icon TABLE OF CONTENTS
  1. Introduction
  2. Objectives
  3. Customer Due Diligence (CDD)
  4. Transaction Monitoring
  5. Reporting of Suspicious Activity
  6. Record Keeping
  7. Staff Training
  8. Risk Assessment
  9. Compliance Officer
  10. Conclusion

1. Introduction

BITLIVA is committed to the highest standards of anti-money laundering (AML), counter-terrorism financing (CTF), and compliance. This Anti-Money Laundering Policy outlines our obligations, procedures, and internal controls to prevent, detect, and report any suspicious activity related to money laundering or terrorist financing through the BITLIVA platform.

This policy is designed in compliance with:

  • The Money Laundering (Prohibition) Act, 2011 (as amended) – Nigeria
  • The Nigerian Financial Intelligence Unit (NFIU) guidelines
  • The Financial Action Task Force (FATF) recommendations
  • Applicable international AML/CTF laws and standards

2. Objectives

The objectives of this AML policy are:

  • To prevent the use of BITLIVA for money laundering or terrorist financing
  • To implement a risk-based approach to customer due diligence (CDD)
  • To establish proper Know Your Customer (KYC) procedures
  • To report suspicious transactions to the appropriate authorities
  • To ensure continuous AML training and awareness for all relevant employees

3. Customer Due Diligence (CDD)

BITLIVA conducts Customer Due Diligence before any customer can access key features of our platform. This includes:

3.1.   Know Your Customer (KYC) Requirements:
All users must submit the following:
Legal Full Name
Bank Verification Number (BVN)

3.2.   Enhanced Due Diligence (EDD):
EDD applies to high-risk customers or large transactions and may include:
Source of funds verification
Ongoing transaction monitoring
Additional documentation or interviews

3.3.   Politically Exposed Persons (PEPs):
BITLIVA screens for PEPs and applies additional scrutiny where necessary.

4. Transaction Monitoring

BITLIVA uses automated and manual systems to monitor:

  • Large or unusual transactions
  • Rapid movement of funds
  • Transactions involving high-risk jurisdictions
  • Activity inconsistent with a user’s profile
  • Suspicious transactions are flagged, reviewed, and escalated to our Compliance Officer for further action.

5. Reporting of Suspicious Activity

BITLIVA will report any suspicious activity to the Nigerian Financial Intelligence Unit (NFIU) in accordance with the Money Laundering Prohibition Act. No user will be notified of such reports (Tipping-off is prohibited by law).

6. Record Keeping

All AML-related documents and communications, including KYC records, transaction logs, and internal reports, are securely retained for a minimum of 5 years from the date of the last transaction or user activity.

7. Staff Training

All staff involved in AML-sensitive operations receive:

  • Initial and ongoing AML training
  • Updates on emerging threats and regulations
  • Access to the company’s AML procedures and escalation protocols

8. Risk Assessment

BITLIVA regularly conducts risk assessments to:

  • Identify vulnerabilities in the platform
  • Review customer risk levels
  • Adjust controls as necessary to meet regulatory expectations

9. Compliance Officer

BITLIVA has appointed a Compliance Officer responsible for:

  • Overseeing all AML policies and procedures
  • Ensuring proper training and implementation
  • Liaising with regulators and financial intelligence units

10. Conclusion

BITLIVA takes its responsibility to prevent financial crime seriously. This AML Policy ensures that we protect our users, comply with applicable laws, and maintain the integrity of the crypto-financial ecosystem.