Know Your Customer (KYC) Policy
Identity Verification Standards, Biometric Validation & Compliance Safeguards
1.0 Purpose
This Know Your Customer (“KYC”) Policy details the mandatory standards for verifying identity, validating customer credentials, and establishing beneficial ownership across KudiLink Financial Services Limited (“KudiLink”).
The primary purpose of this policy is to prevent money laundering, terrorist financing, proliferation financing, identity fraud, and credit misrepresentation, while remaining fully compliant with Central Bank of Nigeria (CBN) regulations and Nigerian statutory laws.
2.0 Mandatory KYC Documentation Requirements
2.1 Individual Borrowers & Applicants
- Full Legal Name: As registered on official government identification.
- Date of Birth & Gender: Verified against national population databases.
- Residential Address: Verifiable physical location with utility bill or proof of residence.
- Government-Issued ID: Bank Verification Number (BVN), National Identification Number (NIN), International Passport, Driver's Licence, or Permanent Voter's Card (PVC).
- Contact Credentials: Verified active mobile phone number and personal e-mail address.
- Biometric Verification: Real-time selfie image with liveness detection matching official ID photographs.
- Proof of Income / Address: Recent bank account statement (minimum 3–6 months) or recent utility bill (water/electricity/waste).
2.2 Corporate & Business Entities
- CAC Documents: Certificate of Incorporation, Status Report (BN / LLC registration form), and Memorandum & Articles of Association (MEMART).
- Tax Identification Number (TIN): Verified with the Federal Inland Revenue Service (FIRS).
- Board Resolution: Official board resolution authorizing account opening and designated signatories.
- Director & Officer Profiles: Full identity credentials and verified IDs for all company directors.
- Beneficial Ownership Declaration: Disclosure of ultimate natural persons holding 5% or more equity/voting rights.
- Signatory Identification: Valid government ID, NIN, and BVN for all authorized signatories.
- Proof of Business Operating Address: Physical inspection or utility bill for business premises.
3.0 Identity Verification Standards
Verification must be completed before account activation or credit disbursement using official, direct database channels:
- Government Database Query: Direct automated validation of BVN via NIBSS and NIN via NIMC API integrations.
- Liveness & Facial Matching: Biometric facial recognition algorithms to prevent spoofing, deepfakes, or impersonation.
- Address Verification: Physical site visit or automated digital geolocation and utility validation.
- Beneficial Ownership Verification: Verification of ownership chains up to the ultimate natural person.
- Sanctions & Watchlist Screening: Automated real-time cross-referencing against UN, OFAC, CBN, and NFIU lists.
- Adverse Media Checks: Screening for news or judicial records involving financial crimes.
4.0 Ongoing KYC Maintenance
KYC is not a one-time event but a continuous process throughout the relationship tenure:
- Continuous Monitoring: Real-time monitoring of transactions against customer profile metrics.
- Periodic Refresh: Updating identity documents and contact details according to risk tiering.
- Trigger-Based Refresh: Mandatory re-verification upon change of address, legal name change, change in corporate ownership structure, or unusual transaction velocity.
5.0 Simplified Due Diligence (SDD)
SDD may be applied exclusively to low-risk individual applicants accessing low-value, micro-credit tiers in strict accordance with CBN tiering guidelines. SDD requires basic BVN/NIN validation and mobile number verification.
6.0 Enhanced Due Diligence (EDD)
EDD is mandatory for high-risk profiles, PEPs, corporate accounts, and high-value credit applications. EDD requires:
- Comprehensive verification of source of funds and overall net worth / wealth.
- Written sign-off from Chief Compliance Officer / Senior Management.
- Enhanced post-disbursement transaction monitoring.
7.0 Sanctions Screening & PEP Checks
All individual and corporate applicants, including ultimate beneficial owners and key officers, are screened against global sanctions databases at onboarding and continuously on a daily basis. Any positive match triggers an immediate hold and notification to the Compliance Department.
8.0 Record Keeping Obligations
All KYC documentation, biometric logs, verification reports, and communication records are encrypted and retained for a minimum period of five (5) years following the end of the customer relationship, in full compliance with CBN AML regulations and the NDPA.
9.0 Roles & Responsibilities
| Department | Primary KYC Responsibility |
|---|---|
| Compliance Department | Policy oversight, EDD approvals, high-risk reviews, and regulatory liaison |
| Operations & Credit | Daily execution of customer onboarding, document collection, and verification |
| Technology Team | Maintenance of automated verification APIs, biometric tools, and encrypted record storage |
| Internal Audit | Independent testing and auditing of KYC procedures and effectiveness |
10.0 Policy Review & Updates
This KYC Policy is formally reviewed on an annual basis or immediately upon the enactment of new Central Bank of Nigeria guidelines, NFIU directives, or data protection laws.
11.0 Policy Inquiries
If you have questions regarding our KYC requirements or verification procedures, please contact our Legal & Compliance team:
KudiLink Financial Services Limited — Compliance Department
E-mail: kyc@kudiloans.com | compliance@kudiloans.com
Address: Propertygate Centre (3rd Floor), 2 The Rock Drive, Lekki Phase 1, Lagos State, Nigeria.