Legal

Anti-Money-Laundering Policy

Last updated · 5 July 2026

HarePay is committed to preventing money laundering, terrorist financing and sanctions evasion. This summary describes the controls we operate and what we expect of merchants.

Our programme

We maintain a risk-based AML/CFT programme aligned with the Central Bank of Nigeria's regulations and applicable law in each market. It is overseen by a designated compliance officer and reviewed regularly.

Know-Your-Business (KYB)

  • We verify the identity of every merchant, its beneficial owners and its directors before enabling live processing.
  • We screen merchants and their principals against sanctions, PEP and adverse-media lists at onboarding and on an ongoing basis.
  • We apply enhanced due diligence to higher-risk businesses and may request source-of-funds or additional documentation.

Transaction monitoring

We monitor transactions for patterns that may indicate money laundering, fraud or sanctions breaches — including structuring, unusual velocity, and payments to or from restricted jurisdictions. Alerts are reviewed by our compliance team.

Sanctions

We screen counterparties against applicable sanctions lists and block or reject transactions involving sanctioned persons, entities or jurisdictions. Attempting to evade sanctions through HarePay is strictly prohibited.

Reporting

Where we identify suspicious activity, we file the required reports with the relevant Financial Intelligence Unit and cooperate with law enforcement. We may be legally prohibited from telling you that a report has been made.

Merchant obligations

Merchants must not use HarePay to launder proceeds of crime, finance terrorism, or evade sanctions, and must respond promptly to compliance requests. Breach may result in immediate suspension and reporting. Questions: compliance@harepay.click.

Questions about this document? Email legal@harepay.click. This page is a plain-language summary provided for convenience and does not replace the signed agreements that govern your HarePay account.