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Legal Document

Buselor Anti-Money Laundering (AML) Policy

Document Type
AML Policy
Effective Date
August 2026
Regulator
CBN / NFIU / EFCC

warning Important: This policy is issued pursuant to the Money Laundering (Prevention and Prohibition) Act 2022, the Nigerian Financial Intelligence Unit Act 2018, and the Central Bank of Nigeria's Baseline Standards for Automated AML Solutions (Circular No. BSD/DIR/PUB/LAB/019/002 dated 10 March 2026).

Introduction and Policy Statement

Buselor is a Settlement-Driven Commerce Infrastructure that enables trusted buying and selling through protected payments, controlled merchant settlements, and integrated logistics. As a platform that processes financial transactions and holds customer funds in partnership with VFD Microfinance Bank Limited, we operate at the heart of Nigeria's financial system.

We recognise the significant responsibility this entails. Buselor is fully committed to preventing the use of our platform for money laundering or any other financial crime. We will not tolerate any activity that undermines the integrity of the financial system or poses a risk to our users, partners, or the broader Nigerian economy.

This Policy is issued in compliance with:

  • The Money Laundering (Prevention and Prohibition) Act 2022 (MLPPA)
  • The Nigerian Financial Intelligence Unit (NFIU) Act 2018
  • The Proceeds of Crime (Recovery and Management) Act 2022
  • The Central Bank of Nigeria (CBN) Guidelines and Circulars, including:
    • CBN Circular No. BSD/DIR/PUB/LAB/019/002 on Baseline Standards for Automated Anti-Money Laundering Solutions for Financial Institutions in Nigeria (10 March 2026)
    • All applicable CBN AML regulations
  • The Financial Action Task Force (FATF) 40 Recommendations and international standards
verified Our Commitment

Buselor will:

  • Deploy robust automated AML systems as mandated by the CBN Baseline Standards
  • Conduct thorough Know Your Customer (KYC) and Customer Due Diligence (CDD) checks
  • Monitor all transactions in real-time for suspicious activity
  • Report suspicious transactions to the NFIU within 24 hours of suspicion forming
  • Cooperate fully with law enforcement and regulatory authorities
  • Maintain comprehensive records for regulatory audit and review
  • Protect customer data in accordance with the Nigeria Data Protection Act 2023

Definitions

Term Definition
AML Anti-Money Laundering
CDD Customer Due Diligence
EDD Enhanced Due Diligence
STR Suspicious Transaction Report
NFIU Nigerian Financial Intelligence Unit
CBN Central Bank of Nigeria
EFCC Economic and Financial Crimes Commission
FATF Financial Action Task Force
PEP Politically Exposed Person
BVN Bank Verification Number
NIN National Identification Number
PND Post-No-Debit
Settlement ID A globally unique identifier assigned to every Buselor transaction (e.g., BST-YYYYMMDD-XXXXXX). This ID is the single source of truth for all financial and physical fulfillment activities.

What is Money Laundering?

Money laundering is the process by which criminals disguise the illegal origins of their funds to make them appear legitimate. It is a critical enabler of all serious and organized crime, including drug trafficking, human trafficking, corruption, fraud, and tax evasion.

Money laundering typically involves three stages:

payments

3.1. Placement

The physical disposal of cash or other assets derived from criminal activity. This is the most vulnerable stage for the launderer, as large amounts of cash are difficult to integrate into the financial system without detection.

Examples relevant to Buselor:

  • Using Buselor to convert cash proceeds of crime into digital wallet balances
  • Funding a Buselor wallet with illicit cash through third-party agents
  • Using multiple small deposits to avoid detection (structuring)
layers

3.2. Layering

The separation of illicit proceeds from their origin through complex financial transactions designed to obscure the audit trail. This is the most complex stage, involving multiple transactions and jurisdictions.

Examples relevant to Buselor:

  • Moving funds between multiple Buselor wallets
  • Using Buselor's settlement mechanism to layer funds through multiple transactions
  • Combining legitimate and illegitimate funds in a single wallet
check_circle

3.3. Integration

The re-introduction of laundered funds into the legitimate economy, making them appear to have originated from a legitimate source.

Examples relevant to Buselor:

  • Withdrawing laundered funds from a Buselor wallet to a bank account
  • Using laundered funds to make purchases through Buselor Express
  • Using laundered funds to pay for goods and services that create a legitimate business record

