Anti-Money Laundering Policy
Last updated: March 1, 2026
1. Purpose & Scope
Rita Africa maintains a comprehensive Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) program designed to prevent the use of our platform for money laundering, terrorist financing, proliferation financing, or other financial crimes. This policy applies to all Rita employees, contractors, agents, and users of our Services, and is implemented in accordance with the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, Central Bank of Nigeria (CBN) AML/CFT regulations, and applicable guidelines from the Nigeria Financial Intelligence Unit (NFIU).
2. Know Your Customer (KYC) Program
All users must complete identity verification before accessing financial services on the Rita platform. Our KYC program operates on a tiered basis: Tier 1 requires Bank Verification Number (BVN) validation and permits basic transaction limits. Tier 2 adds National Identification Number (NIN) verification and biometric selfie matching, enabling higher limits. Tier 3 requires proof of address documentation (utility bill, bank statement, or government-issued document dated within the last 3 months) for maximum transaction limits. Customer information is verified against government databases and independently validated before account activation at each tier.
3. Customer Due Diligence (CDD)
Rita conducts Customer Due Diligence at onboarding and on an ongoing basis throughout the customer relationship. Standard CDD includes verification of customer identity, assessment of the customer's risk profile, and understanding the nature and purpose of the business relationship. Enhanced Due Diligence (EDD) is applied to higher-risk customers, including Politically Exposed Persons (PEPs), customers from higher-risk jurisdictions, customers with unusual transaction patterns, and customers who exceed defined transaction thresholds. EDD measures include additional identity verification, source of funds documentation, and more frequent transaction monitoring.
4. Transaction Monitoring
Rita employs automated, real-time transaction monitoring systems to detect suspicious activity and unusual patterns across all Services. Our monitoring covers transaction amounts, frequency, velocity, geographic patterns, counterparty analysis, and behavioral anomalies. Alerts generated by our monitoring systems are reviewed by trained compliance analysts within prescribed timeframes. Transactions that cannot be satisfactorily explained may be delayed, blocked, or reported to the relevant authorities. Monitoring thresholds and rules are regularly updated to reflect emerging risks and regulatory guidance.
5. Suspicious Activity Reporting
Rita is committed to identifying and reporting suspicious transactions in accordance with Nigerian law. When suspicious activity is detected — whether through automated monitoring, employee observation, or customer complaints — it is escalated to the Chief Compliance Officer for assessment. Where there are reasonable grounds to suspect money laundering or terrorist financing, a Suspicious Transaction Report (STR) is filed with the Nigeria Financial Intelligence Unit (NFIU) within the required timeframe. Rita employees are prohibited from tipping off customers about STR filings or ongoing investigations. All STRs are treated with the highest level of confidentiality.
6. Sanctions Screening
Rita screens all customers and transactions against applicable sanctions lists, including the United Nations Security Council Consolidated Sanctions List, the OFAC Specially Designated Nationals (SDN) List, the EU Consolidated Sanctions List, and any sanctions lists published by the Nigerian government or CBN. Screening is performed at customer onboarding, periodically during the customer relationship, and in real-time for transactions involving cross-border transfers or cryptocurrency withdrawals. Matches or potential matches result in immediate transaction holds pending compliance review.
7. Record Keeping
Rita maintains comprehensive records of all customer identification documents, KYC verification results, transaction records, STRs, and compliance decisions for a minimum period of 5 years after the end of the customer relationship or 5 years after the date of the transaction, whichever is later, in accordance with the Money Laundering (Prevention and Prohibition) Act. Records are stored securely with appropriate access controls, encryption, and audit trails to ensure integrity, availability, and confidentiality.
8. Employee Training & Awareness
All Rita employees receive AML/CTF training upon hiring and at least annually thereafter. Training covers: the legal and regulatory framework for AML/CTF in Nigeria, recognizing and reporting suspicious activities, KYC procedures and customer due diligence, sanctions screening obligations, and the consequences of non-compliance. Employees in customer-facing, compliance, and engineering roles receive additional specialized training relevant to their responsibilities. Training records are maintained as part of our compliance documentation.
9. Risk Assessment
Rita conducts an enterprise-wide AML/CTF risk assessment at least annually, evaluating risks across customer types, products and services, delivery channels, and geographic exposure. The risk assessment informs our AML/CTF policies, procedures, monitoring thresholds, and resource allocation. Higher-risk areas — including cryptocurrency services, cross-border transfers, and high-value transactions — receive enhanced controls and more intensive monitoring. Risk assessment findings are reported to senior management and the board.
10. Compliance Governance
Rita's AML/CTF program is overseen by a designated Chief Compliance Officer (CCO) who reports directly to the board of directors. The CCO is responsible for the design, implementation, and ongoing effectiveness of the AML/CTF program, including policy development, monitoring, reporting, and regulatory liaison. Rita maintains an independent internal audit function that periodically reviews the AML/CTF program for effectiveness and compliance with regulatory requirements. Any deficiencies identified are remediated promptly, and material findings are reported to the board.
Compliance inquiries: support@rita.africa