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Legal Document

Buselor Combating the Financing of Terrorism (CFT) Policy

Document Type
CFT Policy
Effective Date
August 2026
Regulator
CBN / NFIU / UN

warning Important: This policy is issued pursuant to the Terrorism (Prevention and Prohibition) Act 2022, the Money Laundering (Prevention and Prohibition) Act 2022, and the Financial Action Task Force Recommendations.

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 have a critical role to play in preventing the financing of terrorism.

We recognize that terrorists and terrorist organizations exploit legitimate financial systems to raise, move, and store funds. Buselor is fully committed to preventing the use of our platform for terrorist financing or any related activity. We will not tolerate any activity that supports terrorism or undermines national and international security.

This Policy is issued in compliance with:

  • The Terrorism (Prevention and Prohibition) Act 2022 (TPPA)
  • The Money Laundering (Prevention and Prohibition) Act 2022 (MLPPA)
  • The Nigerian Financial Intelligence Unit (NFIU) Act 2018
  • The United Nations Security Council Resolutions on Counter-Terrorism
  • The Financial Action Task Force (FATF) Recommendations
  • The Central Bank of Nigeria (CBN) Guidelines and Circulars
  • The Nigerian Counter-Terrorism Strategy
verified Our Commitment

Buselor will:

  • Deploy robust automated CFT systems as mandated by the CBN Baseline Standards
  • Conduct thorough Know Your Customer (KYC) and Customer Due Diligence (CDD) checks with specific focus on terrorism risk indicators
  • Monitor all transactions in real-time for terrorist financing indicators
  • Report suspicious transactions to the NFIU within 24 hours of suspicion forming
  • Implement targeted financial sanctions as required by the United Nations and Nigeria
  • Cooperate fully with law enforcement and security agencies
  • Maintain comprehensive records for regulatory audit and review
  • Protect customer data in accordance with the Nigeria Data Protection Act 2023
  • Screen customers against terrorism watchlists and sanctions lists

Definitions

Term Definition
CFT Combating the Financing of Terrorism
TF Terrorist Financing
TPPA Terrorism (Prevention and Prohibition) Act 2022
CDD Customer Due Diligence
EDD Enhanced Due Diligence
STR Suspicious Transaction Report
NFIU Nigerian Financial Intelligence Unit
UNSCR United Nations Security Council Resolution
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.
Terrorist As defined in the TPPA: any person who commits, plans, or participates in terrorist acts
Terrorist Organization As defined in the TPPA: any organization designated as a terrorist organization by the United Nations or the Nigerian Government
Terrorist Financing The provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out terrorist acts
Designated Person An individual or entity listed on the UN Security Council Consolidated List or Nigerian Government sanctions list
Targeted Financial Sanctions Asset freezing and other financial restrictions imposed on designated persons and entities

What is Terrorist Financing?

Terrorist financing is the provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out terrorist acts.

3.1. Key Characteristics of Terrorist Financing Unlike money laundering, terrorist financing:
  • May involve funds from legitimate sources (such as personal savings, salaries, charitable donations)
  • Is often for relatively small amounts
  • May be difficult to detect because funds may appear to be for legitimate purposes
  • Can involve any method of funding, including cash, bank transfers, cryptocurrencies, and trade

Terrorist financing has three key elements:

payments

Collection

Raising funds through legitimate or illegitimate means, including:

  • Abuse of non-profit organizations and charities
  • Criminal activities (including fraud, smuggling, and extortion)
  • Personal funds and savings
  • Legitimate business activities
  • State sponsorship (in some cases)
swap_horiz

Movement

Transferring funds to where they are needed, including:

  • International wire transfers
  • Physical cash smuggling
  • Alternative remittance systems (hawala, hundi)
  • Trade-based money movement
gavel

Use

Deploying funds to support terrorist activities, including:

  • Training and recruitment
  • Equipment and logistics
  • Operations and planning
  • Living expenses for operatives
  • Propaganda and recruitment
3.2. Terrorism Financing Red Flags Specific to Nigeria

Buselor's CFT program is designed to detect terrorism financing red flags specific to Nigeria, including:

  • North-East Boko Haram and ISWAP: Funds flowing to or from the North-East region, particularly Borno, Yobe, and Adamawa states
  • North-West Banditry and Kidnapping: Ransom payments and other funds associated with criminal groups in the North-West and North-Central regions
  • South-East IPOB and ESN: Funds associated with secessionist movements in the South-East
  • Charity Abuse: Funds moving through non-profit organizations with operations in high-risk areas
  • Cash Smuggling: Funds being moved across Nigeria's borders through informal channels
  • Alternative Remittance: Use of hawala, hundi, and other informal value transfer systems

