Vendyz Technologies recognizes the critical importance of adhering to global and local regulations that prevent financial crimes, including money laundering and terrorist financing. As a forward-thinking technology company operating in Nigeria, we are committed to the highest standards of integrity and ethical business practices. To safeguard our operations and protect our customers, employees, and stakeholders, Vendyz has developed an Anti-Money Laundering (AML) Policy that aligns with the Nigerian anti-money laundering legal framework and international best practices.

This document serves as a comprehensive guide for all employees, contractors, and agents of Vendyz, outlining the measures we take to identify, prevent, detect, and report suspicious financial activities that could be linked to money laundering or other financial crimes.

The purpose of Vendyz’s AML Policy is to provide a structured framework that ensures our compliance with all applicable anti-money laundering laws and regulations, including but not limited to the Nigerian Money Laundering (Prevention and Prohibition) Act. Our policy aims to:

  • Prevent the use of Vendyz’s services for money laundering or terrorist financing purposes.
  • Protect the integrity and reputation of the company.
  • Ensure that all employees and representatives are aware of their legal and regulatory obligations.
  • Implement a robust system of internal controls, processes, and practices to detect and report suspicious activities.
  • Train employees to recognize and address money laundering risks.

This policy applies to all employees, contractors, agents, and partners of Vendyz, regardless of their role or position. Whether interacting directly with customers, handling transactions, or performing backend operations, each individual is expected to adhere to the provisions outlined in this policy. Any individual found violating the policy will be subject to disciplinary action, which may include termination of employment or legal proceedings where necessary.

a. Customer Due Diligence (CDD)

Customer Due Diligence (CDD) is an essential process for identifying and verifying the identity of our customers before they can engage with our services. This process enables Vendyz to assess the risk profile of each customer and ensure that we are not facilitating illegal activities.

Key CDD Activities:

  • Know Your Customer (KYC): All customers must undergo a KYC verification process, which includes obtaining and validating government-issued identification (e.g., national ID, passport) and proof of address.
  • Source of Funds: Vendyz will require documentation to ascertain the legitimacy of a customer’s funds or financial transactions. This step ensures that the money being used in our platform is not derived from illegal activities such as fraud, drug trafficking, or corruption.
  • Enhanced Due Diligence (EDD): For customers who present a higher risk (e.g., politically exposed persons or individuals with suspicious transaction patterns), Vendyz will perform Enhanced Due Diligence (EDD), which may involve deeper scrutiny and continuous monitoring of the customer’s financial activities.


b. Suspicious Activity Reporting (SAR)

All employees, contractors, and agents of Vendyz are required to remain vigilant and report any transactions or customer behavior that may indicate money laundering or other financial crimes. Suspicious activity may include, but is not limited to:

  • Unexplained large or frequent cash transactions.
  • Attempts to transfer funds to or from high-risk jurisdictions.
  • Complex or illogical transaction structures that seem to lack a legitimate business purpose.
  • Customers avoiding the KYC process or providing false or misleading information.

Reporting Procedures:

  • Employees must report suspicious activities immediately to the designated Compliance Officer.
  • The Compliance Officer will evaluate the report and determine whether to file a Suspicious Transaction Report (STR) with relevant authorities, such as the Nigerian Financial Intelligence Unit (NFIU).
  • All reports of suspicious activity must be kept confidential and employees are prohibited from alerting the customer that a report has been made (a practice known as “tipping off”).


c. Record Keeping

In compliance with Nigerian AML laws, Vendyz is committed to maintaining comprehensive and accurate records of all customer transactions and activities for a specified retention period. This process is critical to ensure that we can support investigations and audits by regulatory bodies, if required.

 Key Aspects of Record Keeping:

  • Retention Period: All records related to customer identification (KYC), transaction histories, and suspicious activity reports must be kept for at least five years after the end of the customer relationship.
  • Accessibility: Records must be stored securely but also be readily accessible to authorized personnel, including law enforcement and regulatory authorities, during investigations or audits.
  • Data Security: Vendyz will implement advanced data protection measures to ensure that sensitive customer information is not compromised or accessed by unauthorized individuals.


d. Training and Education

Continuous education is key to building an informed and vigilant workforce. All employees at Vendyz, especially those in customer-facing roles, are required to undergo regular training on AML laws, company policies, and the latest money laundering typologies.

Training Components:

  • Regulatory Requirements: Employees will be trained on Nigeria’s AML regulations and Vendyz’s specific obligations under those laws.
  • Red Flags: Employees will be educated on the common red flags of money laundering and how to recognize them in customer transactions or behaviors.
  • Internal Processes: Training will include a thorough understanding of Vendyz’s internal reporting procedures, including how to submit a Suspicious Activity Report (SAR).
  • Updates and Refresher Courses: Vendyz will provide periodic updates on changes to AML regulations and emerging trends in financial crime. Refresher courses will also be mandated to ensure all employees stay current with best practices.

 

e. Independent Compliance Officer

To oversee our AML efforts, Vendyz will appoint a dedicated Compliance Officer. This individual will have the expertise and authority to ensure that all aspects of the AML program are effectively implemented and enforced across the organization.

Responsibilities of the Compliance Officer:

  • Overseeing the execution of the AML Policy, including customer due diligence, monitoring, and suspicious activity reporting.
  • Acting as the primary point of contact between Vendyz and external regulatory authorities.
  • Conducting regular reviews and audits of Vendyz’s AML program to ensure its effectiveness and compliance with changing regulations.
  • Delivering ongoing employee training and ensuring that all staff are aware of their responsibilities under the AML Policy.
  • Filing Suspicious Transaction Reports (STRs) with the Nigerian Financial Intelligence Unit (NFIU) as required.

Vendyz recognizes that the financial landscape and regulatory environment are constantly evolving. To ensure that our AML Policy remains effective and compliant with current laws, we will conduct regular reviews and updates. The Compliance Officer will spearhead this effort, supported by senior management, to:

  • Evaluate the effectiveness of current AML measures.
  • Incorporate new regulatory requirements.
  • Address any gaps or weaknesses identified in the company’s anti-money laundering defenses.
  • Adjust the scope of training and internal controls as necessary.

Additionally, Vendyz will engage external auditors or consultants to perform independent evaluations of the AML program as part of our commitment to best practices.

Vendyz Technologies takes its responsibility to combat money laundering seriously. By adhering to this comprehensive AML Policy, we aim to prevent, detect, and report any suspicious activities that could threaten the integrity of our business or the wider financial system. Every employee, contractor, and agent of Vendyz is empowered and obligated to contribute to this effort, ensuring that we continue to operate in a legal, ethical, and transparent manner.

In collaboration with local authorities and international partners, Vendyz will continue to uphold its commitment to fighting financial crime, safeguarding the company, and protecting its customers and the broader community.