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Anti-Money Laundering (AML) Policy

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1. Introduction

Cubithost is committed to preventing money laundering and terrorist financing activities in accordance with the Nigerian Money Laundering (Prohibition) Act 2011 (NML Act) and the Regulations of the Special Control Unit Against Money Laundering (SCUML). This Anti-Money Laundering (AML) Policy outlines the measures we take to identify, mitigate, and report suspicious activity.

2. Customer Due Diligence (CDD) in accordance with SCUML Regulations

Cubithost will perform Customer Due Diligence (CDD) on all customers as mandated by SCUML. This includes:

  • Identifying and verifying customer identities: We will collect and verify your identity documents following the SCUML requirements. This may include a government-issued photo ID (e.g., National ID card, International Passport) and proof of address (e.g., utility bill, bank statement). For businesses, we will require incorporation documents and beneficial ownership information.

  • Understanding the nature and purpose of customer relationships: We will ask you about your intended use of our web hosting and domain registrar services and the source of your funds. This helps us understand your business model and risk profile.

  • Ongoing monitoring of customer activity: We will monitor your account activity for transactions that are inconsistent with your declared business or personal needs. This includes monitoring for unusually high volumes of transactions or transactions originating from high-risk countries or entities.

3. Suspicious Activity Monitoring as per SCUML Guidelines

Cubithost monitors customer activity for signs of suspicious activity that may be indicative of money laundering or terrorist financing as outlined by SCUML. This includes, but is not limited to:

  • Transactions that are inconsistent with your stated business or personal needs, such as a sudden surge in activity or transactions involving large sums of money with no apparent purpose.

  • Transactions involving high-risk countries or entities identified by SCUML.

  • Transactions that are structured to avoid triggering reporting thresholds, such as splitting transactions into smaller amounts to stay below reporting limits.

  • Use of our services for illegal activities such as phishing, spamming, or malware distribution.

4. Reporting to SCUML as Required by Law

If Cubithost suspects that a customer is engaged in money laundering or terrorist financing activities, we are required by law to report the activity to SCUML. We will also file a Suspicious Activity Report (SAR) with the Nigerian Financial Intelligence Unit (NFIU). Additionally, we may block or terminate the customer’s account to prevent further suspicious activity.

5. Communication and Staff Training

Cubithost will clearly communicate this AML Policy to all customers through our website, terms of service, and during account signup. We will also provide ongoing training to our staff on how to identify and report suspicious activity according to SCUML guidelines. This ensures our staff is equipped to effectively implement this AML Policy.

6. Regular Review and Updates

Cubithost will review this AML Policy on a regular basis to ensure that it remains effective and compliant with any changes in Nigerian AML legislation or SCUML regulations.

7. Additional Measures to Mitigate Risk

Cubithost may implement additional measures to comply with AML regulations and mitigate risk, such as:

  • Enhanced due diligence (EDD) for high-risk customers: This may involve obtaining additional identification documents, proof of business activities, and source of wealth verification for customers deemed high-risk based on SCUML guidelines.

  • Geographical restrictions on services: Cubithost may restrict services to customers in countries identified by SCUML as high-risk for money laundering or terrorist financing.

  • Transaction monitoring for specific types of activity: We may implement transaction monitoring systems to identify suspicious activity patterns specific to the web hosting and domain registrar industry.

8. Your Obligations as a Customer

By using Cubithost’s services, you agree to comply with this AML Policy and all applicable Nigerian laws and regulations. You are obligated to:

  • Provide us with accurate and up-to-date information about yourself or your business.

  • Report any suspicious activity on your account to Cubithost immediately.

  • Cooperate with us in the event that we need to perform enhanced due diligence or request additional information.