Anti-Money Laundering (AML) and KYC Policy
1. Introduction and Objectives
Welcome to Bangbet Nigeria (bangbetnigeria.com.ng). As a reputable sports betting and casino operator dedicated to the Nigerian market, we are fully committed to preventing our platform from being exploited for financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the strict measures, procedures, and internal controls we have implemented to detect, prevent, and report money laundering and the financing of terrorism.
Our objective is straightforward: to provide a secure, transparent, and legally compliant betting environment for all Nigerian punters while rigorously protecting the integrity of the Nigerian financial system.
2. Regulatory Framework
This AML Policy is strictly guided by the extant laws and regulatory bodies of the Federal Republic of Nigeria. Our compliance framework aligns with:
- The Money Laundering (Prevention and Prohibition) Act, 2022 (MLPPA 2022) KYC Registry
- The Terrorism (Prevention and Prohibition) Act, 2022 KYC Registry
- Directives from the Nigerian Financial Intelligence Unit (NFIU) KYC Registry
- Guidelines set by the Special Control Unit Against Money Laundering (SCUML) under the Economic and Financial Crimes Commission (EFCC) Morgan Cole Partners
- Regulatory standards established by the Lagos State Lotteries and Gaming Authority (LSLGA) and the National Lottery Regulatory Commission (NLRC)
As a Designated Non-Financial Business and Profession (DNFBP) under Nigerian law, Bangbet Nigeria adheres fully to its statutory obligations regarding risk management and transaction reporting.
3. The Role of the AML Compliance Officer (AMLCO)
To ensure the effective implementation of this policy, Bangbet Nigeria has appointed a dedicated Anti-Money Laundering Compliance Officer (AMLCO) at the senior management level. The AMLCO is responsible for:
- Overseeing all daily AML, CFT (Combating the Financing of Terrorism), and KYC operations.
- Updating risk assessment frameworks and internal control procedures.
- Reviewing and filing Suspicious Transaction Reports (STRs) to the NFIU. KYC Registry
- Ensuring all employees receive regular, up-to-date compliance training.
- Acting as the primary liaison between Bangbet Nigeria and local law enforcement agencies.
4. Know Your Customer (KYC) and Customer Due Diligence (CDD)
To prevent anonymous, underage, or fraudulent usage of our platform, Bangbet Nigeria employs a robust Customer Due Diligence (CDD) protocol. All users must be properly identified and verified.
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4.1. Standard Identity Verification
Before processing significant withdrawals or when an account reaches certain thresholds, we require customers to verify their identity. Accepted verification documents include:
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- National Identification Number (NIN) slip or card.
- Bank Verification Number (BVN) – utilized strictly for identity confirmation in partnership with secure payment gateways.
- Valid Nigerian International Passport.
- Permanent Voter’s Card (PVC).
- Valid Driver’s License. KYC Registry
4.2. Proof of Address
In addition to identity verification, we may request a recent proof of residential address (not older than three months). Accepted documents include:
- Utility bills (e.g., electricity or water bills).
- Bank statements showing the customer’s full name and residential address.
- Local government tax clearance certificates.
4.3. Enhanced Due Diligence (EDD)
For accounts that flag higher risks—such as unusually large transaction volumes, irregular betting patterns, or connections to high-risk jurisdictions—Bangbet Nigeria applies Enhanced Due Diligence (EDD). Under EDD, we reserve the right to request:
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- Proof of the Source of Funds (e.g., payslips, business registration documents, or detailed bank statements).
- Proof of the Source of Wealth. Scribd
- Direct senior management approval to maintain the business relationship. Scribd
5. Politically Exposed Persons (PEPs) and Sanctions Screening
In strict accordance with Section 4 of the MLPPA 2022, Bangbet Nigeria applies stringent checks regarding Politically Exposed Persons (PEPs). A PEP is an individual who is or has been entrusted with a prominent public function (either domestically or internationally), as well as their immediate family members and close associates.
