AML Policy

  1. Introduction
    This Anti-Money Laundering (“AML”) Policy sets out the commitment of xpressbuy247.com (“XpressBuy247”, “we”, “our”, or “the Company”) to preventing the use of our platform for money laundering, terrorist financing, or any other financial crime.
    As an e-commerce and digital services business, we recognize that while we do not request KYC documentation at onboarding, we must still operate under strict monitoring, detection, and reporting mechanisms to minimize financial crime risks.
    This policy is designed in accordance with international AML standards, including:

Financial Action Task Force (FATF) Recommendations
Nigeria’s Money Laundering (Prevention and Prohibition) Act, 2022
Applicable Central Bank of Nigeria (CBN) guidelines
Best practices for global e-commerce and payment service businesses.

  1. Purpose
    The purpose of this AML Policy is to:

Prevent xpressbuy247.com from being used for money laundering or terrorist financing.
Establish internal procedures for monitoring, detecting, and reporting suspicious activities.
Ensure customer trust, payment partner confidence, and compliance with regulatory expectations.
Maintain the integrity of our services for Shop-for-Me, Digital Products, and Dropshipping of Gadgets.

  1. Scope
    This AML Policy applies to:

All transactions carried out on xpressbuy247.com.
All payment methods supported by our payment partners.
All employees, contractors, and agents of the Company.
All customers making use of our services globally.

  1. Customer Due Diligence (CDD) Approach
    While XpressBuy247 does not require KYC documentation at onboarding, we employ risk-based, transaction-level monitoring to ensure AML compliance.
    4.1 Simplified Due Diligence

Customers may make purchases without submitting government-issued identification during onboarding.
Customer identity is indirectly verified through payment channel validation (e.g., bank transfers, card payments, mobile money).

4.2 Enhanced Due Diligence (EDD)
If certain transactions or behaviors appear suspicious, unusual, or high-risk, we may request additional details, such as:

Purpose of the transaction.
Source of funds.
Verification of identity via official documentation.

EDD will be triggered if:

A customer consistently makes large-value purchases above established thresholds.
Transactions show signs of structuring (splitting payments to avoid detection).
The customer requests multiple refunds or chargebacks without valid reason.
A customer attempts to use multiple unrelated payment instruments in a short timeframe.

  1. Monitoring and Reporting
    5.1 Transaction Monitoring
    We actively monitor transactions on our platform to identify unusual activity. This includes:

Automated monitoring tools integrated with our payment processors.
Flagging thresholds for high-value or unusual transactions.
Regular manual reviews of suspicious transaction patterns.

5.2 Suspicious Activity Indicators
Suspicious activity may include, but is not limited to:

Large or repeated transactions inconsistent with normal purchasing behavior.
Unusually high demand for certain digital products (e.g., gift cards, airtime, subscriptions).
Attempts to bypass transaction limits.
Payments originating from high-risk jurisdictions flagged by FATF.
Multiple accounts using the same payment method.

5.3 Reporting Obligations
When suspicious activity is detected:

A Suspicious Transaction Report (STR) will be documented internally.
Reports will be escalated to the Money Laundering Reporting Officer (MLRO) for review.
If confirmed, STRs will be filed with the Nigerian Financial Intelligence Unit (NFIU) or the relevant authority in the customer’s jurisdiction.

  1. Roles and Responsibilities
    6.1 Money Laundering Reporting Officer (MLRO)

Oversees AML compliance within XpressBuy247.
Reviews suspicious transaction reports.
Acts as point of contact with regulatory authorities and payment partners.

6.2 Employees and Agents

Must remain vigilant for unusual customer behavior.
Must escalate any suspicions immediately to the MLRO.
Must comply with internal AML training requirements.

  1. Record Keeping
    XpressBuy247 will maintain accurate records of:

All transactions conducted on the platform.
Suspicious Transaction Reports (STRs).
Communications with regulatory authorities.

Records will be stored securely and retained for a minimum of 5 years, in line with AML regulations.

  1. Training and Awareness

All staff will receive regular AML training on how to detect and report suspicious transactions.
Updates will be provided when AML regulations or internal procedures change.

  1. Risk Management
    XpressBuy247 applies a risk-based approach to AML by:

Using transaction monitoring in place of upfront KYC for low-risk customers.
Triggering EDD for higher-risk transactions.
Applying stricter controls to high-risk jurisdictions and digital products prone to abuse (e.g., gift cards).

  1. Customer Safety & Assurance
    To maintain trust and safety:

All payments are processed through regulated and trusted payment partners.
Transactions are encrypted, traceable, and verifiable.
No customer funds are held outside regulated financial channels.
We operate under strict transparency — customers always receive confirmation receipts.

  1. Policy Review
    This AML Policy will be reviewed annually, or sooner if regulatory or operational changes require. Updates will be communicated to all stakeholders.
  2. Conclusion
    XpressBuy247 is committed to upholding the highest standards of integrity, compliance, and customer protection. While we do not collect KYC documents at onboarding, our robust monitoring systems, enhanced due diligence processes, and reporting obligations ensure that our platform cannot be misused for money laundering or terrorist financing.
    By combining technology-driven monitoring with regulatory compliance, we guarantee a safe, transparent, and trustworthy environment for both our customers and our partners.