Entity: Kalt Technologies Limited (trading as MyKalt)
Introduction
MyKalt is committed to protecting its customers and services from misuse for money laundering, terrorist financing, proliferation financing, fraud and other unlawful activity. This policy explains our public-facing approach to financial-crime compliance and the actions we may take when activity requires review.
We use a risk-based approach to our compliance responsibilities. To protect customers and the integrity of our programme, confidential compliance and security procedures are not published.
Purpose and scope
This policy applies to MyKalt services, customer relationships, transactions, relevant personnel and service providers involved in delivering those services. Its purpose is to support the prevention, detection, assessment and escalation of financial-crime risks, while treating customers fairly and protecting their personal information.
MyKalt may request information, delay or decline an instruction, place a transaction under review, limit or suspend access to a service, preserve records, or cooperate with competent authorities where required by law, risk assessment, service-provider requirements or operational necessity.
Legal and regulatory framework
Our policy is designed to support compliance with applicable Nigerian law and regulatory requirements, including the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022 and the Nigeria Data Protection Act 2023. Relevant FATF standards also inform our risk-based approach.
This policy is not legal advice and does not state or imply that MyKalt holds a licence, registration, approval or reporting status unless MyKalt expressly publishes that status. Legal and regulatory requirements may change, and this policy will be reviewed accordingly.
Risk-based approach
We assess financial-crime risk using factors that may include the nature of the customer relationship, products and services used, transaction characteristics, delivery channel, geographic exposure and information available during the relationship. The steps taken may vary according to the level and nature of risk identified.
Our risk-based approach may result in different verification requirements, additional questions, enhanced review, transaction restrictions or other proportionate measures. Confidential decision-making procedures are not published.
Customer due diligence
Customer identification and verification are important elements of our AML, CFT and CPF programme. We may conduct customer due diligence when establishing or maintaining a relationship, when a transaction or activity requires review, or in other circumstances required by law or our procedures. More information is available in our KYC and Customer Due Diligence Policy.
Where higher risk is identified, we may request additional information relating to the customer, beneficial ownership, source of funds, source of wealth, purpose of activity or other relevant matters. If required information is not provided or cannot be satisfactorily verified, we may decline, delay, restrict or end the relevant relationship or service, subject to applicable law.
Monitoring and escalation
We may review activity to identify behaviour or transactions that warrant further assessment. Examples may include activity that appears unusual, inconsistent with information provided, rapidly changing, potentially fraudulent, linked to high-risk circumstances, or otherwise indicative of possible financial crime. Examples are illustrative and do not describe all matters that may require review.
Matters requiring review may be escalated to appropriate compliance personnel. MyKalt may take protective or restrictive measures while an assessment is ongoing. Where required, suspected activity may be handled and reported through the appropriate lawful channels. We do not disclose whether a review, report or request from an authority exists, except where disclosure is permitted or required by law.
Sanctions and higher-risk activity
MyKalt seeks to comply with applicable targeted financial-sanctions obligations and to consider risks relating to politically exposed persons, higher-risk jurisdictions, unusual ownership or control, and suspicious activity. We may request additional information, apply enhanced review or restrict a service where a sanctions, financial-crime or other material risk concern arises.
Confidential compliance procedures are managed through internal policies and are subject to legal, regulatory and operational review. We do not disclose information that could compromise customer security or the effectiveness of those procedures.
Records and confidentiality
We retain relevant information and records for as long as necessary to support our services, security, risk management, audit, dispute resolution and applicable legal or regulatory obligations. Information is handled in accordance with applicable confidentiality and data-protection obligations. For details of our approach to personal data, please read our Privacy Policy.
Customers and third parties must not be informed about a suspicious-activity review or report where doing so would be prohibited by law or could compromise an assessment, investigation or lawful request.
Governance and updates
MyKalt maintains policies, procedures, training, oversight and review arrangements appropriate to its business and applicable obligations. We may revise this policy to reflect changes in our services, risk profile, law or regulatory expectations. The latest version will be published on this page.
For general questions about this policy, contact [email protected]. We cannot provide legal advice or disclose internal compliance reviews, customer information or confidential security arrangements.