AML/KYC Information

Customer-facing identity verification, monitoring, sanctions and financial-crime controls.

Service

Effective date

18 August 2026

Primary jurisdiction

Federal Republic of Nigeria

Status

Publication draft - requires legal and regulatory review

IMPORTANT OPERATOR COMPLETION NOTE

Before publication, BTCMarts must insert the operator’s full legal name, CAC registration number, physical address, support email, privacy contact, complaints contact, and verified regulatory or licensing status. Nothing in this document should be read as claiming a licence or approval that has not been formally granted.

Quick-use summary

Read this document before using the relevant BTCMarts service.

Keep transaction confirmations and use only verified BTCMarts channels.

Contact BTCMarts promptly if information is wrong, a device or account is compromised, or you need to exercise a right.

Bracketed operator and contact fields must be completed before publication.

1. Purpose and zero-tolerance position

BTCMarts is committed to preventing money laundering, terrorism financing, proliferation financing, fraud, sanctions evasion and use of the Services for unlawful activity. This customer-facing information summarises controls; it does not disclose confidential detection thresholds or replace BTCMarts’ internal AML/CFT/CPF programme.

2. Risk-based verification

Before allowing some or all services, BTCMarts may collect and verify identity, date of birth, address, phone, email, occupation, government identifier, photograph or liveness evidence, bank account, wallet control, business registration, directors, beneficial owners, purpose of account, expected activity, source of funds and source of wealth.

Verification level may depend on transaction size, frequency, geography, product, delivery channel, customer type, occupation, agent involvement, device, wallet exposure and other risk indicators. Enhanced due diligence may apply to politically exposed persons, higher-risk jurisdictions, complex ownership, unusual patterns, non-face-to-face onboarding and adverse information.

3. Screening and monitoring

BTCMarts may screen customers, beneficial owners, counterparties and wallet addresses against applicable sanctions, terrorism, proliferation, politically exposed person and adverse-media sources. Screening occurs at onboarding and periodically or transactionally thereafter.

Transactions may be monitored for structuring, rapid movement, third-party funding, mule activity, mixing or obfuscation exposure, scams, ransomware, darknet exposure, inconsistent source of funds, unusual agents, account takeover, circular flows, high-risk jurisdictions and attempts to avoid limits.

4. Prohibited and restricted activity

Do not transact for an undisclosed third party; use another person’s bank account or identity; split transactions to avoid checks; conceal origin, ownership, purpose or destination; use stolen or criminal proceeds; interact with sanctioned persons; use BTCMarts for scams, ransomware or illegal markets; falsify documents; or instruct an agent to bypass controls.

BTCMarts may refuse cash, privacy-enhancing methods, high-risk assets, self-hosted wallets without ownership evidence, or any product/geography/counterparty outside its risk appetite. Product availability does not create an entitlement to transact.

5. Holds, requests and reporting

BTCMarts may delay, reject, limit, freeze or cancel activity; request documents; restrict withdrawals; preserve assets or records; or terminate accounts where required or reasonably necessary. BTCMarts may report suspicious activity and submit other required reports to competent authorities without informing the affected person where tipping-off restrictions apply.

Lawful requests from courts, SEC Nigeria, NFIU, EFCC, law enforcement, tax authorities, sanctions authorities or other competent bodies may require disclosure or restraint. BTCMarts will assess authority and disclose only as lawfully required.

6. Agents, partners and outlets

Agents and partners must complete appropriate due diligence, training and screening; identify customers through approved tools; maintain confidentiality; avoid off-platform custody; escalate red flags; and never warn a customer about a suspicious-activity report or investigation. Commission may be withheld or reversed for non-compliant transactions.

Physical outlets should apply cash controls, CCTV notices, dual control where appropriate, receipt and reconciliation procedures, device security, incident escalation and limits aligned with BTCMarts’ risk assessment.

7. Records and privacy

BTCMarts keeps KYC, transaction, communications, decision and monitoring records for the period required by applicable AML, SEC, tax and other laws, and longer where a legal hold applies. AML processing may be based on legal obligation and substantial public interest and may limit access, deletion or notification rights where disclosure would prejudice prevention or detection of crime.

8. User responsibilities

Provide truthful, current and complete information; transact only for yourself or a disclosed represented entity; use accounts and wallets you control; explain the lawful purpose of activity; respond promptly to information requests; protect credentials; and report unauthorised activity.

BTCMarts will never ask for a seed phrase, private key, full password or one-time authenticator code. Report suspicious approaches to [AML/SECURITY EMAIL].

9. Governance and review

BTCMarts should maintain a board-approved or senior-management-approved risk assessment, designated compliance responsibility, independent testing, staff training, escalation procedures, sanctions governance, case management, reporting controls and periodic review. The programme must be updated for new products, technologies, geographies, typologies and regulatory change.

10. Contact and regulatory status

AML/compliance contact: [NAME/ROLE], [EMAIL], [ADDRESS]. Regulatory registrations/licences: [INSERT VERIFIED STATUS AND IDENTIFIERS ONLY]. Customers should verify any claimed status through the relevant regulator’s official register.

Regulatory references

These references are provided for transparency and do not convert this draft into legal advice.

Nigeria Data Protection Act 2023 - Nigeria Data Protection Commission: https://ndpc.gov.ng/resources/

Nigeria Data Protection Act General Application and Implementation Directive 2025: https://ndpc.gov.ng/wp-content/uploads/2025/07/NDP-ACT-GAID-2025-MARCH-20TH.pdf

SEC Nigeria Rules on Issuance, Offering Platforms and Custody of Digital Assets (2022): https://home.sec.gov.ng/our-mandate/regulation/rules-and-regulations/

SEC Nigeria digital-assets and crypto-assets information: https://sec.gov.ng/our-mandate/development/business-insights/sec-policies-on-cryptocurrency-and-crypto-assets/

Nigeria Sanctions Committee - applicable AML/CFT laws: https://nigsac.gov.ng/OtherLaws

Document control

Version 1.0 | Effective 18 August 2026 | Owner: [BTCMARTS LEGAL/COMPLIANCE ROLE] | Next review: 18 August 2027 or earlier upon material legal, product or operational change.