AML & KYC Policy

Swaply is committed to maintaining the highest standards of integrity and compliance with the following laws and regulations:

• Money Laundering (Prohibition) Act, 2011 (as amended)
• Terrorism (Prevention) (Amendment) Act, 2013
• Central Bank of Nigeria (CBN) AML/CFT Regulations
• Economic and Financial Crimes Commission (EFCC) Act
• Nigerian Financial Intelligence Unit (NFIU) directives
• United Nations sanctions regimes implemented in Nigeria

We operate a risk-based AML/CFT program in line with the Financial Action Task Force (FATF) Recommendations and the Nigerian legal framework. The program is reviewed and updated at least annually.

We collect and verify customer identity information at registration and on an ongoing basis. Required information includes:

• Full legal name, date of birth, and nationality
• Residential address and contact details
• Government-issued identification number (NIN, BVN, or passport)
• Tax Identification Number (TIN), where applicable
• Source of funds and source of wealth (for higher tiers)
• Photograph and liveness check

Identity is verified using independent, reliable sources such as government databases and accredited KYC vendors.

We use automated systems and human analysts to monitor transactions for red flags including:

• Unusual transaction patterns inconsistent with customer profile
• Rapid in-and-out movement of funds (pass-through behaviour)
• High-risk jurisdictions or counter-parties
• Cash-intensive or anonymity-seeking behaviours
• Transactions just below reporting thresholds (structuring)

We file Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs) with the NFIU as required by law. We do not inform customers that a report has been filed. Knowingly tipping off a customer of a report is a criminal offence.

All customers are screened against Nigerian, African, UN, EU, US OFAC, and UK HMT sanctions lists, as well as PEP and adverse media databases. Screening runs at onboarding and continuously thereafter. Matches are reviewed and escalated as required.

We maintain KYC records, transaction records, and supporting documents for at least 5 years after the end of the business relationship, in line with regulatory requirements.

Relevant staff receive mandatory AML/CFT training on induction and at least annually. Our AML program is independently audited periodically.

For compliance-related enquiries, contact our Compliance Officer: