logo






Anti-Money Laundering (AML) Policy

1. Introduction

 Midoman ("the Company") is dedicated to combating money laundering, terrorist financing, and other financial crimes. We are committed to adhering to all applicable laws and regulations in Nigeria and internationally to maintain the integrity of our platform and protect our users.



2. Definition of Money Laundering

 Money laundering involves processing illicit funds to obscure their true origin, making them appear legitimate. This process typically includes:

  •   Placement:  Introducing illegal funds into the financial system.
  •   Layering:       Conducting complex transactions to conceal the source.
  •   Integration:   Reintroducing laundered funds into the economy as legitimate assets.

 Such activities facilitate corruption and organized crime, enabling individuals to legitimize proceeds from illegal activities.



3. Commitment to Compliance

  Midoman is committed to:

  •   Implementing internal controls to deter and detect money laundering and terrorist financing activities.
  •   Complying with all relevant Nigerian laws, including the Money Laundering (Prevention and Prohibition) Act, 2022.
  •   Cooperating with regulatory and law enforcement agencies to combat financial crimes.


4. Internal Controls and Procedures

 To prevent misuse of our platform:

  •   Risk-Based Approach:  We assess and manage risks associated with money laundering and terrorist financing by implementing appropriate measures based on the level of risk identified.
  •   Transaction Monitoring:  We utilize both automated and manual systems to monitor transactions for suspicious activities, such as unusually large or frequent transactions and those involving high-risk jurisdictions.
  •   Record Keeping:  We maintain comprehensive records of customer identification, transaction histories, and any reports of suspicious activities for a minimum of five years, in compliance with Nigerian regulations.


5. Know Your Customer (KYC) and Customer Due Diligence (CDD)

 We have established a risk-based approach to KYC and CDD procedures:

  •   Customer Identification:  Collecting and verifying personal information, including full name, date of birth, residential address, and government-issued identification.
  •   Enhanced Due Diligence:  Applying additional scrutiny to high-risk customers, such as those with large transaction volumes or from high-risk countries.
  •   Ongoing Monitoring:  Continuously monitoring customer transactions to identify and report suspicious activities promptly.


6. Employee Training and Awareness

  Midoman provides regular training to all employees to:

  •   Recognize and report suspicious activities.
  •   Understand their responsibilities under AML laws and company policies.
  •   Stay informed about emerging trends and regulatory updates related to money laundering and terrorist financing.


7. Reporting Suspicious Activities

  Employees are required to report any suspicious activities to the Compliance Unit immediately. The Compliance Unit will assess the report and, if necessary, file a Suspicious Transaction Report (STR) with the Nigerian Financial Intelligence Unit (NFIU), in accordance with legal requirements.




8. Compliance Officer

  Midoman has appointed a Compliance Officer responsible for:

  •   Overseeing the implementation and enforcement of this AML Policy.
  •   Ensuring ongoing compliance with all relevant laws and regulations.
  •   Serving as the primary point of contact for regulatory bodies and law enforcement agencies.


9. Policy Review

 This AML Policy will be reviewed and updated regularly to reflect changes in regulations, emerging risks, and alterations in our business operations.