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- Screening: All accounts are screened against local PEP databases, as well as global sanctions lists (including UN, OFAC, and EU lists).
- Approval: Accounts identified as belonging to PEPs require immediate Enhanced Due Diligence (EDD) and specific approval from senior management before they can operate freely. Scribd
- Ongoing Monitoring: PEP accounts are subjected to rigorous, continuous monitoring to ensure their source of wealth remains legitimate. KYC Registry
6. Financial Transactions and Risk Monitoring
We utilize advanced, automated transaction monitoring systems to track user activity in real-time. To mitigate money laundering risks, Bangbet Nigeria enforces the following strict financial rules:
- Closed-Loop System: Withdrawals must be processed back to the exact same bank account or mobile wallet (e.g., OPay, PalmPay, Paystack) used for the initial deposit.
- No Third-Party Transactions: We strictly prohibit third-party deposits and withdrawals. The name registered on the betting account must identically match the name on the financial instrument used for funding and cashouts.
- Digital Traceability: In compliance with NFIU and SCUML thresholds, we do not accept raw cash deposits. All account funding must pass through traceable, licensed electronic banking channels.
- Turnover Requirements: To prevent the platform from being used as a digital wallet to mask illicit fund movements, all deposited funds must be wagered at least once before a withdrawal can be requested.
7. Suspicious Transaction Reporting (STR)
Bangbet Nigeria operates a strict internal reporting protocol regarding suspicious financial behavior. Under Nigerian law, we are legally mandated to report any suspicious activities without “tipping off” the customer.
Indicators of suspicious activity include, but are not limited to:
- Depositing large sums of money and attempting to withdraw it immediately with little to no betting activity.
- Providing forged, altered, or stolen identification documents.
- Using multiple accounts to bypass transaction limits (smurfing).
- Requests to transfer winnings to an unrelated third party.
Upon detecting such activities, the AML Compliance Officer will freeze the account pending investigation and file a Suspicious Transaction Report (STR) directly with the NFIU within 24 hours.
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8. Record Keeping
In full compliance with Section 11 of the MLPPA 2022, Bangbet Nigeria maintains comprehensive and secure records of all user activities.
- Customer Identification Records: All KYC documents, BVN verification logs, and communication histories are securely encrypted.
- Transaction Records: Detailed logs of all deposits, bets, wins, and withdrawals are digitally archived.
- Retention Period: All records are retained for a minimum of five (5) years after the termination of the business relationship or the completion of an occasional transaction. These records are kept strictly confidential but remain accessible to competent regulatory and law enforcement authorities upon lawful request. KYC Registry+ 1
9. Employee Training and Awareness
An effective AML policy relies heavily on the vigilance of our staff. Bangbet Nigeria ensures that all employees—especially those in customer support, finance, and risk management departments—undergo mandatory, regular AML/CFT training.
This training covers:
- The legal obligations under the MLPPA 2022 and current terrorism prevention laws.
- How to identify red flags, money laundering typologies, and unusual betting behaviors.
- Internal procedures for escalating suspicious activities to the AML Compliance Officer.
- The severe legal consequences of tipping off a customer under investigation. KYC Registry
10. Policy Review and Audits
The methods used by financial criminals are constantly evolving. Consequently, Bangbet Nigeria conducts regular independent audits of our AML/CFT framework to ensure its continuous effectiveness. This policy is reviewed annually and updated dynamically in response to new directives from the NLRC, LSLGA, NFIU, EFCC, and other relevant Nigerian legislative bodies.
11. Contact Us
If you have any questions regarding our Anti-Money Laundering Policy, Know Your Customer procedures, or if you need to securely submit verification documents, please reach out to our dedicated compliance team:
- Email: [email protected]
- Customer Support: Available via Live Chat and official helplines found on our Contact Us page.
Disclaimer: Bangbet Nigeria reserves the full right to suspend accounts, seize funds, and report users to the appropriate Nigerian law enforcement agencies if we reasonably suspect any involvement in money laundering, terrorism financing, or other fraudulent activities.
