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Tinkoh Customer Due Diligence (CDD) / Know Your Customer (KYC) Policy

1. Purpose

The purpose of this policy is to ensure that Tinkoh-Tinkoh adopts a systematic approach to verifying the identity of our customers and assessing the potential risks associated with each customer. Our goal is to prevent and mitigate the risks of fraud, money laundering, and the financing of terrorism by following practices in line with the Central Bank of Nigeria (CBN) AML/CFT Regulations (2022), the Economic and Financial Crimes Commission (EFCC) Act, and the Money Laundering (Prevention and Prohibition) Act (2022).

2. Identification & Verification

All customers are required to undergo a comprehensive identification and verification process before engaging in any transactions or activities on our platform. This includes:
  • Full Name & Date of Birth
  • Government-Issued ID: Customers must provide a valid government-issued identification card (e.g., passport, national ID, or driver’s license).
  • Proof of Address: Customers must submit a recent utility bill, bank statement, or any other official document showing their residential address.
  • Email Address
  • Source of Funds (where applicable): For certain transactions or high-risk customers, documentation verifying the source of funds may be required. This is especially important for large or unusual transactions.

3. Ongoing Monitoring

We monitor customer activity continuously to ensure that transactions align with the customer’s profile and historical behavior:
  • Regular Checks: Routine review of transactions to identify red flags or unusual behavior.
  • Risk-Based Approach: Transaction volume and complexity are assessed, and higher scrutiny is applied when necessary.

4. Enhanced Due Diligence (EDD)

For high-risk customers (e.g., politically exposed persons (PEPs), non-residents, or customers conducting large/unusual transactions), the following measures apply:
  • Additional Documentation: May include information on source of wealth and purpose of transactions.
  • More Frequent Monitoring: Transactions will be reviewed more often and in greater detail.
  • Ongoing Risk Assessment: The customer’s risk profile is reviewed regularly and updated when necessary.

5. Record Keeping

Tinkoh-Tinkoh will retain records of all customer identification documents, communications, and transaction histories for a minimum of five (5) years. These records will be available for inspection by relevant regulatory authorities.

6. Reporting Obligations

We are obligated to report suspicious activities to the relevant authorities, including the Nigerian Financial Intelligence Unit (NFIU), by submitting Suspicious Activity Reports (SARs) in accordance with legal requirements.

7. Third-Party Verification

We may engage licensed third-party verification providers or API tools in line with CBN and NDPC requirements, ensuring all customer data is processed securely and lawfully.

8. Compliance & Training

All staff involved in customer onboarding and verification are trained regularly on KYC/AML laws and updates. Compliance with CBN, EFCC, and international AML/CFT standards is mandatory.