Legal and Regulatory Framework

4.1. The Money Laundering (Prevention and Prohibition) Act 2022 This Act, signed into law by President Muhammadu Buhari in 2022, repealed the Money Laundering (Prohibition) Act 2011 and strengthened Nigeria's AML framework. Key provisions relevant to Buselor include:
  • Section 7: Mandates reporting entities to render STRs to the NFIU within 24 hours of a transaction being deemed suspicious
  • Section 8: Requires financial institutions to verify customer identity and maintain records
  • Section 9: Prohibits anonymous accounts and requires proper identification of customers
  • Section 10: Mandates reporting of cash transactions above specified thresholds
  • Section 15: Establishes penalties for non-compliance, including substantial fines and imprisonment
  • Section 26: Requires financial institutions to implement AML policies and procedures
  • Section 27: Mandates training of employees on AML obligations
4.2. The Proceeds of Crime (Recovery and Management) Act 2022 This Act makes comprehensive provisions for the seizure, confiscation, forfeiture, and management of properties derived from unlawful activity. It mandates:
  • The creation of dedicated accounts for proceeds of crime and confiscated assets
  • Enhanced accountability mechanisms for asset recovery
  • Cooperation between financial institutions and law enforcement in asset recovery efforts
4.3. The Nigerian Financial Intelligence Unit (NFIU) Act 2018 The NFIU is Nigeria's central agency for receiving, analyzing, and disseminating financial intelligence. Key obligations include:
  • All financial institutions must report suspicious transactions to the NFIU
  • The NFIU has the power to issue guidelines on STR reporting
  • The NFIU maintains a database of STRs for use by law enforcement
4.4. CBN Baseline Standards for Automated AML Solutions On 10 March 2026, the CBN issued Circular No. BSD/DIR/PUB/LAB/019/002 mandating all financial institutions to deploy automated, technology-driven AML systems.
  • Scope: Applies to all CBN-regulated institutions, including payment service providers, fintechs, and mobile money operators
  • Core Functions: Automated systems must support: customer identification and verification, customer risk assessment, sanction and watchlist screening, PEP screening, transaction monitoring, case management, regulatory reporting, audit and governance, and data protection
  • Technology: The CBN encourages adoption of AI, machine learning, and advanced analytics
  • Timelines: Full compliance within 24 months (by June 2028)
4.5. Nigeria's FATF Grey List Exit Nigeria was removed from the FATF grey list in October 2025. This milestone signifies that Nigeria has made the necessary reforms to address AML weaknesses, but also means that continued progress and sustained compliance are essential. The CBN's AML Baseline Standards are a direct response to post-grey list obligations.

Buselor's AML Framework

5.1. Governance and Oversight

Board and Senior Management Commitment: Buselor's Board of Directors and Senior Management are fully committed to AML compliance. The Board has designated a senior executive as the Money Laundering Reporting Officer (MLRO) with primary responsibility for overseeing the AML program, ensuring compliance, reporting to management, and serving as the primary point of contact with the NFIU, CBN, and other regulatory authorities.

AML Compliance Team: Buselor maintains a dedicated AML Compliance Team with sufficient resources, authority, and independence to effectively implement the AML program.

5.2. Risk Assessment Buselor conducts regular, documented risk assessments to identify and evaluate ML risks associated with products and services, customer types and geographies, delivery channels, and business relationships. Risk assessments are reviewed and updated annually, or more frequently if significant changes occur.
5.3. Customer Due Diligence (CDD)

Standard CDD: Before establishing a business relationship or carrying out a transaction, Buselor must identify and verify the customer's identity, identify beneficial owners, understand the purpose of the business relationship, and conduct ongoing due diligence.

Verification Methods: Buselor uses automated identity verification systems integrated with national infrastructure such as BVN and NIN databases.

Tiered KYC: In compliance with CBN requirements, Buselor operates a three-tiered KYC system:

  • Tier 1 Full legal name, phone number (OTP verification), email address
  • Tier 2 BVN or NIN, government-issued ID, passport photograph
  • Tier 3 CAC documentation (for businesses), physical address verification, utility bill, valid government ID
5.4. Enhanced Due Diligence (EDD) EDD is required for customers identified as higher risk, including PEPs, customers from high-risk jurisdictions, non-face-to-face customers, unusual or complex transaction patterns, and customers with significant unexplained wealth. EDD measures include obtaining additional information, seeking senior management approval, conducting enhanced monitoring, and reviewing source of funds and wealth.
5.5. PEP and Sanctions Screening Buselor screens all customers, beneficial owners, and counterparties against domestic and international sanctions lists, PEP registers, internal watchlists, and adverse media sources. Screening is conducted at onboarding, on a periodic basis (at least quarterly), and immediately when sanctions lists are updated.

