Myver Compliance Policy

The purpose of this Policy is to:

• Ensure Myver operates in compliance with the Central Bank of Nigeria (CBN) guidelines, Nigeria Data Protection Regulation (NDPR), Nigeria Data Protection Act (NDPA), and other applicable laws.
• Establish internal systems for monitoring, detecting, and preventing financial crime.
• Protect Myver's users, partners, and stakeholders from fraud, money laundering, and misuse of financial services.
• Promote ethical business practices and regulatory transparency.

This Policy applies to:

• All employees, contractors, officers, and directors of Myver.
• All users of Myver's Services.
• All merchants, agents, and third-party partners engaged with Myver.

Myver complies with:

• Central Bank of Nigeria (CBN) Guidelines on Electronic Payments, Mobile Money Operations, and Payment Service Providers.
• Anti-Money Laundering (AML) Act 2022 and Terrorism (Prevention and Prohibition) Act 2022.
• Nigeria Data Protection Regulation (NDPR) & Nigeria Data Protection Act (NDPA).
• Proceeds of Crime (Recovery and Management) Act 2022.
• Card network rules (Visa, Mastercard, Verve).
• Compliance requirements of partner institutions:
  • Xpress Wallet & Providus Bank (wallet operations).
  • VFD Microfinance Bank (savings, fixed deposits, POS).
  • Paystack (card processing).

• Board of Directors: Provides oversight of compliance risk management.
• Chief Compliance Officer (CCO): Responsible for implementing compliance programs and reporting to regulators.
• Compliance Team: Monitors daily compliance, conducts investigations, and ensures internal training.
• All Employees: Required to understand and adhere to compliance obligations.

• Users must undergo KYC verification before accessing certain Services.
• KYC levels determine transaction and balance limits, in line with CBN guidelines.
• Acceptable KYC documents include BVN, NIN, government-issued IDs, and proof of address.
• Enhanced Due Diligence (EDD) applies to high-risk users, merchants, or transactions.

Myver maintains an AML/CFT program consistent with CBN and global standards:

• Customer Due Diligence (CDD): Verifying user identities and beneficial ownership.
• Transaction Monitoring: Detecting unusual, suspicious, or structured transactions.
• Suspicious Transaction Reporting (STR): Filing reports with the Nigerian Financial Intelligence Unit (NFIU).
• Sanctions Screening: Screening against OFAC, UN, EU, and local sanctions lists.
• Record Keeping: Maintaining KYC and transaction records for at least 5 years.

• Myver processes personal data in compliance with NDPR and NDPA.
• Data is collected only for lawful, specific purposes and processed fairly and transparently.
• User consent is required for sensitive data (e.g., biometrics).
• Cross-border transfers comply with NDPR/GDPR safeguards.
• Full details are outlined in Myver's Privacy Policy.

• All merchants and agents must pass due diligence checks before onboarding.
• Merchants engaging in prohibited activities (see Prohibited Merchants & Activities List) will not be onboarded.
• Ongoing monitoring will be conducted to detect fraud, suspicious activity, or regulatory breaches.
• Myver reserves the right to suspend or terminate merchant/agent accounts for compliance violations.

• Mandatory compliance training for all employees on AML/CFT, KYC, data protection, and ethics.
• Annual refresher training and testing to maintain compliance awareness.
• Specialized training for high-risk functions (compliance officers, risk analysts, merchant onboarding staff).

• Myver encourages employees, partners, and customers to report suspected violations confidentially.
• Reports may be made via email or hotline to the Compliance Officer.
• Whistleblowers are protected against retaliation.

• Regular compliance audits will be conducted internally and externally.
• Independent reviews may be conducted by regulators, auditors, or partners.
• Identified gaps will be addressed promptly with corrective action plans.

• Violations of this Policy may result in disciplinary action, including termination of employment, suspension of accounts, or termination of contracts.
• Where required, violations will be reported to regulatory authorities and law enforcement.

• This Policy will be reviewed at least annually to ensure continued compliance with laws, regulations, and partner requirements.
• Updates will be communicated to employees, partners, and users where relevant.