AML / CTF Policy

01Purpose and Scope

This Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy applies to every person who creates a jetazap account or uses any jetazap service, and to all directors, staff, contractors and partners who handle customer funds or data on our behalf.

We design our controls with reference to Nigerian law, including the Money Laundering (Prevention and Prohibition) Act, the Terrorism (Prevention and Prohibition) Act, and guidance issued by the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU) and other competent authorities, together with the requirements of our licensed payment and card partners.

02Our Commitments

• We will not knowingly accept, move or hold funds derived from criminal activity.
• We verify customers before enabling higher-risk services such as the virtual dollar card.
• We monitor transactions and investigate unusual activity (see our Transaction Monitoring Policy).
• We report suspicious activity to the relevant authorities where the law requires or permits us to.
• We keep records and train our team so these controls work in practice, not only on paper.

03Governance and Responsibilities

Senior management is accountable for this policy. A designated Compliance Officer is responsible for day-to-day oversight, for approving policy updates, for reviewing escalated alerts and for acting as the contact point with regulators and partners.

All staff with access to customer accounts or payment operations must complete AML/CTF awareness training on joining and at least once a year, and must escalate suspicious activity immediately rather than investigating it themselves.

04Risk-Based Approach

We assess risk by customer type, product, funding method, transaction size and pattern, and geography. Higher-risk situations receive more verification and closer monitoring.

05Customer Due Diligence

We apply customer due diligence in line with our KYC Policy. Enhanced due diligence is applied to higher-risk customers and may include additional identity documents, source-of-funds information and senior management approval before a service is enabled.

If we cannot complete due diligence, we will not open the account or enable the service, and we may restrict or close an existing account.

06Sanctions and Prohibited Activity

We do not provide services to persons or entities subject to applicable sanctions, or use the platform for sanctioned activity. We may screen users and transactions against relevant sanctions and watch lists.

• Using jetazap to hide the origin of funds or to move funds for a third party you have not disclosed.
• Splitting transactions to avoid limits or checks.
• Allowing another person to use your account or card.
• Funding terrorism, proliferation or any unlawful activity.

07Suspicious Activity Reporting

Where we know or suspect that a transaction or attempted transaction involves proceeds of crime or terrorist financing, we will report it to the competent authority as required by law.

08Record Keeping

We keep identity records, transaction records and reports for the period required by Nigerian law and our partners, which is generally at least five years after the end of the relationship or the transaction, and longer where required for a legal or regulatory purpose.

09Review of this Policy

This policy is reviewed at least annually and whenever the law, our products or our risk profile change significantly. Questions can be sent to support@usejeta.com.ng.