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KYC Policy

Last updated: 10/30/2025

Introduction

Zerocard is a fintech company that issues crypto payment cards designed to facilitate seamless everyday transactions. The platform enables users to store stablecoins, such as USDC, within their digital wallets and utilize them for payments and withdrawals in the same manner as conventional currency.

This Know Your Customer (KYC) Policy serves as the foundation of Zerocard's AML/CFT/CPF compliance framework, establishing the standards and procedures for verifying the identity of users and ensuring compliance with all applicable laws and regulations in Nigeria and other jurisdictions.

Purpose and Scope

The policy is designed to help Zerocard identify and verify its users, perform due diligence checks, and prevent money laundering, terrorism financing, and other illegal financial activities.

Before processing any transaction, the company must verify each user's identity and source of funds. If a new user fails or refuses to provide required information, their transactions must not be processed, and if they are existing customers, their accounts should be suspended or terminated.

Guiding Principles

This policy is developed in line with:

  • The Central Bank of Nigeria (CBN) Anti-Money Laundering/Combating the Financing of Terrorism/Countering Proliferation Financing of Weapons of Mass Destruction in Financial Institutions CBN(AML/CFT/CPF) Regulations of 2022
  • The Money Laundering (Prevention and Prohibition) Act, 2022
  • The Terrorism (Prevention) Act, 2022 (as amended)
  • Securities and Exchange Commission (SEC) rules on digital assets
  • Nigeria Data Protection Act (NDPA) 2023
  • The 40 Recommendations issued by the Financial Action Task Force (FATF)

Customer Identification Requirements

Each new user must be at least 18 years old and provide applicable onboarding information, which is subject to verification through electronic means or supporting documentation.

Basic information collection: Zerocard mandatorily collects the following information from users:

  • Full legal name (as per government ID)
  • Date of birth
  • Phone Number
  • Email
  • Residential address and proof (utility bill not later than 3 months)
  • Nationality
  • National Identity Number (NIN)
  • Bank Verification Number (BVN)
  • Biometric verification (liveness check)

Valid Identification Documents

Means of identification allowed includes any of the following valid documents:

  • Valid International Passport
  • Valid Driver's License
  • National Identity Card
  • Any other document approved by the regulators from time to time

Risk Categorization

Zerocard adopts a risk-based approach to Money Laundering (ML) and Terrorism Financing (TF) in line with regulatory best practices. Users are classified into the following risk categories:

  • High Risk: Non-resident users, Politically and Financially exposed persons (PEPs & FEPs), those adjudged fraudulent by competent courts, users whose source of wealth cannot be reasonably established
  • Medium Risk: Government Ministries and Parastatals/Enterprises, Other Public Sector Accounts
  • Low Risk: Public corporations, financial institutions and other self-regulatory institutions

Politically Exposed Persons (PEPs)

PEPs are individuals who are or have been entrusted with prominent public functions in Nigeria and/or foreign countries and people/entities associated with them. This includes political office holders and senior government functionaries.

PEPs and FEPs are subject to enhanced due diligence measures, including senior management approval and continuous monitoring of their accounts and transactions.

KYC Re-certification

Zerocard performs ongoing monitoring through periodic and trigger event reviews. The frequency of a user's periodic review is determined by their risk rating:

  • Low Risk: 5 years
  • Medium Risk: 3 years
  • High Risk: 1 year

Sanction Screening

In compliance with applicable regulations, Zerocard maintains strict procedures to prevent engagement with individuals subject to financial sanctions. The company shall not open accounts for, or conduct transactions with, any individual identified on any national or international sanctions list.

Data Protection and Record Keeping

All personal information collected for KYC purposes is protected in accordance with our Privacy Policy and applicable data protection laws, including the Nigeria Data Protection Act (NDPA) 2023.

Records are maintained for a minimum of 5 years after the closure of accounts or cessation of business relationships, in compliance with the Money Laundering (Prevention and Prohibition) Act, 2022.

Contact Us

If you have any questions about our KYC requirements, please contact us at support@getzerocard.xyz.