Last updated: December 15, 2024

1. Introduction

Bitsmart Pay is committed to preventing money laundering and terrorist financing. This Anti-Money Laundering (AML) Policy outlines our commitment to detecting and preventing money laundering activities and complying with all applicable laws and regulations.

2. Regulatory Framework

Our AML program complies with:

• Central Bank of Nigeria (CBN) AML/CFT Regulations
• Nigerian Financial Intelligence Unit (NFIU) Guidelines
• Money Laundering (Prohibition) Act 2011 (as amended)
• Terrorism (Prevention) Act 2013 (as amended)
• FATF Recommendations

3. Customer Due Diligence (CDD)

We implement comprehensive Know Your Customer (KYC) procedures:

3.1 Identity Verification

• Government-issued photo ID (National ID, International Passport, Driver's License)
• Proof of address (utility bill, bank statement)
• Biometric verification (facial recognition)
• Phone number verification
• Email verification

3.2 Enhanced Due Diligence (EDD)

For high-risk customers or transactions above ₦5,000,000, we conduct enhanced due diligence including:

• Source of funds verification
• Purpose of transaction documentation
• Additional background checks
• Senior management approval

4. Transaction Monitoring

We employ sophisticated transaction monitoring systems to detect suspicious activities:

• Real-time transaction screening
• Pattern recognition algorithms
• Unusual transaction alerts
• Velocity checks
• Cross-border transaction monitoring

5. Suspicious Activity Reporting

We maintain procedures for identifying and reporting suspicious activities:

• Immediate escalation to Compliance Officer
• Investigation within 24 hours
• Suspicious Transaction Reports (STRs) filed with NFIU
• Currency Transaction Reports (CTRs) for transactions above threshold
• No tipping off policy strictly enforced

6. Red Flags

We monitor for common money laundering indicators including:

• Rapid movement of funds without clear business purpose
• Structuring transactions to avoid reporting thresholds
• Unusual patterns inconsistent with customer profile
• Use of multiple accounts for no apparent reason
• Reluctance to provide required information
• Transactions involving high-risk jurisdictions

7. Sanctions Screening

All customers and transactions are screened against:

• UN Security Council Sanctions List
• OFAC Specially Designated Nationals (SDN) List
• EU Consolidated Sanctions List
• Local law enforcement lists
• Politically Exposed Persons (PEP) databases

8. Record Keeping

We maintain comprehensive records:

• Customer identification documents - 5 years after relationship ends
• Transaction records - 5 years from transaction date
• Suspicious activity reports - 5 years
• Training records - 5 years
• Internal investigation files - 5 years

9. Staff Training

All employees receive comprehensive AML training:

• Initial AML training upon hiring
• Annual refresher training
• Role-specific training for high-risk functions
• Updates on regulatory changes
• Testing and certification requirements

10. Compliance Officer

Our designated AML Compliance Officer is responsible for:

• Implementing and maintaining the AML program
• Conducting risk assessments
• Filing regulatory reports
• Training coordination
• Internal audits and reviews
• Liaison with regulatory authorities

11. Risk Assessment

We conduct regular risk assessments considering:

• Customer risk (type, location, activity)
• Product/service risk
• Geographic risk
• Channel risk
• Regulatory risk

12. Penalties for Non-Compliance

Violations of this AML policy may result in:

• Account suspension or termination
• Transaction reversal
• Reporting to law enforcement
• Legal prosecution
• Asset freezing

13. Customer Cooperation

Customers are required to:

• Provide accurate and complete information
• Update information when changes occur
• Cooperate with verification requests
• Report suspicious activities
• Not engage in money laundering activities

14. Contact Information

For AML-related inquiries or to report suspicious activities:
Email: compliance@bitsmartpay.com
Phone: +234 700 REPORT1
Anonymous Tip Line: report.bitsmartpay.com

Last updated: December 15, 2024

1. Information We Collect

We collect information you provide directly to us, such as when you create an account, make a transaction, or contact us for support. This includes:

• Personal information (name, email, phone number)
• Identity verification documents
• Financial information
• Transaction history
• Device and usage information

