AML / KYC Policy
Last Updated: May 21, 2026
Qugo is dedicated to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This AML/KYC Policy outlines our protocols for identity verification, transaction monitoring, and risk mitigation in compliance with the Nigerian Money Laundering (Prevention and Prohibition) Act.
1. Regulatory Compliance Framework
Qugo operates in compliance with local and international regulatory standards:
- Money Laundering (Prevention and Prohibition) Act: We implement compliance frameworks designed to prevent, detect, and report laundering practices.
- SCUML & NFIU Reporting: In accordance with statutory guidelines, we coordinate with the Special Control Unit Against Money Laundering (SCUML) and fulfill reporting obligations with the Nigerian Financial Intelligence Unit (NFIU) for suspicious activity reports (SARs) and threshold transaction reports (TTRs).
2. Customer Verification Tiers (KYC)
To prevent unauthorized use and verify user identities, we enforce a strict, tiered verification system. All verification is handled programmatically:
| Tier Level | Required Verification Documentation | Daily Transaction Limit |
|---|---|---|
| Tier 1 | Full Name, Verified Email, Phone Number, Bank Verification Number (BVN) check. | ₦50,000 |
| Tier 2 | Tier 1 criteria + Government Issued ID (National Identification Number/NIN, Voter Card, or Passport). | ₦500,000 |
| Tier 3 | Tier 2 criteria + Liveness Detection facial verification check & Proof of Address. | ₦5,000,000+ |
3. Identity Verification Checks
Facial Verification: Tier 3 verification requires a biometric facial recognition scan (Liveness Check) to verify that the person creating the account matches the identification documentation submitted. This process is powered securely by our KYC processors, Prembly and Smile ID. We do not store biometric templates on our systems.
4. Transaction Monitoring & Flags
Our compliance team uses automated systems to monitor transaction patterns for suspicious behavior. Accounts displaying unusual frequency, volume anomalies, or structural irregularities may be flagged for manual review, resulting in temporary transaction freezes pending receipt of source-of-funds documentation.
5. Sanctions Screening
Qugo regularly screens all registered users against local and international sanctions databases, including Office of Foreign Assets Control (OFAC) and local PEP (Politically Exposed Persons) databases. Accounts matching sanctioned records will be blocked immediately.
6. Policy Updates & Contact
We update our AML/KYC guidelines dynamically as regulatory requirements evolve. For inquiries or reporting, contact us at aml@qugo.app.