AML & Compliance Policy
How TRADESMART keeps the platform — and Nigeria's financial system — safe from money laundering and terrorism financing.
Know Your Customer (KYC)
Every user is verified against government-issued ID, BVN, and live selfie. Tiered limits unlock as verification deepens.
Transaction monitoring
All transactions are monitored in real time against typology rules and machine-learning risk models, with manual review on high-risk flags.
Suspicious activity reporting
We file Suspicious Transaction Reports (STRs) with the NFIU within statutory timeframes, and freeze accounts where required by law.
Sanctions screening
All users and counterparties are screened against UN, OFAC, EU, and Nigerian sanctions lists, with daily re-scans.
1. Regulatory framework
TRADESMART operates in line with the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, the SCUML directives, the SEC Digital Assets Rules 2022, and CBN guidelines applicable to Virtual Asset Service Providers (VASPs).
2. Risk-based approach
We assess each customer for ML/TF risk based on identity, geography, source of funds, transaction patterns, and PEP status. Higher-risk relationships receive Enhanced Due Diligence (EDD) and ongoing review.
3. Customer Due Diligence (CDD)
All accounts complete identity verification (NIN/BVN + government ID), liveness check, and address confirmation before transacting. Tier-2 and Tier-3 limits require additional documentation.
4. Source of funds
Large or unusual deposits may trigger a request for proof of source of funds (e.g., trade receipts, salary slip, business registration). Failure to provide acceptable evidence may result in funds being held pending review.
5. Record keeping
We retain CDD records, transaction records, and SAR/STR filings for a minimum of seven (7) years from the date of transaction or account closure.
6. Training
All TRADESMART staff complete AML/CFT training within 30 days of joining and refresher training annually. Operations and compliance staff receive additional, role-specific training.
7. Compliance officer
Our designated Money Laundering Reporting Officer (MLRO) is registered with SCUML and is the primary point of contact with regulators and law enforcement.
8. Reporting concerns
If you believe an account is being misused, email compliance@tradesmart.ng. All reports are treated confidentially.
Compliance contact: compliance@tradesmart.ng