Effective Date: 11th May, 2026
Last Updated: 11th May, 2026
This our Anti-Money Laundering and Counter-Terrorism Financing Policy ("AML Policy" or "Policy") sets out the framework, principles, procedures, controls, and compliance obligations adopted by FalconPay Limited ("FalconPay", "we", "our", or "us") for the prevention, detection, deterrence, reporting, and management of money laundering, terrorism financing, proliferation financing, fraud, corruption, and other financial crimes. FalconPay recognizes its legal and regulatory responsibility to maintain a secure financial ecosystem and to ensure that its platform, products, services, payment infrastructure, applications, APIs, and related systems are not used for unlawful or illicit financial activities. This Policy applies to all FalconPay directors, officers, employees, agents, contractors, partners, merchants, users, service providers, and any other persons or entities accessing or using FalconPay Services. FalconPay is committed to complying with all applicable anti-money laundering and counter-terrorism financing laws, regulations, directives, circulars, and industry standards, including but not limited to the relevant laws and regulatory frameworks of the Federal Republic of Nigeria, directives issued by the Central Bank of Nigeria, the Nigerian Financial Intelligence Unit, the Economic and Financial Crimes Commission, and other competent authorities. FalconPay also aligns its compliance practices with internationally recognized standards and best practices, including recommendations issued by the Financial Action Task Force and other relevant international regulatory bodies.
The primary objective of this Policy is to establish a comprehensive compliance framework capable of preventing FalconPay Services from being used to facilitate money laundering, terrorism financing, fraud, financial crime, sanctions evasion, or other unlawful activities. This Policy further seeks to ensure compliance with all applicable legal and regulatory obligations relating to anti-money laundering and counter-terrorism financing. It establishes procedures for customer verification, risk assessment, transaction monitoring, suspicious activity reporting, sanctions compliance, internal oversight, employee awareness, and regulatory cooperation. The Policy is additionally intended to protect FalconPay, its users, financial institution partners, regulators, and the broader financial system from operational, reputational, legal, compliance, and financial risks associated with illicit financial activities.
FalconPay shall maintain full compliance with all applicable anti-money laundering and counter-terrorism financing obligations imposed under Nigerian law and applicable international standards. FalconPay reserves the right to implement compliance measures exceeding minimum regulatory requirements where necessary for risk management, operational security, or regulatory protection. Where applicable laws or regulatory directives impose stricter obligations than those contained in this Policy, such laws or directives shall prevail. Users of FalconPay Services are required to cooperate fully with FalconPay's compliance obligations and provide all information reasonably requested for verification, monitoring, investigations, or regulatory reporting purposes.
FalconPay shall conduct Customer Due Diligence ("CDD") procedures prior to onboarding users and throughout the duration of the business relationship where necessary. The purpose of CDD is to verify customer identities, understand the nature of business activities, assess risks associated with users, and prevent the misuse of FalconPay Services for unlawful purposes. As part of its verification procedures, FalconPay may collect and verify personal identification information, business registration records, beneficial ownership information, proof of address, tax information, banking details, and any additional information reasonably required for compliance purposes. For business entities, FalconPay may verify corporate registration documents, directorship information, ownership structures, operating licenses, source of business activities, and the identities of ultimate beneficial owners. FalconPay reserves the right to refuse onboarding, suspend account activation, restrict transactions, or terminate business relationships where verification requirements are not satisfactorily completed or where suspicious, misleading, incomplete, or unverifiable information is provided. CDD obligations may continue after onboarding, and FalconPay may request updated information, conduct periodic reviews, or require re-verification at any time.
FalconPay applies Enhanced Due Diligence ("EDD") measures to users, businesses, jurisdictions, transactions, or activities classified as high-risk. High-risk classifications may arise from factors including transaction volume, geographical exposure, business category, unusual transaction behavior, politically exposed person status, adverse media findings, sanctions exposure, cryptocurrency involvement, cross-border activity, or any other compliance or operational concern identified by FalconPay. EDD measures may include additional identity verification procedures, source of funds verification, source of wealth assessments, enhanced transaction scrutiny, senior management approval, periodic compliance reviews, ongoing monitoring, or requests for supplementary documentation. FalconPay reserves the right to decline, suspend, restrict, or terminate relationships involving users or transactions considered excessively risky or inconsistent with its compliance obligations.
FalconPay maintains transaction monitoring systems designed to identify, detect, review, and investigate unusual, suspicious, fraudulent, or potentially unlawful activities. Monitoring activities may be conducted through automated systems, manual reviews, behavioral analysis tools, artificial intelligence systems, compliance alerts, risk scoring mechanisms, or any other lawful monitoring process deemed necessary by FalconPay. Transactions may be reviewed based on factors such as abnormal transaction patterns, rapid movement of funds, unusual account behavior, inconsistencies with known customer profiles, large-value transfers, structuring attempts, sanctions concerns, suspicious counterparties, excessive chargebacks, or indicators of financial crime. FalconPay reserves the right to delay, block, reject, reverse, investigate, or suspend transactions pending the outcome of compliance reviews or regulatory obligations.
