Compliance Framework

Compliance Framework

Effective Date: January 1, 2025

Last Updated: January 1, 2025

1. Regulatory Framework

ClexPay operates in full compliance with Nigerian financial regulations and international standards:

• Nigerian Money Laundering (Prohibition) Act 2011 (as amended)
• Economic and Financial Crimes Commission (EFCC) guidelines
• Central Bank of Nigeria (CBN) regulations
• Securities and Exchange Commission (SEC) guidelines
• Financial Action Task Force (FATF) recommendations
• Corporate Affairs Commission (CAC) requirements

2. Corporate Registration

ClexPay is a legally registered entity in Nigeria:

• Legal Name: CLIFFSIDE GLOBAL LINK LTD
• Registration Number: RC: 7503561
• Regulatory Body: Corporate Affairs Commission (CAC), Nigeria
• Business Type: Financial Technology Services
• Registration Date: 2020

3. Anti-Money Laundering (AML) Compliance

We maintain a robust AML program that includes:

• Comprehensive customer due diligence procedures
• Ongoing transaction monitoring and analysis
• Suspicious activity reporting to relevant authorities
• Regular staff training on AML requirements
• Independent annual AML program audits
• Cooperation with law enforcement investigations

4. Know Your Customer (KYC) Requirements

Our KYC program ensures proper customer identification:

• Multi-tier verification system with appropriate limits
• Document verification using advanced technology
• Enhanced due diligence for high-risk customers
• Ongoing monitoring and periodic re-verification
• Secure storage and protection of customer data

5. Data Protection and Privacy

We comply with Nigerian data protection laws and international standards:

• Nigeria Data Protection Regulation (NDPR) compliance
• Secure data processing and storage practices
• Customer consent management
• Data breach notification procedures
• Regular privacy impact assessments

6. Financial Crime Prevention

We implement comprehensive measures to prevent financial crimes:

• Real-time transaction monitoring systems
• Fraud detection and prevention algorithms
• Sanctions screening and watchlist monitoring
• Risk-based customer assessment procedures
• Regular security audits and penetration testing

7. Reporting and Record Keeping

We maintain comprehensive records and reporting systems:

• Transaction records retained for 7 years minimum
• Customer identification records retained for 5 years after account closure
• Suspicious Transaction Reports (STR) filed with NFIU
• Regular regulatory reporting to relevant authorities
• Audit trails for all system activities

8. Compliance Governance

Our compliance program is overseen by dedicated professionals:

• Designated Compliance Officer responsible for program oversight
• Board-level oversight of compliance activities
• Regular compliance training for all employees
• Independent compliance audits and assessments
• Continuous monitoring of regulatory developments

9. International Standards

We adhere to international best practices and standards:

• Financial Action Task Force (FATF) recommendations
• Basel Committee on Banking Supervision guidelines
• International Organization of Securities Commissions (IOSCO) principles
• ISO 27001 information security management standards
• PCI DSS compliance for payment card data security

10. Continuous Improvement

We continuously enhance our compliance framework:

• Regular review and update of policies and procedures
• Implementation of new technologies for compliance monitoring
• Staff training and professional development programs
• Engagement with regulatory authorities and industry bodies
• Participation in compliance best practice initiatives

11. Contact Information

For compliance-related inquiries or to report concerns:

• Compliance Officer: [email protected]
• Phone: +234 (0) 123 456 7890
• Address: Shop 11 AAA, Excel Ventures Plaza, Okpanam Road, Asaba, Delta State, Nigeria
• Business Hours: Monday - Friday, 9:00 AM - 6:00 PM WAT

This compliance framework is regularly reviewed and updated to ensure continued adherence to evolving regulatory requirements and industry best practices.