warning
Important: This policy is issued
pursuant to the Money Laundering (Prevention and Prohibition) Act 2022, the Nigerian Financial
Intelligence Unit Act 2018, and the Central Bank of Nigeria's Baseline Standards for Automated
AML Solutions (Circular No. BSD/DIR/PUB/LAB/019/002 dated 10 March 2026).
Introduction and Policy Statement
Buselor is a Settlement-Driven Commerce Infrastructure that enables trusted buying and selling through
protected payments, controlled merchant settlements, and integrated logistics. As a platform that
processes financial transactions and holds customer funds in partnership with VFD Microfinance Bank Limited, we operate at the
heart of Nigeria's financial system.
We recognise the significant responsibility this entails. Buselor is fully committed to preventing the use of our
platform for money laundering or any other financial crime. We will not tolerate any activity that
undermines the integrity of the financial system or poses a risk to our users, partners, or the broader
Nigerian economy.
This Policy is issued in compliance with:
- The Money Laundering (Prevention and Prohibition)
Act 2022 (MLPPA)
- The Nigerian Financial Intelligence Unit (NFIU)
Act 2018
- The Proceeds of Crime (Recovery and Management)
Act 2022
- The Central Bank of Nigeria (CBN)
Guidelines and Circulars, including:
- CBN Circular No. BSD/DIR/PUB/LAB/019/002 on Baseline Standards for Automated Anti-Money
Laundering Solutions for Financial Institutions in Nigeria (10 March 2026)
- All applicable CBN AML regulations
- The Financial Action Task Force (FATF) 40
Recommendations and international standards
verified
Our Commitment
Buselor will:
- Deploy robust automated AML systems
as mandated by the CBN Baseline Standards
- Conduct thorough Know Your Customer (KYC)
and Customer Due Diligence (CDD) checks
- Monitor all transactions in real-time
for suspicious activity
- Report suspicious transactions to the NFIU
within 24 hours of suspicion forming
- Cooperate fully with law enforcement and regulatory authorities
- Maintain comprehensive records for regulatory audit and review
- Protect customer data in accordance with the Nigeria Data Protection Act 2023
Definitions
| Term |
Definition |
| AML |
Anti-Money Laundering |
| CDD |
Customer Due Diligence |
| EDD |
Enhanced Due Diligence |
| STR |
Suspicious Transaction Report |
| NFIU |
Nigerian Financial Intelligence Unit |
| CBN |
Central Bank of Nigeria |
| EFCC |
Economic and Financial Crimes Commission |
| FATF |
Financial Action Task Force |
| PEP |
Politically Exposed Person |
| BVN |
Bank Verification Number |
| NIN |
National Identification Number |
| PND |
Post-No-Debit |
| Settlement ID |
A globally unique identifier assigned to every Buselor transaction (e.g.,
BST-YYYYMMDD-XXXXXX). This ID is the single source of truth for all financial and
physical fulfillment activities. |
What is Money Laundering?
Money laundering is the process by which criminals disguise the illegal origins of their funds to make
them appear legitimate. It is a critical enabler of all serious and organized crime, including drug
trafficking, human trafficking, corruption, fraud, and tax evasion.
Money laundering typically involves three stages:
payments
3.1. Placement
The physical disposal of
cash or other assets derived from criminal activity. This is the most vulnerable stage
for the launderer, as large amounts of cash are difficult to integrate into the
financial system without detection.
Examples relevant to Buselor:
- Using Buselor to convert cash proceeds of crime into digital wallet balances
- Funding a Buselor wallet with illicit cash through third-party agents
- Using multiple small deposits to avoid detection (structuring)
layers
3.2. Layering
The separation of illicit
proceeds from their origin through complex financial transactions designed to obscure
the audit trail. This is the most complex stage, involving multiple transactions and
jurisdictions.
Examples relevant to Buselor:
- Moving funds between multiple Buselor wallets
- Using Buselor's settlement mechanism to layer funds through multiple transactions
- Combining legitimate and illegitimate funds in a single wallet
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3.3. Integration
The re-introduction of
laundered funds into the legitimate economy, making them appear to have originated from a
legitimate source.
Examples relevant to Buselor:
- Withdrawing laundered funds from a Buselor wallet to a bank account
- Using laundered funds to make purchases through Buselor Express
- Using laundered funds to pay for goods and services that create a legitimate
business record
Legal and Regulatory Framework
4.1.
The Money Laundering (Prevention and Prohibition) Act 2022
This Act, signed into law by
President Muhammadu Buhari in 2022, repealed the Money Laundering (Prohibition) Act 2011 and
strengthened Nigeria's AML framework. Key provisions relevant to Buselor include:
- Section 7: Mandates reporting
entities to render STRs to the NFIU within 24 hours of a transaction being deemed suspicious
- Section 8: Requires financial
institutions to verify customer identity and maintain records
- Section 9: Prohibits anonymous
accounts and requires proper identification of customers
- Section 10: Mandates reporting
of cash transactions above specified thresholds
- Section 15: Establishes
penalties for non-compliance, including substantial fines and imprisonment
- Section 26: Requires financial
institutions to implement AML policies and procedures
- Section 27: Mandates training of
employees on AML obligations
4.2.