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services
• Process transactions and send transaction notifications
• Verify your identity and prevent fraud
• Communicate with you about our services
• Comply with legal obligations

3. Information Sharing

We do not sell, trade, or otherwise transfer your personal information to third parties without your consent, except:

• To comply with laws, regulations, or legal requests
• To protect our rights, property, or safety
• With service providers who assist in our operations
• In connection with a merger or acquisition

4. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. This includes:

• 256-bit SSL encryption
• Secure data storage
• Regular security audits
• Employee training on data protection

5. Your Rights

You have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of your information
• Object to certain uses of your information
• Withdraw consent where applicable

6. Cookies and Tracking

We use cookies and similar tracking technologies to enhance your experience on our platform. You can control cookie settings through your browser preferences.

7. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

8. Contact Us

If you have questions about this Privacy Policy, please contact us at privacy@bitsmartpay.com or through our support channels.

Last updated: December 15, 2024

1. General Policy

Due to the nature of cryptocurrency transactions, all completed trades are final and cannot be reversed. However, we understand that issues may arise, and we're committed to resolving them fairly.

2. Eligible Refunds

Refunds may be considered in the following cases:

• Technical errors on our platform resulting in incorrect transactions
• Duplicate transactions caused by system errors
• Service outages preventing transaction completion
• Unauthorized transactions (subject to investigation)

3. Non-Refundable Situations

Refunds will NOT be provided for:

• Market price fluctuations
• User errors (wrong wallet address, incorrect amount)
• Completed transactions you later regret
• Violations of our Terms of Service
• External wallet or exchange issues

4. Refund Process

To request a refund:

1. Contact support within 24 hours of the transaction
2. Provide your transaction ID and detailed explanation
3. Include any supporting evidence (screenshots, etc.)
4. Cooperate with our investigation team

5. Processing Time

Refund requests are typically reviewed within 48 hours. If approved, refunds are processed within 3-5 business days. Complex cases may take longer.

6. Refund Method

Approved refunds will be credited to:

• Your Bitsmart Pay wallet (preferred)
• Original payment method (if applicable)
• Bank transfer (in special cases)

7. Dispute Resolution

If you disagree with our refund decision, you may appeal by providing additional information. Final decisions rest with our management team.

8. Contact Us

For refund requests, contact our support team at support@bitsmartpay.com or through our 24/7 live chat.

Last updated: December 15, 2024

1. Acceptance of Terms

By accessing and using Bitsmart Pay services, you accept and agree to be bound by the terms and provision of this agreement. If you do not agree to these terms, please do not use our services.

2. Eligibility

You must be at least 18 years old and have the legal capacity to enter into contracts. By using our services, you represent and warrant that you meet these eligibility requirements.

3. Account Registration

To use certain features of our services, you must register for an account. You agree to provide accurate, current, and complete information during registration and to update such information as necessary.

4. KYC and AML Compliance

We are required to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations. You agree to provide all requested documentation and information for verification purposes.

5. Trading Rules

When trading cryptocurrencies on our platform, you agree to:

• Trade only with funds that belong to you
• Not engage in market manipulation or fraudulent activities
• Accept the risks associated with cryptocurrency trading
• Comply with all applicable laws and regulations

6. Fees and Charges

We reserve the right to charge fees for our services. All applicable fees will be displayed before you confirm any transaction. Fees are subject to change with notice.

7. Prohibited Activities

You may not use our services for any illegal or unauthorized purpose, including but not limited to:

• Money laundering or terrorist financing
• Fraud or scam activities
• Violating any laws in your jurisdiction
• Hacking or attempting to gain unauthorized access

8. Limitation of Liability

To the maximum extent permitted by law, Bitsmart Pay shall not be liable for any indirect, incidental, special, consequential, or punitive damages resulting from your use of our services.

9. Changes to Terms

We reserve the right to modify these terms at any time. We will notify you of any changes by posting the new terms on our website. Your continued use of our services after such modifications constitutes acceptance of the updated terms.

10. Contact Information

If you have any questions about these Terms & Conditions, please contact us at legal@bitsmartpay.com.