Transaction Monitoring

6.1. Automated Transaction Monitoring System Buselor deploys an automated transaction monitoring system that meets the CBN Baseline Standards. The system uses advanced analytics, data monitoring tools, and AI to:
  • Track large volumes of transactions in real-time
  • Flag unusual patterns and generate alerts
  • Assess activity in the context of the full customer profile
  • Monitor transactions across relevant channels in real-time or near-real-time
6.2. Red Flags and Indicators

Buselor's transaction monitoring system is designed to detect red flags including, but not limited to:

Transaction Pattern Red Flags:

  • Structuring: Breaking down transactions to avoid reporting thresholds
  • Unusually large transactions: Inconsistent with customer profile or business activity
  • Rapid movement of funds: Depositing and immediately withdrawing to a different account
  • Multiple small transactions: High volume over a short period inconsistent with normal activity
  • Transactions involving high-risk jurisdictions: Jurisdictions identified by the FATF
  • Circular transactions: Funds moving through multiple accounts and returning to the source
  • Sudden change in patterns: Significant deviation from established history

Buselor-Specific Red Flags:

  • Transactions involving prohibited virtual assets (cryptocurrencies, NFTs, stablecoins)
  • Unusually high-value transactions from accounts with minimal prior activity
  • High volume of transactions from accounts with incomplete KYC
  • Multiple guest checkouts from the same IP address using different identities
  • Seller anomalies: Sellers with unusually high transaction volume but minimal physical presence
  • Multiple stores with inconsistent business profiles
  • Rapid merchant onboarding: Sudden spike in merchant registrations with similar characteristics
  • Unusual settlement patterns or account changes
  • Inconsistent product listings: Products at values significantly above or below market rates
  • Frequent disputes inconsistent with normal commerce activity
6.3. Suspicious Transaction Reporting (STR) A suspicion is formed when the AML Compliance Team determines, based on a thorough examination, that there are reasonable grounds to suspect the transaction is related to money laundering. STRs are filed with the NFIU within 24 hours of suspicion being formed.

Prohibited Activities

block 7.1. Cryptocurrency and Virtual Assets Ban

In accordance with CBN guidance and the Securities and Exchange Commission (SEC) Nigeria regulations, Buselor strictly prohibits the use of our platform for:

  • Buying, selling, or facilitating transactions in cryptocurrencies (e.g., Bitcoin, Ethereum, USDT)
  • Non-Fungible Tokens (NFTs)
  • Stablecoins
  • Digital bonds
  • Any other digital virtual assets classified as securities

warning Consequences: Any user found using Buselor's platform for these purposes will have their account permanently terminated, all pending funds frozen, an STR filed with the NFIU, and details shared with regulatory authorities as required by law.

7.2. Other Prohibited Activities Users are prohibited from using Buselor for:
  • Money laundering
  • Fraud (including account takeover, identity theft, and card fraud)
  • Transactions involving illegal goods or services
  • Structuring transactions to avoid reporting thresholds
  • Tax evasion
  • Corruption and bribery
  • Any other activity that violates Nigerian law or our Terms of Service

Staff Training and Awareness

8.1. Training Program

Initial Training: All new employees receive AML training within their first month, covering legal and regulatory framework, Buselor's AML policy and procedures, types of ML activity and red flags, reporting obligations, and consequences of non-compliance.

Ongoing Training: Annual refresher training for all employees, specialized training for compliance, operations, and customer support staff, and updates whenever significant regulatory changes occur.

Training Records: All training activities are documented and maintained for regulatory review.

Regulatory Reporting and Cooperation

9.1. Suspicious Transaction Reports Buselor files Suspicious Transaction Reports with the NFIU in accordance with MLPPA Section 7 (within 24 hours of suspicion forming).
9.2. Cooperation with Authorities Buselor cooperates fully with the NFIU, CBN, EFCC, and other law enforcement and regulatory authorities. Cooperation includes responding promptly to information requests, providing access to records and systems, complying with court orders, assisting in investigations, and providing expert testimony where required.
9.3. Audit and Examination Buselor is subject to regulatory examinations by the CBN, AML inspections by the NFIU, and internal and external audits. Buselor maintains all records and systems in a state of readiness for regulatory examination at all times.

Penalties and Sanctions for Non-Compliance

10.1. For Users Users who violate this AML Policy may face:
  • Account suspension or permanent termination
  • Post-No-Debit (PND) restriction on all accounts and pending funds
  • Reporting to the NFIU
  • Referral to law enforcement (EFCC)
  • Civil and criminal liability
  • Asset forfeiture
  • Financial penalties under the MLPPA
10.2. For Buselor Non-compliance with AML regulations exposes Buselor to:
  • Regulatory fines and sanctions
  • Reputational damage
  • Criminal liability for directors and officers
  • Potential delisting from partner programs
  • Loss of banking relationships
  • Regulatory enforcement actions

Buselor is fully committed to maintaining a robust AML program to avoid these consequences.

Contact Information

Money Laundering Reporting Officer (MLRO)

Email: [email protected]

AML Compliance Team

Email: [email protected]

Regulatory Reporting

Email: [email protected]

Whistleblower Reporting

Email: [email protected]

All reports are treated confidentially, and reporters are protected from retaliation as provided by law.

info Policy Acknowledgment: By using Buselor's platform, you acknowledge that you have read, understood, and agree to comply with this AML Policy. You understand that Buselor is required by law to verify your identity, monitor transactions for suspicious activity, and file reports with the NFIU as required by law.

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