The Proceeds of Crime (Recovery and Management) Act 2022
This Act makes comprehensive
provisions for the seizure, confiscation, forfeiture, and management of properties derived from
unlawful activity. It mandates:
- The creation of dedicated accounts for proceeds of crime and confiscated assets
- Enhanced accountability mechanisms for asset recovery
- Cooperation between financial institutions and law enforcement in asset recovery efforts
4.3.
The Nigerian Financial Intelligence Unit (NFIU) Act 2018
The NFIU is Nigeria's central
agency for receiving, analyzing, and disseminating financial intelligence. Key obligations
include:
- All financial institutions must report suspicious transactions to the NFIU
- The NFIU has the power to issue guidelines on STR reporting
- The NFIU maintains a database of STRs for use by law enforcement
4.4.
CBN Baseline Standards for Automated AML Solutions
On 10 March 2026, the CBN
issued Circular No. BSD/DIR/PUB/LAB/019/002 mandating all financial institutions to deploy
automated, technology-driven AML systems.
- Scope: Applies to all
CBN-regulated institutions, including payment service providers, fintechs, and mobile money
operators
- Core Functions: Automated
systems must support: customer identification and verification, customer risk assessment,
sanction and watchlist screening, PEP screening, transaction monitoring, case management,
regulatory reporting, audit and governance, and data protection
- Technology: The CBN encourages
adoption of AI, machine learning, and advanced analytics
- Timelines: Full compliance
within 24 months (by June 2028)
4.5.
Nigeria's FATF Grey List Exit
Nigeria was removed from the
FATF grey list in October 2025. This
milestone signifies that Nigeria has made the necessary reforms to address AML weaknesses, but
also means that continued progress and sustained compliance are essential. The CBN's AML
Baseline Standards are a direct response to post-grey list obligations.
Buselor's AML Framework
5.1.
Governance and Oversight
Board and Senior Management Commitment:
Buselor's Board of Directors and Senior Management are fully committed to AML compliance. The
Board has designated a senior executive as the Money Laundering Reporting Officer
(MLRO) with primary responsibility for overseeing the AML program, ensuring
compliance, reporting to management, and serving as the primary point of contact with the NFIU,
CBN, and other regulatory authorities.
AML Compliance Team: Buselor maintains a
dedicated AML Compliance Team with sufficient resources, authority, and independence to
effectively implement the AML program.
5.2.
Risk Assessment
Buselor conducts regular,
documented risk assessments to identify and evaluate ML risks associated with products and
services, customer types and geographies, delivery channels, and business relationships. Risk
assessments are reviewed and updated annually, or more frequently if significant changes
occur.
5.3.
Customer Due Diligence (CDD)
Standard CDD: Before establishing a
business relationship or carrying out a transaction, Buselor must identify and verify the
customer's identity, identify beneficial owners, understand the purpose of the business
relationship, and conduct ongoing due diligence.
Verification Methods: Buselor uses
automated identity verification systems integrated with national infrastructure such as BVN and
NIN databases.
Tiered KYC: In compliance with CBN
requirements, Buselor operates a three-tiered KYC system:
- Tier 1 Full legal name, phone number (OTP
verification), email address
- Tier 2 BVN or NIN, government-issued ID,
passport photograph
- Tier 3 CAC documentation (for businesses),
physical address verification, utility bill, valid government ID
5.4.
Enhanced Due Diligence (EDD)
EDD is required for customers
identified as higher risk, including PEPs, customers from high-risk jurisdictions, non-face-to-face
customers, unusual or complex transaction patterns, and customers with significant unexplained
wealth. EDD measures include obtaining additional information, seeking senior management
approval, conducting enhanced monitoring, and reviewing source of funds and wealth.
5.5.
PEP and Sanctions Screening
Buselor screens all customers,
beneficial owners, and counterparties against domestic and international sanctions lists, PEP
registers, internal watchlists, and adverse media sources. Screening is conducted at onboarding,
on a periodic basis (at least quarterly), and immediately when sanctions lists are
updated.
Transaction Monitoring
6.1.
Automated Transaction Monitoring System
Buselor deploys an automated
transaction monitoring system that meets the CBN Baseline Standards. The system uses advanced
analytics, data monitoring tools, and AI to:
- Track large volumes of transactions in real-time
- Flag unusual patterns and generate alerts
- Assess activity in the context of the full customer profile
- Monitor transactions across relevant channels in real-time or near-real-time
6.2.
