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ParlyPay Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy

1. Introduction & Purpose

ParlyPay is committed to upholding the highest standards of integrity and transparency in all financial transactions. This Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) Policy outlines the principles, procedures, and controls implemented to prevent the misuse of ParlyPay’s services for money laundering, terrorist financing, sanctions evasion, or other illicit activities.

This policy also serves to protect ParlyPay from legal, regulatory, reputational, and financial risks, while shifting liability to users for unlawful activity that occurs despite our compliance and preventive measures.

Our Commitment

At ParlyPay, we are committed to preventing money laundering, terrorist financing, fraud, and other illegal financial activities.

This policy explains your obligations as a user and how ParlyPay protects the integrity of its platform. By using ParlyPay, you agree to comply with this AML/CTF policy at all times.

2. Scope & Applicability

This policy applies to:

  • All users (individuals, merchants, businesses, agents, API partners).
  • All employees, contractors, and affiliates of ParlyPay.
  • All ParlyPay services, including wallets, cross-border payments, virtual cards, escrow, API integrations, and settlements.

By using ParlyPay, all parties expressly agree to comply with this policy.

3. Regulatory Framework

ParlyPay operates under the following legal frameworks:

Nigeria

  • Central Bank of Nigeria (CBN) AML/CFT/CPF Regulations (2022).
  • Draft Baseline Standards for Automated AML Solutions (2025) – requiring AI-driven monitoring, BVN/NIN integration, automated reporting to NFIU, case management, sanctions screening, and encrypted data handling.
  • Nigerian Financial Intelligence Unit (NFIU) reporting obligations for Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs).

United States

  • Bank Secrecy Act (BSA).
  • Anti-Money Laundering Act of 2020.
  • FinCEN’s proposed modernization rule (2024) emphasizing risk-based AML programs.
  • Beneficial Ownership Information (BOI) reporting obligations (modified March 2025 – U.S. persons exempt, foreign entities still required).
  • OFAC Sanctions compliance and SDN list screening.
  • AML requirements for crypto service providers and FATF’s Travel Rule enforcement.

International

  • FATF Recommendations.
  • UN Conventions on AML/CFT.
  • EU 6th AML Directive (where applicable).

Know Your Customer (KYC) & Verification

To use ParlyPay services, you must:

  • Provide valid government-issued identification (e.g., passport, NIN, BVN, driver’s license).
  • Complete identity verification and, where applicable, biometric checks.
  • Provide proof of address (e.g., utility bill, bank statement).
  • Businesses must disclose ownership details, including Ultimate Beneficial Owners (UBOs).

4. Risk-Based Approach (RBA)

ParlyPay adopts a risk-based approach to AML/CFT:

  • Low-risk: Domestic transfers with fully verified users.
  • Medium-risk: SMEs, frequent cross-border transfers to stable jurisdictions.
  • High-risk: Politically Exposed Persons (PEPs), crypto-related activity, users in high-risk jurisdictions, complex layering patterns.

Enhanced Due Diligence (EDD) is applied to high-risk users and transactions.

Acceptable Use of ParlyPay

You agree NOT to use ParlyPay for:

  • Money laundering, terrorist financing, or fraud.
  • Transactions linked to sanctions-evaded countries, blacklisted persons, or illegal goods.
  • Concealing the source of funds or structuring transactions to avoid reporting thresholds.
  • Cryptocurrency, gambling, or high-risk activities without explicit approval.

5. Customer Due Diligence (CDD) & Know Your Customer (KYC)

For Individuals:

  • Government-issued ID (passport, NIN, BVN, driver’s license).
  • Facial recognition/biometric verification.
  • Proof of address (utility bill, bank statement).
  • Source of funds declaration.

For Businesses (KYB):

  • Certificate of incorporation, business license.
  • Tax Identification Number (TIN).
  • Beneficial Ownership disclosure (UBO ≥ 25%).
  • Cross-check with company registries and sanctions lists.

KYC/KYB is mandatory before account activation. Users with incomplete verification will be denied service.

User Responsibilities

As a user, you agree to:

  1. Ensure all funds sent or received through ParlyPay are from legitimate sources.
  2. Provide accurate information and keep your details updated.
  3. Cooperate with any AML/CFT checks, reviews, or investigations.
  4. Immediately report to ParlyPay if you suspect your account has been misused.

6. Transaction Monitoring & Sanctions Screening

ParlyPay uses AI/ML tools for real-time monitoring:

  • Detects structuring, layering, rapid movements of funds.
  • Screens transactions against OFAC, UN, Nigerian, EU, and international sanctions lists.
  • Suspicious activity is escalated to the MLRO.
  • High-value transactions automatically flagged for review.

Indemnity & Liability Disclaimer

  1. User Liability
    • You are fully responsible for the legality of all transactions conducted through your account.
  2. Indemnity
    • You agree to indemnify and hold harmless ParlyPay, its affiliates, officers, and employees from any claims, fines, penalties, damages, or expenses arising from your breach of this AML/CTF Policy or any misuse of the platform.
  3. Disclaimer
    • ParlyPay is not liable for losses caused by:
      • Freezing, blocking, or seizure of funds due to regulatory actions.
      • Delays or restrictions caused by compliance checks.
      • Indirect or unforeseen damages linked to user misconduct.

7. Reporting Obligations

  • Suspicious Transaction Reports (STRs): Filed with NFIU (Nigeria) or FinCEN (U.S.) within required timelines.
  • Currency Transaction Reports (CTRs): For transactions above threshold limits (e.g., ₦5 million for individuals, ₦10 million for corporates in Nigeria; $10,000 in the U.S.).
  • Terrorist Financing Reports (TFRs): For suspected terrorist financing activities.
  • Automated filing where possible to meet regulator deadlines.

