued ID (National ID, Passport, Driver’s License), Bank Verification Number (BVN), proof of address, and valid phone/email.
• Corporate Entities: Certificate of Incorporation, CAC forms, Board Resolution, Tax Identification Number (TIN), Memorandum & Articles of Association, details of directors and beneficial owners.
• Beneficial Ownership: Ultimate beneficial owners (UBOs) must be identified and verified.
• Non-Residents: Additional scrutiny including international sanctions screening and source of funds checks.

6. Risk Assessment & Categorization

CIPAGO applies a risk-based approach by classifying customers into:

• Low Risk: Salaried employees, government workers, reputable institutions.
• Medium Risk: Small businesses, traders, NGOs with verified sources of funds.
• High Risk: PEPs, cross-border clients, cash-intensive businesses, clients from high-risk jurisdictions.

Enhanced Due Diligence (EDD) is mandatory for all high-risk customers.

7. Ongoing Monitoring

Post-onboarding, CIPAGO monitors customer activity continuously:

• Automated transaction monitoring for red flags.
• Review of unusual or complex transactions inconsistent with customer profiles.
• Periodic KYC refresh for long-term clients (every 1-3 years depending on risk level).
• Screening against updated sanctions and watchlists.

8. Data Protection & Confidentiality

Customer information is protected under the Nigeria Data Protection Act and GDPR principles. Data collected for KYC will only be used for compliance purposes and shared strictly with authorized regulators when required by law.

9. Training & Awareness

All employees receive annual KYC/AML training covering onboarding, risk rating, red flags, escalation procedures, and regulatory obligations.

10. Penalties for Non-Compliance

Failure to adhere to this KYC Policy may result in disciplinary action, including termination of employment, blacklisting of agents/partners, regulatory fines, and criminal prosecution under Nigerian law.

11. Policy Review

This policy will be reviewed annually, or sooner if required by changes in law, regulation, or risk environment.