Fimpaypoint (operated by FIM DIGITAL VENTURES LIMITED) provides financial technology software and payment infrastructure, Banking services, virtual Account Number issuance, and settlement disbursements are provided via our CBN-licensed commercial banking partners and licensed switches. Merchant funds are safely held in segregated custodial trust accounts insured by the NDIC.
1 Introduction
Fimpaypoint is committed to maintaining the highest standards of integrity, security, transparency, and regulatory compliance.
This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the comprehensive measures implemented by FIM DIGITAL VENTURES LIMITED ("Fimpaypoint") to prevent money laundering, terrorist financing, fraud, sanctions violations, identity theft, financial crime, and other prohibited activities.
By using Fimpaypoint's products, services, dashboards, APIs, or payment gateways, customers and merchants agree to comply with this Policy and provide accurate, truthful information when requested.
2 Purpose
The core objectives of this Policy are to:
- Prevent the use of Fimpaypoint for illegal activities and financial crimes.
- Protect merchants, customers, partners, and financial institution networks.
- Comply with applicable statutory laws, Central Bank directives, and regulatory obligations.
- Verify the true legal identity of customers, corporate entities, and merchants.
- Detect and prevent suspicious transactions, pass-through velocity anomalies, and unauthorized fund movements.
- Continuously monitor platform activity for fraud, abuse, and chargeback anomalies.
- Support national and global financial crime prevention and anti-terrorist financing efforts.
3 Scope
This Policy applies universally to:
- Individual customers
- Business customers
- Merchants & enterprise clients
- API users & integrators
- Developers
- Partners & banking switches
- Employees & contractors
- Hosted Checkout & Paylinks
- Dedicated Virtual Accounts
- Payment Collection Rails
- Interbank Settlements
- Automated Payouts & Transfers
- REST APIs & Webhooks
- Developer Infrastructure
4 Customer Identification & Verification (KYC)
Fimpaypoint collects, validates, and independently verifies identity information before granting access to payment processing, dedicated collection virtual accounts, and disbursement features.
Individual Customers & Proprietors
Information and biometric artifacts collected may include:
Business Customers & Registered Merchants
Corporate verification documentation may include:
* Fimpaypoint reserves the right to request additional supporting documentation or re-verification at any time.
5 Risk-Based Approach (RBA)
Fimpaypoint applies a rigorous risk-based approach to onboarding, underwriting, and ongoing portfolio monitoring. Accounts are assessed and categorized into tiered risk levels:
Fully verified individuals and established commercial businesses operating within standard retail or digital services with stable, predictable transaction patterns.
Newly onboarded merchants, starter enterprises with limited historical processing data, or businesses exhibiting higher-than-average transaction velocity and growth spikes.
Merchants in high-risk commercial sectors, high-volume cross-border processing, rapid funds-flow profiles, or accounts requiring specialized enhanced surveillance and continuous audit.
6 Enhanced Due Diligence (EDD)
Fimpaypoint conducts Enhanced Due Diligence (EDD) where transaction metrics, customer location, industry, or corporate structures indicate elevated risk. Additional requirements may include:
- Source of Funds (SOF) Verification: Invoices, contracts, or bank proof demonstrating legitimate commercial origin of processed capital.
- Source of Wealth (SOW) Documentation: Audited financial statements or shareholder disclosures for high-volume processors.
- Beneficial Ownership & PEP Screening: Screening against international sanctions (OFAC, UN, UK HMT) and Politically Exposed Persons (PEP) registries.
- Enhanced Real-Time Telemetry: Accelerated velocity throttles, multi-factor payout authorizations, and mandatory review thresholds.
Fimpaypoint reserves the right to decline onboarding, suspend payouts, or restrict platform operations where satisfactory EDD verification cannot be completed.
7 Transaction Monitoring & Pattern Surveillance
Fimpaypoint continuously surveils all inbound payment collections, virtual account credits, and outbound settlements using automated AML heuristics and fraud scoring engines.
Monitored patterns and red flags include:
8 Prohibited Activities & Sanctions
Fimpaypoint maintains an absolute zero-tolerance standard against prohibited activities. Platform services, virtual accounts, and payment links may NEVER be utilized for:
9 Payout Monitoring & Anti-Fraud Controls
Merchants utilizing automated disbursement and settlement rails are subject to operational safeguard controls, including:
- Beneficiary Validation: Real-time interbank name-inquiry resolution before payout release.
- Daily Velocity Ceilings: Tiered processing caps adjusted according to compliance status and processing history.
- Multi-Factor Authorization: Mandatory secondary verification (Email OTP / 2FA) for manual and API payouts.
- IP Whitelisting: Server IP restrictions enforced on merchant API keys to prevent unauthorized webhook or payout injection.
- Manual Risk Gateways: High-risk or unusual transfer requests trigger operational review prior to banking gateway dispatch.
10 Account Review & Operational Restrictions
Fimpaypoint reserves the unrestricted operational right to:
- Restrict account features and processing capabilities.
- Temporarily suspend service access or disable API credentials.
- Delay or withhold interbank settlements pending investigation.
- Freeze balances and dispute settlement disbursements.
- Demand refreshed or notarized corporate verification documentation.
Such actions may be implemented where fraudulent behavior is suspected, account ownership cannot be confirmed, statutory directives mandate a hold, or elevated chargeback ratios compromise platform integrity.
11 Reporting & Regulatory Cooperation
FIM DIGITAL VENTURES LIMITED strictly fulfills statutory reporting mandates in accordance with prevailing laws, collaborating directly with:
Where required by law, Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs) will be filed without notice to the investigated customer (anti-tipping-off provisions).
12 Record Retention
Fimpaypoint maintains an encrypted, tamper-evident audit repository of all customer onboarding records, government identity documents, transaction histories, settlement records, and communication logs.
All compliance records are retained for a minimum statutory period of five (5) to seven (7) years following the termination of customer relationships or execution of transactions, in compliance with Nigerian AML/CFT regulations and statutory requirements.
13 Data Protection & Confidentiality
Personal, corporate, and biometric data obtained during KYC and transaction monitoring is processed in rigorous adherence to:
- The Nigeria Data Protection Act (NDPA 2023).
- The Fimpaypoint Privacy & Data Protection Policy.
- Institutional Information Security policies and TLS 1.3 encrypted data-at-rest baselines.
Data collected for AML/KYC obligations is held strictly confidential and never commercialized, monetized, or shared with unauthorized commercial entities.
14 Security & Fraud Escalation Channels
Suspicious platform events trigger automated escalation protocols directly to our specialized operational divisions:
15 Policy Updates & Contact Information
FIM DIGITAL VENTURES LIMITED reserves the right to update or modify this AML & KYC Policy periodically to reflect emerging statutory regulations, supervisory guidance, and technological enhancements. The most recent version will always remain publicly available on our website.