Customer Acceptance Policy
Onboarding Criteria, Risk Categorization & Compliance Standards
1.0 Purpose
This Customer Acceptance Policy defines the precise criteria, risk evaluation parameters, and compliance standards for onboarding customers into KudiLink Financial Services Limited (“KudiLink”)'s digital lending ecosystem.
Our objective is to ensure that customer relationships strictly align with Nigerian regulatory requirements, CBN directives, NFIU rules, and KudiLink's institutional risk appetite.
2.0 Customer Categories
2.1 Acceptable Customers
Subject to successful completion of standard KYC checks, KudiLink accepts:
- Individual applicants holding valid, verifiable government-issued identification (NIN, BVN, Driver's License, International Passport, Voter's Card).
- Registered corporate entities (LLCs, Enterprises) with verifiable Corporate Affairs Commission (CAC) documentation and identifiable ultimate beneficial owners.
- Non-Governmental Organizations (NGOs) and Incorporated Trustees with complete, verified regulatory filings and board resolutions.
2.2 High-Risk Customers (Enhanced Due Diligence Required)
Applicants falling under high-risk parameters require mandatory Enhanced Due Diligence (EDD) and Senior Management / Compliance approval prior to onboarding:
- Politically Exposed Persons (PEPs), their family members, and close business associates.
- Non-resident individuals or foreign corporate entities.
- Businesses operating in high-risk sectors (crypto-assets, gaming/casinos, arms manufacturing, foreign exchange trading/bureau de change).
- Customers originating from or connected to FATF high-risk or monitored jurisdictions.
- Cash-intensive business models.
- Complex or multi-layered corporate ownership structures.
2.3 Prohibited Customers
Strict Non-Onboarding Policy: KudiLink will under no circumstances open accounts or disburse credit facilities to any entity or individual within prohibited categories.
- Shell companies or banks with no physical office presence or operations.
- Anonymous, alias, or fictitious account names.
- Sanctioned individuals or entities listed on UN, OFAC, EU, UK, CBN, or NFIU watchlists.
- Designated terrorist organizations, syndicate affiliates, or criminal entities.
- Unlicensed Money Service Businesses (MSBs) or unregulated financial intermediaries.
- Applicants who refuse, fail, or omit to provide mandatory KYC identification data.
- Entities involved in arms proliferation, weapons trade, or nuclear-related activities.
3.0 Customer Acceptance Requirements
Before any credit line or account access is granted, the following mandatory steps must be executed:
- Complete digital KYC submission via the KudiLoans platform.
- Automated real-time verification of identity credentials (BVN / NIN) and residential/business address.
- Full disclosure and verification of ultimate beneficial ownership (for corporate accounts).
- Risk assessment scoring against internal AML risk matrix.
- Real-time screening against global sanctions, PEP databases, and adverse media.
- Formal written sign-off from the Compliance Department for all High-Risk category applications.
4.0 Customer Risk Rating Matrix
Every onboarded customer is assigned a dynamic risk rating that governs ongoing transaction limits and document refresh schedules:
| Risk Rating | Description | Due Diligence Level |
|---|---|---|
| Low Risk | Standard salaried individuals, verifiable employment, clear credit history | Simplified / Standard CDD |
| Medium Risk | Self-employed individuals, SMEs with standard trading history | Standard CDD + Periodic Review |
| High Risk | PEPs, high-value borrowers, complex businesses, high-risk sectors | Mandatory EDD + Senior Approval |
| Prohibited | Sanctioned entities, shell companies, unverified profiles | Immediate Rejection / Block |
5.0 Review & Re-Certification Cycles
Customer profiles and risk classifications are continuously maintained and re-certified according to the following mandatory timeline:
- High-Risk Customers: Mandatory annual review (every 12 months).
- Medium-Risk Customers: Re-certification every 2 years (24 months).
- Low-Risk Customers: Re-certification every 3 years (36 months).
- Trigger-Based Review: Immediate re-assessment upon trigger events, including unusual transaction activity, material change in ownership, PEP status updates, or adverse media reports.
6.0 Policy Inquiries
For questions regarding customer acceptance criteria, risk classifications, or onboarding compliance, please contact:
KudiLink Financial Services Limited — Onboarding & Legal
E-mail: onboarding@kudiloans.com | legal@kudiloans.com
Address: Propertygate Centre (3rd Floor), 2 The Rock Drive, Lekki Phase 1, Lagos State, Nigeria.