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AML & Compliance

ComplianceLast updated: 1 January 2025
Contents
Our CommitmentLegal FrameworkKYC RequirementsSuspicious ActivitySanctionsRecord KeepingContact

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1.

Our Commitment

Cards R Us is committed to the prevention of money laundering, terrorist financing, and all forms of financial crime. We operate a robust, risk-based compliance programme aligned with international best practices and the specific regulations of every jurisdiction in which we are authorised to operate. Compliance is not a box to tick — it is a core part of how we do business.

Any attempt to use our platform for illicit purposes will result in immediate account termination and referral to law enforcement authorities.

2.

Legal Framework

Our AML programme is built on a multi-jurisdictional legal framework. In Nigeria, we comply with the Money Laundering (Prevention and Prohibition) Act 2022, the CBN AML/CFT Regulations, and NFIU guidelines.

Internationally, we align with the Financial Action Task Force (FATF) Forty Recommendations and the Egmont Group principles. Where we operate in the United Kingdom or European Union, we additionally comply with the Proceeds of Crime Act 2002 and the EU's 6th Anti-Money Laundering Directive (6AMLD) respectively.

3.

Know Your Customer (KYC)

We apply a risk-based approach to identity verification. All registered accounts are subject to standard KYC checks including: a valid government-issued photo ID (national passport, driver's licence, or national ID card), a recent proof of address (utility bill or bank statement, not older than three months), and a verified phone number and email address.

For higher-volume accounts or transactions above designated thresholds, enhanced due diligence (EDD) may be required, including source of funds documentation. Accounts that do not complete the required KYC tier may have transaction limits applied, withdrawals suspended, or accounts permanently restricted.

4.

Suspicious Activity Reporting

Our transaction monitoring systems operate 24/7, using rule-based and machine-learning models to flag potentially suspicious behaviour. Indicators that may trigger a review include: structuring of transactions to avoid reporting thresholds, rapid resale of digital codes at a discount, purchasing patterns inconsistent with a user's profile, and unusual geographic patterns.

Where suspicious activity is confirmed, a Suspicious Transaction Report (STR) is filed with the relevant financial intelligence unit as required by law. We are legally prohibited from tipping off subjects of such reports.

5.

Sanctions Screening

Every customer and transaction is screened in real-time against international and domestic sanctions lists — including the OFAC SDN List, UN Security Council Consolidated List, EU Consolidated List, UK HM Treasury Financial Sanctions List, and the Nigerian ONSA list.

We do not conduct business with sanctioned individuals, entities, or jurisdictions. Any confirmed match immediately freezes the associated account pending a compliance review.

6.

Record Keeping

Customer identification records, transaction histories, and compliance case files are retained for a minimum of five years from the date of the transaction or the end of the customer relationship, whichever is later. All records are stored with AES-256 encryption and are accessible only to authorised compliance personnel.

7.

Compliance Contact

For AML and compliance enquiries, please contact our team at compliance@cardsrus.com. Our Chief Compliance Officer is reachable at the same address. We aim to respond to all compliance enquiries within one business day.

Questions about this document?

Our compliance and support teams are available 24/7 to help.

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