This statement summarises how Flippr approaches anti money laundering and counter terrorist financing, and what we ask of our customers. It is a summary for customers and partners. Our full internal policies are more detailed and are available to regulators and partners on request.
Operator: Engagoor Limited (RC 9520908)
Registered address: 39C, Road 27, Ikota Villa Estate, Ikota, Lagos State, Nigeria
Contact: hello@engagoor.xyz
1. Our commitment
Engagoor Limited operates Flippr in line with Nigerian anti money laundering and counter terrorist financing requirements, including the Money Laundering (Prevention and Prohibition) Act 2022 and the Terrorism (Prevention and Prohibition) Act 2022. We do not knowingly do business with anyone who uses our service to launder money, finance terrorism, evade sanctions, or handle the proceeds of crime.
2. Customer due diligence
Every customer is verified before they can transact. Our checks include:
- confirming full name, date of birth and residential address;
- verifying a government identifier such as BVN or NIN;
- checking a government-issued identity document;
- a liveness and face match check confirming the customer is the person on the document; and
- confirming that the payout bank account belongs to the verified customer.
We do not permit anonymous accounts, accounts in false names, or accounts operated for an undisclosed third party.
3. Screening
Customers are screened against sanctions lists, politically exposed person lists and adverse media at onboarding, and are rescreened on an ongoing basis. A positive match is reviewed before any relationship continues.
4. Enhanced due diligence
Where a customer or transaction presents higher risk, we apply additional measures before proceeding. These may include establishing the source of funds or wealth, requesting supporting documents, applying lower limits, and senior approval of the relationship. Higher risk includes politically exposed persons, unusual transaction patterns, and connections to higher risk jurisdictions.
5. Ongoing monitoring
We monitor transactions for patterns that do not fit what we know about a customer, including unusual size or frequency, structuring to stay under thresholds, and rapid movement of funds. We also screen blockchain addresses for links to known illicit activity. We may pause a transaction or an account while we review it.
6. Reporting
Where we know or suspect that funds are the proceeds of crime or relate to terrorist financing, we report to the Nigerian Financial Intelligence Unit as required by law. We also file the currency and transaction reports the law requires. We do not tip off customers about reports, because the law prohibits it.
7. Record keeping
We keep identification records, verification evidence and transaction records for at least five years after the end of the customer relationship or the date of the transaction, whichever is later, and longer where an authority requires it.
8. Customers we will not accept
- anyone under 18;
- anyone we cannot identify and verify to our satisfaction;
- anyone on an applicable sanctions list, or acting for a sanctioned party;
- anyone transacting on behalf of an undisclosed third party; and
- anyone we reasonably believe is using the service for unlawful purposes.
9. Governance and training
Responsibility for compliance sits with the company's management, which reviews these controls and approves changes. Staff who deal with customers or transactions receive anti money laundering training before they start and refresher training thereafter, and training is recorded.
10. Contact
Compliance queries, information requests from authorities, and reports of suspicious activity involving Flippr can be sent to hello@engagoor.xyz, addressed to the compliance contact at Engagoor Limited, 39C, Road 27, Ikota Villa Estate, Ikota, Lagos State, Nigeria.