Legal and Regulatory Framework

4.1. The Terrorism (Prevention and Prohibition) Act 2022 (TPPA) The TPPA is Nigeria's primary anti-terrorism legislation. It repealed the Terrorism (Prevention) Act 2011 and provides for the effective implementation of international instruments on the prevention and combating of terrorism and suppression of the financing of terrorism.
  • Section 1: Defines terrorist acts and terrorism offences
  • Section 3: Establishes the offence of financing terrorism
  • Section 84: Mandates reporting entities to render STRs related to terrorism financing to the NFIU within 24 hours of suspicion
  • Section 85: Requires financial institutions to implement CFT policies and procedures
  • Section 86: Mandates freezing of assets of designated persons and entities
  • Section 87: Prohibits dealing with funds belonging to terrorists or terrorist organizations
  • Section 88: Establishes penalties for non-compliance, including imprisonment and fines
4.2. United Nations Security Council Resolutions Nigeria is bound by mandatory UN Security Council Resolutions, including:
  • UNSCR 1267 (1999): Established the sanctions regime against Al-Qaida and the Taliban
  • UNSCR 1373 (2001): Established the Counter-Terrorism Committee and mandated states to criminalize terrorist financing
  • UNSCR 1988 (2011): Established the sanctions regime against the Taliban
  • UNSCR 2253 (2015): Consolidated the sanctions regime against ISIL/Al-Qaida
  • UNSCR 2368 (2017): Extended the sanctions regime
4.3. FATF Recommendations The FATF 40 Recommendations include specific requirements for CFT:
  • Recommendation 5: Countries should criminalize terrorist financing
  • Recommendation 6: Countries should implement targeted financial sanctions
  • Recommendation 8: Countries should ensure non-profit organizations are not misused for terrorist financing
  • Recommendation 17: Countries should ensure financial institutions apply CDD measures, including for terrorist financing risks
  • Recommendation 19: Countries should apply enhanced due diligence for high-risk jurisdictions

Buselor's CFT Framework

5.1. Governance and Oversight

Board and Senior Management Commitment: Buselor's Board of Directors and Senior Management are fully committed to CFT compliance. The Board has designated a senior executive as the Money Laundering Reporting Officer (MLRO) with primary responsibility for overseeing the CFT program, ensuring compliance, and serving as the primary point of contact with the NFIU, security agencies, and other regulatory authorities.

CFT Compliance Team: Buselor maintains a dedicated CFT Compliance Team with sufficient resources, authority, and independence to effectively implement the CFT program.

5.2. Targeted Financial Sanctions

Immediate Implementation: Upon notification of a designation by the United Nations or the Nigerian Government, Buselor will:

  • Identify any accounts, funds, or assets belonging to the designated person or entity
  • Immediately freeze all such funds and assets (within seconds)
  • Prevent any dealing with the frozen funds
  • Report the freeze to the NFIU and appropriate authorities
5.3. Sanctions Screening Buselor screens all customers, beneficial owners, and counterparties against:
  • UN Security Council Consolidated List
  • Nigerian Government sanctions list
  • OFAC SDN List (as applicable)
  • Other international sanctions lists
  • Internal watchlists

Screening is conducted at onboarding, on a periodic basis (at least quarterly), immediately when sanctions lists are updated, and when new products or services are launched.

5.4. Non-Profit Organization Oversight Recognizing that non-profit organizations (NPOs) can be misused for terrorist financing, Buselor applies enhanced scrutiny to NPO customers:
  • Verification: Verifying the NPO's registration and status
  • Review: Reviewing the NPO's stated purpose and activities
  • Monitoring: Monitoring transactions for unusual patterns
  • Reporting: Reporting any suspicious activity involving NPOs

Transaction Monitoring

6.1. Automated CFT Monitoring System Buselor deploys an automated transaction monitoring system with specific CFT capabilities:
  • Sanctions Screening: Real-time screening against all relevant sanctions lists
  • Watchlist Monitoring: Screening against terrorism watchlists
  • Behavioral Analytics: Identifying unusual patterns indicative of terrorist financing
  • Geographic Monitoring: Flagging transactions involving high-risk regions
  • Network Analysis: Identifying connections to known terrorists or terrorist organizations
6.2. Terrorist Financing Red Flags and Indicators

Buselor's transaction monitoring system is designed to detect terrorism financing red flags including:

Transaction Pattern Red Flags:

