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AML / CFT POLICY

Last Updated: May 2025

Spectra Technologies Limited — Anti-Money Laundering and Counter-Financing of Terrorism Policy

POLICY STATEMENT

Spectra Technologies Limited is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) compliance. This policy is designed to prevent SpectraPay and its platform from being used as a vehicle for financial crime, money laundering, or the financing of terrorism.

This policy is maintained in compliance with:

  • The Money Laundering (Prevention and Prohibition) Act 2022
  • The Economic and Financial Crimes Commission (EFCC) Act
  • Central Bank of Nigeria (CBN) AML/CFT Regulations
  • Financial Action Task Force (FATF) Recommendations
  • All other applicable Nigerian laws and regulations

ANTI-MONEY LAUNDERING OFFICER

SpectraPay has appointed a designated Anti-Money Laundering and Counter-Financing of Terrorism Reporting Officer (AMLCFTRO) responsible for:

  • Overseeing all AML/CFT compliance activities
  • Reviewing and filing Suspicious Activity Reports (SARs)
  • Maintaining AML records
  • Ensuring staff training and awareness
  • Liaising with relevant Nigerian authorities including the NFIU, EFCC, and CBN

KNOW YOUR CUSTOMER (KYC) PROCEDURES

SpectraPay operates a tiered KYC system to verify the identity of all users before granting access to the full range of platform services.

Tier 0 — Basic registration (name, email, phone number). Limited platform access. Tier 1 — Email and phone number verification. Standard transaction limits apply. Tier 2 — BVN submission and biometric identity verification via Dojah (our licensed KYC provider). Full platform access and unlimited withdrawals unlocked.

Acceptable identity documents include: current valid Nigerian passport, national identity card (NIN slip or card), permanent voter's card, or valid driver's licence. All identity documents are verified against government databases. BVN is validated through licensed financial data providers in compliance with CBN guidelines.

CUSTOMER DUE DILIGENCE (CDD)

SpectraPay conducts standard CDD on all users and enhanced due diligence (EDD) on high-risk users, including Politically Exposed Persons (PEPs) and users whose transaction patterns indicate elevated risk.

Users are classified as low, medium, or high risk. KYC records are reviewed and updated as follows:

High-Risk Users — every 1 year Medium-Risk Users — every 2 years Low-Risk Users — every 5 years

POLITICALLY EXPOSED PERSONS (PEPs)

SpectraPay screens all users against PEP databases. A PEP is any individual who holds or has held a prominent public function within the preceding year, including their close family members and known associates.

PEP status alone does not disqualify a user, but triggers Enhanced Due Diligence, including source-of-funds verification and senior management approval before account activation.

TRANSACTION MONITORING

SpectraPay conducts ongoing monitoring of user transactions to identify unusual or suspicious activity. Red flags that trigger review include:

  • Sudden large increases in transaction volume inconsistent with a user's profile
  • Multiple transactions structured to avoid reporting thresholds
  • Deposits or withdrawals to/from high-risk jurisdictions
  • Patterns inconsistent with the user's stated purpose of account
  • Repeated failed KYC attempts followed by successful ones

Flagged transactions are reviewed by the AMLCFTRO. Where suspicion is confirmed, a Suspicious Activity Report (SAR) is filed with the Nigerian Financial Intelligence Unit (NFIU) or other competent authority.

PROHIBITED ACTIVITIES AND PERSONS

SpectraPay does not provide services to:

  • Individuals or entities on UN, OFAC, EU, or UK Treasury sanctions lists
  • Residents of sanctioned jurisdictions (including North Korea, Iran, Syria, Cuba, and Crimea)
  • Shell companies with unverifiable beneficial ownership
  • Businesses involved in illegal activities including drug trafficking, human trafficking, or terrorism financing
  • Cryptocurrency mixers or privacy coin services that obscure transaction origins
  • Unregistered or unlicensed money service businesses

SUSPICIOUS ACTIVITY REPORTING

Where SpectraPay's AMLCFTRO has knowledge or reasonable suspicion of money laundering or terrorist financing, a Suspicious Activity Report (SAR) will be submitted to the Nigerian Financial Intelligence Unit (NFIU), the EFCC, or any other relevant competent authority.

SpectraPay will cooperate fully with law enforcement agencies in all investigations.

RECORD KEEPING

All identity verification records, transaction records, and filed SARs are retained for a minimum of five (5) years from the date of the transaction or account closure, in accordance with Nigerian AML regulations.

All records are stored securely and can be retrieved without undue delay upon lawful request.

INTERNATIONAL SANCTIONS SCREENING

SpectraPay screens all users and transactions against the following sanctions lists:

  • United Nations consolidated sanctions list
  • US Office of Foreign Assets Control (OFAC) SDN list
  • European Union consolidated sanctions list
  • UK HM Treasury financial sanctions list
  • CBN regulatory watch lists

Screening is conducted at onboarding and on an ongoing basis. Any match triggers an immediate account freeze pending AMLCFTRO review.

STAFF TRAINING

All SpectraPay team members with access to user data or compliance functions receive AML/CFT training at onboarding and at least once per quarter thereafter.

Training covers identification of suspicious activity, KYC procedures, SAR filing obligations, and international sanctions compliance.

CONTACT

For AML/CFT-related enquiries or to report suspicious activity, contact our compliance team at: compliance@spectrapay.io