Monitoring & Reporting

  • All transactions are monitored using AI and regulatory-compliant systems.
  • Suspicious activity may result in:
    • Account suspension or termination.
    • Reporting to regulators (CBN, NFIU, FinCEN, OFAC, etc.).
    • Freezing of funds pending investigation.
  • ParlyPay has a legal obligation to file reports and will not notify you if such reports are made.

8. Data Privacy & Record Keeping

  • KYC and transaction records retained for at least 5 years (Nigeria) and 5–10 years (U.S.).
  • Data protected under NDPR, GDPR, and U.S. privacy frameworks.
  • Encryption, multi-factor authentication, restricted access, and blockchain audit trails used to secure data.

Data Retention & Privacy

  • We keep your KYC and transaction data for a minimum of 5–10 years as required by law.
  • All data is secured under NDPR, GDPR, and international privacy standards.

10. Independent Audit & Review

  • Independent audits conducted annually.
  • AI/ML monitoring systems reviewed for accuracy, bias, and effectiveness.
  • Regular compliance reporting to management and regulators.

Right to Suspend or Terminate

ParlyPay reserves the right to:

  • Suspend, restrict, or terminate your account without notice if AML/CTF concerns arise.
  • Refuse transactions suspected to be unlawful.
  • Report suspicious transactions to regulators without your consent.

11. User Liability & Indemnity

To protect ParlyPay from known and unforeseen liabilities:

  1. User Responsibility
    • Users warrant that all funds transacted through ParlyPay are from lawful sources.
    • Users are prohibited from using ParlyPay for money laundering, terrorist financing, sanctions evasion, fraud, or any unlawful activity.
  2. Indemnity Clause
    • Users agree to indemnify and hold harmless ParlyPay, its affiliates, officers, and employees from any claims, fines, penalties, damages, or expenses arising from user misconduct.
  3. Disclaimer of Liability
    • ParlyPay is not liable for losses resulting from:
      • User violations of AML laws.
      • Frozen, seized, or confiscated funds by regulators.
      • Indirect, incidental, or unforeseen damage caused by user activity.
  4. Right to Suspend or Terminate
    • ParlyPay may suspend, freeze, or terminate any account or transaction without prior notice if suspicious activity is detected.

Governing Law & Compliance

  • Nigerian users: Must comply with CBN AML/CFT Regulations (2022) and upcoming AI-driven AML standards (2025).
  • U.S. users: Must comply with BSA, AMLA 2020, OFAC, and FinCEN rules.
  • International users: Must comply with FATF recommendations and local AML laws.

12. Escalation & Legal Cooperation

  • Internal escalation procedures for suspected cases.
  • Cooperation with law enforcement, regulators, and global AML networks.
  • Accounts may be frozen pending investigation.

13. Policy Review & Amendments

  • Reviewed annually or upon regulatory changes.
  • Updated to reflect evolving Nigerian (CBN/NFIU) and U.S. (FinCEN/OFAC) rules.
  • Users will be notified of significant amendments.

Updates to This Policy

  • ParlyPay may update this AML/CTF policy at any time in line with regulatory changes. Continued use of the platform constitutes acceptance of updates.

Conclusion

This policy ensures that ParlyPay remains compliant with Nigerian, U.S., and international AML/CFT laws while protecting the platform from liability. Users bear full responsibility for lawful use, and ParlyPay enforces rigorous monitoring, reporting, and preventive controls.

ParlyPay is built on trust. By using our services, you commit to lawful financial activity. Any breach of this AML/CTF Policy may lead to account suspension, legal action, reporting to regulators, and permanent ban from our platform.

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Incubated by FasterCapital

© MySparkLite LLC 2025. All rights reserved.

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Parlypay: A Product of MySparkLite LLC
Parlypay is a flagship product of MySparkLite LLC, a private limited company registered as a Limited Liability Company (LLC) in Wyoming, USA.

Parlypay operates as a cutting-edge cross-border payment solution that empowers businesses to collect payments, manage recurring transactions, and process international money transfers. It is designed to deliver seamless and secure payment experiences for merchants and individuals engage in remote gig worldwide.

Disclaimer
Parlypay’s services are exclusively available to eligible corporate customers and users involved in legitimate gig jobs across borders. These services are governed by local and international regulations, and users must adhere to the eligibility criteria specified by MySparkLite LLC.

It is important to note that MySparkLite LLC is a technology company and not a bank. Banking services for Parlypay are provided through partnerships with licensed financial institutions.

Payment services for Parlypay are powered by payment processor technology. Stripe is one of the providers our payment processing, registered as a licensed money transmitter in various jurisdictions, ensuring compliance with local and international financial regulations. Their infrastructure supports Parlypay’s secure and seamless transactions across multiple currencies and countries.

An open banking platform provides the underlying technology for Parlypay’s account verification and secure financial data integration. As a trusted platform for open banking, Plaid ensures that users have a streamlined experience while connecting their bank accounts to Parlypay. Plaid complies with global data protection standards to safeguard users’ financial information.

Payment gateways in Africa: Paystack powers Parlypay’s infrastructure, leveraging its expertise in processing secure and efficient transactions in local currencies. As a licensed payment service provider regulated by the Central Bank of Nigeria (CBN), Paystack ensures compliance with regional regulatory requirements while enabling seamless payment collection for businesses.