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IDERA TECH LTD (MYVER/FLUR)

Compliance & AML Policy

A transparent overview of how IDERA TECH LTD adheres to CBN regulations, global AML standards, and best practices to ensure a secure financial ecosystem for all Flur users.

Scope: All users, staff & partners
Last updated: 30 December 2025
1

Purpose & Scope

This policy establishes the minimum standards for IDERA TECH LTD's compliance with applicable laws. It is binding on all stakeholders to ensure we operate with integrity and prevent financial crime.

WHO IT APPLIES TO

Directors & Board Members
All Employees & Contractors
Agents, Partners & Third Parties

VIOLATIONS

Disciplinary actions including termination
Reporting to law enforcement
Personal legal liability
Applies across: Flur app, Flur Shop, POS, APIs, and back-office tools.
2

Regulatory Framework

CBN & Payments

  • CBN Act 2007
  • BOFIA 2020
  • Guidelines on Mobile Money Services
  • Regulation on Electronic Payments

AML & Financial Crime

  • Money Laundering (Prevention & Prohibition) Act 2022
  • Terrorism (Prevention & Prohibition) Act 2022
  • NFIU & EFCC Regulations

Data & Others

  • Nigeria Data Protection Act (NDPA) 2023
  • Cybercrime Act 2015
  • FCCPC Act 2018
3

KYC & Due Diligence

Tiered KYC Model

TIER 1

Phone number & basic details. Limited transaction caps.

Basic
TIER 2

BVN verification & ID. Intermediate limits.

Standard
TIER 3

Full docs, utility bill. Highest limits.

Enhanced

Enhanced Due Diligence (EDD)

TRIGGERS & MEASURES

Politically Exposed Persons (PEPs) screening
High-risk geographies or industries
Source of funds verification required
Manual senior management approval

Ongoing Monitoring

CORE MONITORING ELEMENTS

Periodic KYC data refresh
Daily sanctions list screening
Real-time transaction analysis
Re-verification upon major profile changes

AML/CFT Program

Program Components

Risk-Based Approach (RBA) assessing customer, product, and geographical risks.
Automated transaction monitoring systems.
Regular staff training on identifying financial crime patterns.

Suspicious Activity Reporting

Monitoring for structuring (smurfing) and unusual volumes.
Immediate SAR/STR filings to the NFIU upon suspicion.
Strict record retention (5+ years) for all investigations.
5

Consumer Protection

Transparency

Clear disclosure of all fees and terms in plain language. Immediate transaction receipts and accessible statements.

Fair Treatment

Non-discriminatory access to services. Specialized support for vulnerable users and multilingual assistance.

Dispute Resolution

Accessible complaint channels with strict investigation timelines. Escalation paths to CBN Consumer Protection Department.

Data Protection & Cybersecurity

Compliance

Adherence to NDPA 2023 & NDPR. Appointed Data Protection Officer (DPO) and regular DPIAs.

Incident Response

Documented plan for breaches including mandatory notification to NDPC and affected users within 72 hours.

InfoSec

ISO 27001 aligned ISMS. Regular penetration testing, encryption of data/transit, and MFA enforcement.

Third-Party Risk

01Due Diligence

Risk assessment & license review before onboarding.

02Contracts

Strict data protection & audit right clauses.

03Oversight

Ongoing performance & compliance monitoring.

Training & Awareness

Mandatory onboarding training for all staff
Annual AML/CFT & Data Privacy refreshers
Role-specific deep dives for ops/compliance teams

Governance & Accountability

Compliance Function

Led by a Chief Compliance Officer (CCO) with an independent reporting line to the Board of Directors.

Whistleblowing

Confidential channels for reporting misconduct with guaranteed non-retaliation protection.

Reporting & Cooperation

We maintain transparent relationships with:

CBNNFIUEFCCSCUMLNBPC

Submitting all required monthly, quarterly, and annual returns on time.

Policy Review

This policy is reviewed annually or upon significant changes in regulations or business operations.

Latest approval by Board of Directors

Contact Us

CHIEF COMPLIANCE OFFICER

cco@flur.com

GENERAL COMPLIANCE INQUIRIES

compliance@flur.com

DATA PROTECTION OFFICER

dpo@flur.com

Whistleblowing

Hotline: +234 (0) 123 456 7890

Email: whistleblow@flur.com

OFFICE ADDRESS

IDERA TECH LTD (Myver)

12, Innovation Drive, Lekki Phase 1, Lagos, Nigeria.