Red Flags and Indicators
Buselor's transaction monitoring
system is designed to detect red flags including, but not limited to:
Transaction Pattern Red Flags:
- Structuring: Breaking down
transactions to avoid reporting thresholds
- Unusually large transactions:
Inconsistent with customer profile or business activity
- Rapid movement of funds:
Depositing and immediately withdrawing to a different account
- Multiple small transactions:
High volume over a short period inconsistent with normal activity
- Transactions involving high-risk
jurisdictions: Jurisdictions identified by the FATF
- Circular transactions: Funds
moving through multiple accounts and returning to the source
- Sudden change in patterns:
Significant deviation from established history
Buselor-Specific Red Flags:
- Transactions involving prohibited virtual
assets (cryptocurrencies, NFTs, stablecoins)
- Unusually high-value transactions
from accounts with minimal prior activity
- High volume of transactions from
accounts with incomplete KYC
- Multiple guest checkouts from the
same IP address using different identities
- Seller anomalies: Sellers with
unusually high transaction volume but minimal physical presence
- Multiple stores with
inconsistent business profiles
- Rapid merchant onboarding: Sudden
spike in merchant registrations with similar characteristics
- Unusual settlement patterns or
account changes
- Inconsistent product listings:
Products at values significantly above or below market rates
- Frequent disputes inconsistent
with normal commerce activity
6.3.
Suspicious Transaction Reporting (STR)
A suspicion is formed when the
AML Compliance Team determines, based on a thorough examination, that there are reasonable
grounds to suspect the transaction is related to money laundering. STRs are filed with the NFIU
within 24 hours of suspicion being
formed.
Prohibited Activities
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7.1. Cryptocurrency and Virtual Assets Ban
In accordance with CBN guidance and
the Securities and Exchange Commission (SEC) Nigeria regulations, Buselor strictly prohibits the use of our platform
for:
- Buying, selling, or facilitating transactions in cryptocurrencies (e.g., Bitcoin, Ethereum,
USDT)
- Non-Fungible Tokens (NFTs)
- Stablecoins
- Digital bonds
- Any other digital virtual assets classified as securities
warning
Consequences: Any user found using Buselor's platform for these purposes will
have their account permanently terminated, all pending funds frozen, an STR
filed with the NFIU, and details shared with regulatory authorities as required by law.
7.2.
Other Prohibited Activities
Users are prohibited from using
Buselor for:
- Money laundering
- Fraud (including account takeover, identity theft, and card fraud)
- Transactions involving illegal goods or services
- Structuring transactions to avoid reporting thresholds
- Tax evasion
- Corruption and bribery
- Any other activity that violates Nigerian law or our Terms of Service
Staff Training and Awareness
8.1.
Training Program
Initial Training: All new employees receive
AML training within their first month, covering legal and regulatory framework, Buselor's AML policy
and procedures, types of ML activity and red flags, reporting obligations, and consequences of
non-compliance.
Ongoing Training: Annual refresher training
for all employees, specialized training for compliance, operations, and customer support staff, and
updates whenever significant regulatory changes occur.
Training Records: All training activities
are documented and maintained for regulatory review.
Regulatory Reporting and Cooperation
9.1.
Suspicious Transaction Reports
Buselor files Suspicious
Transaction Reports with the NFIU in accordance with MLPPA Section 7 (within 24 hours of suspicion
forming).
9.2.
Cooperation with Authorities
Buselor cooperates fully with
the NFIU, CBN, EFCC, and other law enforcement and regulatory authorities. Cooperation includes
responding promptly to information requests, providing access to records and systems, complying
with court orders, assisting in investigations, and providing expert testimony where
required.
9.3.
Audit and Examination
Buselor is subject to
regulatory examinations by the CBN, AML inspections by the NFIU, and internal and external
audits. Buselor maintains all records and systems in a state of readiness for regulatory
examination at all times.
Penalties and Sanctions for Non-Compliance
10.1.
For Users
Users who violate this AML
Policy may face:
- Account suspension or permanent
termination
- Post-No-Debit (PND) restriction on
all accounts and pending funds
- Reporting to the NFIU
- Referral to law enforcement (EFCC)
- Civil and criminal liability
- Asset forfeiture
- Financial penalties under the MLPPA
10.2.
For Buselor
Non-compliance with AML
regulations exposes Buselor to:
- Regulatory fines and sanctions
- Reputational damage
- Criminal liability for directors and officers
- Potential delisting from partner programs
- Loss of banking relationships
- Regulatory enforcement actions
Buselor is fully committed
to maintaining a robust AML program to avoid these consequences.
Whistleblower Reporting
Email: whistleblower@buselor.com
All reports are treated
confidentially, and reporters are protected from retaliation as provided by law.
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Policy Acknowledgment: By using
Buselor's platform, you acknowledge that you have read, understood, and agree to comply with
this AML Policy. You understand that Buselor is required by law to verify your identity, monitor
transactions for suspicious activity, and file reports with the NFIU as required by law.