Compliance & Regulatory

Anti-Money Laundering Policy

Our commitment to preventing financial crime and maintaining the integrity of the Nigerian financial system.

Last updated: May 2026

1. Overview and Policy Statement

Alltrust is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. This policy has been established to prevent the platform from being used as a vehicle for money laundering or the financing of terrorism.

This policy applies to all users, employees, agents, and third parties who interact with Alltrust. Non-compliance with this policy may result in account termination and reporting to relevant authorities.

Regulatory Framework

This policy complies with the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, and applicable Central Bank of Nigeria (CBN) directives on AML/CFT for financial institutions.

2. Our Legal Obligations

Customer Due Diligence (CDD)

Verify the identity of all customers before providing services. This includes collecting and verifying full name, address, date of birth, BVN, and NIN where applicable.

Enhanced Due Diligence (EDD)

Apply additional verification measures for high-risk customers including Politically Exposed Persons (PEPs), customers from high-risk countries, and high-value transactions.

Record Keeping

Maintain all customer identification records, transaction records, and AML compliance documentation for a minimum of 5 years as required by Nigerian law.

Transaction Monitoring

Monitor all transactions for unusual patterns, structuring, rapid movement of funds, and other red flags using automated systems and manual review.

Suspicious Activity Reporting

File Suspicious Transaction Reports (STRs) with the Nigerian Financial Intelligence Unit (NFIU) within 72 hours of detecting suspicious activity.

Staff Training

Ensure all relevant staff receive regular AML/CFT training and are aware of their legal obligations and the platform's reporting procedures.

3. Know Your Customer (KYC) Requirements

Alltrust operates a tiered KYC system aligned with CBN's tiered KYC policy for digital financial services:

KYC Level 0 — Unverified

  • Phone number and email verification only
  • Daily transaction limit: ₦20,000
  • Monthly limit: ₦50,000
  • Cannot join circles or apply for loans

KYC Level 1 — Basic

  • BVN or NIN verification required
  • Daily transaction limit: ₦200,000
  • Monthly limit: ₦1,000,000
  • Can join circles and create savings plans

KYC Level 2 — Full

  • BVN + address verification required
  • Daily transaction limit: ₦1,000,000
  • Monthly limit: ₦5,000,000
  • Can apply for micro-loans up to ₦500,000

KYC Level 3 — Premium

  • Full KYC + income verification required
  • Daily transaction limit: ₦10,000,000
  • Monthly limit: ₦50,000,000
  • Access to all platform features and maximum loan amounts

4. Transaction Monitoring

All transactions on Alltrust are monitored in real-time and retrospectively for the following red flags:

Structuring (smurfing)

Breaking large transactions into smaller amounts to avoid detection thresholds.

Rapid fund movement

Depositing and immediately withdrawing funds with no economic rationale.

Multiple account activity

Using multiple accounts to move funds between them.

Unusual transaction patterns

Transactions inconsistent with the user's stated income or profile.

High-risk geographies

Transactions involving countries on FATF or UN sanctions lists.

Anonymous funding sources

Attempts to fund wallets from unverified or untraceable sources.

5. Reporting Suspicious Activity

Tipping-off Prohibition: You must not inform any person that a suspicious transaction report has been filed or that they are under investigation. Doing so is a criminal offence under Nigerian law and may result in prosecution.

If you suspect that a transaction or activity on the platform relates to money laundering or terrorism financing, report it immediately to:

Money Laundering Reporting Officer (MLRO)

Email: compliance@alltrust.com

Reports are treated with strict confidentiality and forwarded to the Nigerian Financial Intelligence Unit (NFIU) where required.

6. Sanctions Compliance

Alltrust screens all users and transactions against:

  • United Nations Security Council sanctions lists
  • Office of Foreign Assets Control (OFAC) lists
  • CBN and NFIU sanctioned entities lists
  • EU and UK financial sanctions registers
  • Politically Exposed Persons (PEP) databases

Any match will result in immediate account freeze and mandatory reporting to the NFIU within 24 hours, without notice to the account holder.

7. Training and Awareness

All staff with customer-facing or financial oversight roles receive mandatory AML/CFT training at onboarding and annually thereafter. Training covers recognition of money laundering typologies, reporting obligations, and the consequences of non-compliance.

8. Contact the MLRO

For questions about this policy, AML compliance, or to report suspicious activity, contact our Money Laundering Reporting Officer:

Alltrust Compliance Team

All compliance inquiries are handled within 2 business days. Suspicious activity reports are actioned immediately.

Contact Compliance Team