BettaLyfe
AML / KYC Policy

This Policy applies to all BettaLyfe employees, directors, officers, and registered agents. It also informs our expectations of service partners: Providus Bank (wallet), AXA Mansard and NEM Health (insurance), Unicorn MFB (loans), Pension Managers (pension), and Paystack (payments) — each governed by their own regulatory obligations and DPAs with BettaLyfe.

Money Laundering Reporting Officer (MLRO)

BettaLyfe has appointed a designated MLRO responsible for: overseeing AML/KYC compliance, evaluating and filing STRs and CTRs with the NFIU, and liaising with CBN, NFIU, and EFCC.

MLRO contact: compliance@bettalyfe.com

All Staff and Agents Must

• Complete mandatory AML/KYC training before commencing duties and annually thereafter
• Report any suspicious customer activity to the MLRO immediately
• Never tip off a customer that a report has been or may be filed (criminal offence under MLPPA 2022)

All BVN verification is automated in real time via NIBSS. All NIN verification via NIMC. Self-declaration alone does not satisfy any tier. Any mismatch between submitted and verified data triggers a manual review hold.

4.1 Corporate / Business Account KYC

• CAC Certificate of Incorporation
• Memorandum and Articles of Association
• BVN and NIN of all directors and beneficial owners holding 5% or more
• Proof of business address
• PSC (Persons with Significant Control) Register as required under CAMA 2020

Standard CDD — All Customers

• Identity verification per KYC tiers above
• Real-time sanctions screening: OFAC, UN, NFIU, and CBN sanctions lists
• Politically Exposed Persons (PEP) screening
• Adverse media screening

Enhanced Due Diligence (EDD) — High-Risk Customers

EDD is mandatory for: PEPs and their immediate family or associates, customers from FATF high-risk jurisdictions, customers with complex high-value transaction patterns, and any account flagged as high-risk by automated monitoring.

EDD measures: Senior management approval for account opening, additional documentation, increased monitoring frequency, account review every 6 months minimum.

6.1 BettaCredit and Gift Card-Specific Red Flags

• BettaCredit or gift cards purchased in bulk and immediately gifted to multiple unrelated third parties
• Repeated gift card purchases at or just below N50,000 in rapid succession from a single account
• Gift card codes shared across a large network of new accounts with no prior transaction history
• BettaCredit funded from multiple different unrelated sources in the same day

6.2 General Transaction Red Flags

• Wallet top-ups immediately followed by full redemption with no service usage
• Transactions structured just below the N5,000,000 CTR reporting threshold (structuring)
• Multiple accounts sharing the same BVN, NIN, device, or IP address
• Any single account receiving more than 100 transactions in a defined period (NFIU threshold)
• Transactions inconsistent with the user's stated occupation, income, or KYC profile

6.3 Identity and Behavioural Red Flags

• Customer reluctant or evasive about providing KYC information
• ID documents appear altered, inconsistent, or do not match NIBSS/NIMC verified data
• Customer requests that transactions not be recorded or expresses unusual knowledge of AML thresholds

All users and transactions are screened in real time against:

• UN Security Council Sanctions lists
• OFAC SDN list
• CBN and NFIU domestic sanctions lists
• FATF high-risk and monitored jurisdiction lists

Positive matches result in immediate account freeze and MLRO notification for NFIU reporting within 24 hours.

• Mandatory onboarding AML training before any staff member or agent commences duties
• Annual refresher training covering regulatory updates and new ML/TF typologies
• Incident-triggered training following any confirmed AML breach or regulatory finding