Where FalconPay identifies transactions or activities reasonably suspected to involve money laundering, terrorism financing, fraud, sanctions violations, financial crime, or other unlawful conduct, FalconPay may file Suspicious Activity Reports ("SARs") or Suspicious Transaction Reports ("STRs") with the appropriate regulatory, financial intelligence, or law enforcement authorities in accordance with applicable laws and regulations. FalconPay may also disclose information to competent authorities where required or permitted under applicable law. Users acknowledge that FalconPay may be prohibited by law from notifying them where a suspicious activity report has been filed or where investigations are ongoing. Any attempt to interfere with, obstruct, influence, manipulate, or evade compliance investigations or reporting obligations shall constitute a serious violation of this Policy.
FalconPay shall maintain records relating to customer identification, account information, transaction history, compliance reviews, investigations, sanctions screening results, communications, and regulatory reporting activities in accordance with applicable legal and regulatory retention requirements. Records may be retained in physical or electronic format and shall be protected using reasonable administrative, technical, and organizational safeguards. FalconPay reserves the right to retain records for such additional periods as may be necessary for legal proceedings, regulatory obligations, dispute resolution, audits, investigations, risk management, or operational purposes.
FalconPay conducts sanctions screening and politically exposed person ("PEP") screening as part of its compliance and risk management framework. Users, businesses, beneficial owners, counterparties, and transactions may be screened against local and international sanctions lists, watchlists, enforcement databases, politically exposed person databases, and adverse media sources. FalconPay reserves the right to reject, suspend, freeze, restrict, investigate, or terminate accounts or transactions associated with sanctioned persons, prohibited jurisdictions, high-risk entities, or persons presenting elevated financial crime risks. Users shall not use FalconPay Services in violation of applicable sanctions laws or regulatory restrictions.
FalconPay maintains internal compliance controls designed to ensure the effective implementation and enforcement of this Policy. Such controls may include role-based access restrictions, audit trails, transaction logs, segregation of duties, compliance oversight structures, escalation procedures, independent reviews, cybersecurity safeguards, reporting channels, governance procedures, and internal approval mechanisms. FalconPay may appoint designated compliance personnel or officers responsible for overseeing compliance implementation, regulatory coordination, monitoring activities, investigations, training programs, and internal reporting obligations. Compliance controls may be reviewed, strengthened, modified, or expanded periodically to address evolving risks, operational changes, technological developments, or regulatory requirements.
FalconPay recognizes that effective AML compliance depends significantly on staff awareness and institutional accountability. Accordingly, FalconPay shall provide periodic training, awareness programs, guidance materials, and compliance education to relevant employees, officers, contractors, and personnel regarding anti-money laundering obligations, suspicious activity identification, transaction monitoring procedures, sanctions compliance, regulatory expectations, and reporting responsibilities. Training programs may be updated periodically to reflect changes in laws, regulations, financial crime trends, emerging risks, or operational procedures.
FalconPay adopts a risk-based approach in identifying, assessing, managing, and mitigating money laundering and terrorism financing risks. The risk-based approach enables FalconPay to allocate compliance resources proportionately based on the nature, size, complexity, geographical exposure, transaction behavior, business model, and risk profile associated with users or activities. Risk assessments may be conducted periodically and may result in enhanced monitoring, additional compliance obligations, transaction restrictions, account reviews, or termination of business relationships where appropriate. FalconPay reserves the sole discretion to determine risk classifications and corresponding compliance measures.
FalconPay reserves the right to take any action deemed necessary to ensure compliance with applicable anti-money laundering obligations and to protect the integrity of its platform and financial ecosystem. Such actions may include account suspension, transaction restrictions, freezing of funds where legally permissible, enhanced monitoring, reporting to competent authorities, refusal of services, termination of business relationships, or legal enforcement measures. FalconPay may cooperate fully with regulators, law enforcement agencies, financial intelligence units, courts, financial institutions, payment partners, and other competent authorities in relation to investigations, regulatory requests, subpoenas, compliance reviews, enforcement proceedings, or information-sharing obligations permitted under applicable law.
FalconPay shall not be liable for losses, damages, delays, restrictions, account suspensions, frozen funds, declined transactions, or enforcement actions arising from compliance with applicable anti-money laundering laws, sanctions obligations, regulatory directives, internal compliance procedures, or actions taken pursuant to this Policy.
FalconPay reserves the right to review, revise, amend, update, or replace this Policy at any time in response to regulatory developments, changes in law, evolving financial crime risks, operational requirements, technological developments, or industry best practices. Updated versions of this Policy shall become effective upon publication on FalconPay's website or through other communication channels determined appropriate by FalconPay. Continued use of FalconPay Services following such updates constitutes acceptance of the revised Policy.
This Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any dispute arising out of or relating to this Policy shall be subject to the exclusive jurisdiction of the competent courts in Nigeria.
As a condition precedent to the commencement of any legal action, suit, claim, arbitration, or regulatory proceeding against FalconPay, the user shall first issue a written Pre-Action Notice to FalconPay detailing the nature of the complaint, the facts relied upon, the reliefs sought, and all supporting documents relevant to the dispute. FalconPay shall be entitled to a period of three (3) months from the date of receipt of the Pre-Action Notice within which to investigate, review, respond to, and where applicable, attempt amicable settlement of the dispute before any proceedings may be commenced. Failure to comply with this provision may render any action premature or incompetent to the fullest extent permitted under applicable law.
FalconPay Limited Email: support@falconpay.ng FalconPay Business Website