  • Suspicious small transactions: Multiple small transactions inconsistent with customer profile
  • Structuring: Breaking down transactions to avoid reporting thresholds
  • Transactions involving high-risk regions: Jurisdictions or regions associated with terrorist activity
  • Unusual frequency: Transactions occurring at unusual times or frequencies
  • Rapid movement of funds: Funds moving quickly through multiple accounts
  • Circular transactions: Funds moving through accounts and eventually returning to the source

Buselor-Specific Red Flags:

  • Multiple accounts: Operating multiple accounts with similar patterns
  • Guest checkout patterns: Multiple guest checkouts from locations associated with terrorist activity
  • Merchant anomalies: Sellers with products or services inconsistent with terrorist financing risk
  • Frequent disputes: Pattern of disputes that may be designed to generate cash
  • Unusual product listings: Products listed at values that may facilitate terrorist financing
  • Logistics anomalies: Delivery patterns inconsistent with legitimate commerce
  • Seller networks: Multiple sellers operating from same location or with similar profiles
  • Rapid merchant registration: Multiple merchant registrations from the same IP address
Geographic Red Flags
  • North-East Borno, Yobe, Adamawa: Boko Haram/ISWAP activity
  • North-West Zamfara, Katsina, Kaduna, Sokoto: Banditry/kidnapping
  • North-Central Niger, Plateau, Kogi: Banditry
  • South-East Anambra, Imo, Abia, Enugu: IPOB/ESN activity
  • South-South Rivers, Bayelsa, Akwa Ibom: Militancy
  • International: Transactions involving known terrorism hotspots (Sahel, Horn of Africa, Middle East)
  • Borders: Transactions involving Nigeria's land borders

Asset Freezing

block 7.1. Obligation to Freeze

Buselor has an absolute obligation to freeze all funds and assets belonging to designated persons and entities immediately upon notification of designation.

Freezing Action:

  • Freeze all accounts, wallets, and assets
  • Prevent any dealing with frozen funds
  • Prevent any transfer or withdrawal
  • Report the freeze to the NFIU
  • Maintain records of the freeze

warning Prohibition: No funds or assets may be made available to designated persons. No dealing with frozen funds or assets is permitted.

Staff Training and Awareness

8.1. Training Program

Initial Training: All new employees receive CFT training within their first month, covering legal and regulatory framework (TPPA, UNSCRs), Buselor's CFT policy and procedures, types of terrorist financing 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 training on emerging terrorist financing threats and typologies.

Training Records: All training activities are documented and maintained for regulatory review.

Regulatory Reporting and Cooperation

9.1. Suspicious Transaction Reports Buselor files STRs with the NFIU in accordance with TPPA Section 84 (within 24 hours of suspicion forming).
9.2. Cooperation with Security Agencies Buselor cooperates fully with the NFIU, DSS, NIA, ONSA, and other law enforcement and security agencies. 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.

Prohibited Activities

10.1. Terrorist Financing Buselor strictly prohibits the use of our platform for any activity related to terrorist financing, including:
  • Providing funds for terrorist activities
  • Collecting funds for terrorists or terrorist organizations
  • Moving funds to or from terrorists or terrorist organizations
  • Facilitating transactions involving designated persons
  • Any activity that violates the TPPA
10.2. Dealing with Designated Persons Buselor prohibits any dealing with designated persons, including:
  • Maintaining accounts for designated persons
  • Conducting transactions involving designated persons
  • Providing funds to designated persons
  • Receiving funds from designated persons
  • Any activity that benefits designated persons

Penalties and Sanctions for Non-Compliance

11.1. For Users Users who violate this CFT 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 security agencies (DSS, NIA)
  • Criminal liability under the TPPA (imprisonment, fines)
  • Asset freezing and seizure
  • International sanctions
11.2. For Buselor Non-compliance with CFT 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
  • International sanctions

Buselor is fully committed to maintaining a robust CFT program to avoid these consequences.

Contact Information

Money Laundering Reporting Officer (MLRO)

Email: mlro@buselor.com

CFT Compliance Team

Email: cft@buselor.com

Terrorist Financing Reporting

Email: tf@buselor.com

Whistleblower Reporting

Email: whistleblower@buselor.com

All reports are treated confidentially, and reporters are protected from retaliation as provided by law.

info Policy Acknowledgment: By using Buselor's platform, you acknowledge that you have read, understood, and agree to comply with this CFT Policy. You understand that Buselor is required by law to screen customers against terrorism watchlists, monitor transactions for terrorist financing indicators, and file reports with the NFIU as required by law.

info Note: This document constitutes Buselor's complete Anti-Money Laundering and Combating the Financing of Terrorism compliance framework. Both policies are integrated and operate in conjunction with each other, with the CFT policy containing specific provisions required by the Terrorism (Prevention and Prohibition) Act 2022.

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