Anti-Money Laundering (AML/CFT) Policy

CodedFone does not tolerate money laundering, terrorist financing or the use of its services to move the proceeds of crime. This policy explains how we prevent, detect and report such activity on www.codedfone.com.

1. Scope

This policy applies to all CodedFone customers, staff, contractors and agents, and to every service we offer, with particular attention to gift card transactions, which carry a higher risk of misuse.

2. Legal Basis

• Money Laundering (Prevention and Prohibition) Act 2022
• Terrorism (Prevention and Prohibition) Act 2022
• Nigeria Data Protection Act 2023
• Guidance issued by the Nigerian Financial Intelligence Unit (NFIU)

3. Compliance Officer

CodedFone has appointed a Compliance Officer who is responsible for applying this policy and our identity verification (KYC) procedure, reviewing and reporting suspicious activity, keeping compliance records, and training staff.

4. Risk Assessment

We treat the following as our main money laundering risks and apply stronger checks to them:

• gift cards bought with stolen or fraudulent funds, or sold after being obtained through fraud;
• customers acting on behalf of someone else;
• high-value or high-frequency transactions in a short period; and
• several accounts linked to the same person, device or bank account.

5. Identity Verification (KYC)

Every customer must verify their identity before they can buy or sell gift cards. We collect your full name, residential address, email address, phone number, National Identification Number (NIN) and Bank Verification Number (BVN), and check your NIN and BVN before your account is verified. Each NIN and BVN can be linked to only one CodedFone account. Customers who cannot be verified cannot use gift card services.

6. Transaction Limits and Monitoring

Gift card transactions are subject to daily and monthly limits. We monitor activity for warning signs, including:

• transactions just below the limits, or repeated attempts to exceed them;
• a sudden increase in activity that does not fit a customer's history;
• many high-value cards submitted in a short time;
• frequent changes of payout bank account; and
• reluctance to provide information, or information that does not match.

7. Sanctions Screening

Customers are screened against the United Nations Security Council Consolidated List and the Nigerian sanctions list. CodedFone will not provide services to a sanctioned person.

8. Reporting Suspicious Activity

Where we suspect money laundering, terrorist financing or fraud, we may suspend the account and report it to the Nigerian Financial Intelligence Unit (NFIU) or other relevant authorities, as the law requires. We are not permitted to tell a customer that a report has been made.

9. Record Keeping

Identification records, transaction records and all reports are kept for at least five (5) years, as required by the Money Laundering (Prevention and Prohibition) Act 2022, and are handled securely in line with our Privacy Policy and the Nigeria Data Protection Act 2023.

10. Training and Review

Staff who deal with customers or transactions are trained on this policy when they join and at least once a year. This policy is reviewed at least once a year, and sooner if the law or our services change.

11. Contact

Questions about this policy? Email us at codedfone@gmail.com.