AML & KYC Policy

XexoPay is committed to preventing its Services from being used for money laundering, terrorist financing, proliferation financing or fraud. This page summarises the controls we apply. It is a public summary of our internal AML/CFT/CPF programme.

1. Know your customer

We verify the identity of every customer before or as they start using the Services. Account levels, the information required and the limits that apply follow the Central Bank of Nigeria’s tiered KYC framework. The limits for each level are shown in the app.

Level	What we ask for
Tier 1	Name, phone number, date of birth, and BVN or NIN
Tier 2	Tier 1, plus a verified BVN or NIN and a government-issued ID
Tier 3	Tier 2, plus a verified residential address

We may ask for more information or documents at any time, for example if your activity changes or we need to understand the source of funds.

2. Screening and monitoring

We screen customers against sanctions lists and lists of politically exposed persons, and apply enhanced checks where needed.
We monitor transactions for unusual or suspicious activity.
We do not open or keep anonymous accounts or accounts in obviously false names.

3. Reporting

Where the law requires, we report suspicious transactions and other prescribed transactions to the Nigerian Financial Intelligence Unit. The law does not allow us to tell a customer that a report has been made.

4. Actions we may take

We may delay or refuse a transaction, freeze funds, restrict or close an account, or decline to open one, where we have reasonable grounds to suspect money laundering, terrorist financing, fraud or a breach of sanctions, or where a regulator or court directs us to.

5. Record keeping

We keep identification and transaction records for at least 5 years after an account is closed or a transaction is completed, as the law requires. See our Privacy Policy.

6. Staff and governance