🛡️ Compliance

AML / KYC Policy

Our commitment to preventing money laundering and financial crime

CBN AML/CFT Framework 2022 · Finance Act 2026 · FATF Aligned

Our Commitment

JasonPay maintains a zero-tolerance policy towards money laundering, terrorist financing, proliferation financing, and any other form of financial crime. We operate in full compliance with the CBN Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Framework, the Money Laundering (Prevention and Prohibition) Act 2022, and all applicable FATF recommendations.

Customer Due Diligence (CDD)

KYC Tier Structure

Tier	Requirements	Daily Limit	Single Tx Limit
Tier 1	Phone number + BVN	₦300,000	₦50,000
Tier 2	Tier 1 + Address verification	₦1,000,000	₦200,000
Tier 3	Tier 2 + NIN + Enhanced review	Unlimited	₦5,000,000

Enhanced Due Diligence (EDD)

EDD is applied automatically for:

Politically Exposed Persons (PEPs) and their immediate families
Transactions above ₦5,000,000 in a single session
High-risk jurisdictions (FATF grey/black list countries)
Unusual transaction velocity patterns
Business accounts with complex ownership structures

Transaction Monitoring

Our automated monitoring system continuously evaluates:

Transaction velocity — frequency of transactions within defined periods
Amount thresholds — automatic alerts for transactions above CBN-defined limits
Behavioural patterns — deviations from established account behaviour
Beneficiary risk profiling — cross-referencing against sanctions and watchlists
Geographic risk — originating and destination country risk scoring

Suspicious Activity Reporting (SAR)

All suspicious transactions are reported to the Nigerian Financial Intelligence Unit (NFIU) in accordance with the Money Laundering (Prevention and Prohibition) Act 2022. JasonPay staff are prohibited from "tipping off" any customer under investigation.

Sanctions Screening

JasonPay screens all customers and transactions against:

UN Security Council consolidated sanctions list
OFAC Specially Designated Nationals (SDN) list
EU consolidated sanctions list
CBN/NFIU watchlists

Record Keeping

All KYC documents and transaction records are retained for a minimum of 5 years after the end of the business relationship, and 7 years for transaction records, in compliance with CBN regulations.

Contact

AML Compliance Officer: compliance@jasonpaybank.com

To report suspected financial crime: fraud@jasonpaybank.com

NFIU whistleblower: nfiu.gov.ng