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.
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
VIOLATIONS
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
KYC & Due Diligence
Tiered KYC Model
Phone number & basic details. Limited transaction caps.
BVN verification & ID. Intermediate limits.
Full docs, utility bill. Highest limits.
Enhanced Due Diligence (EDD)
TRIGGERS & MEASURES
Ongoing Monitoring
CORE MONITORING ELEMENTS
AML/CFT Program
Program Components
Suspicious Activity Reporting
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
Risk assessment & license review before onboarding.
Strict data protection & audit right clauses.
Ongoing performance & compliance monitoring.
Training & Awareness
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:
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.
Contact Us
CHIEF COMPLIANCE OFFICER
cco@flur.comGENERAL COMPLIANCE INQUIRIES
compliance@flur.comDATA PROTECTION OFFICER
dpo@flur.comOFFICE ADDRESS
IDERA TECH LTD (Myver)
12, Innovation Drive, Lekki Phase 1, Lagos, Nigeria.