AML / CFT / CPF Policy

Last Updated: August 5, 2026

This page is maintained by MamaSave to answer common AML / CFT / CPF questions about the MamaSave platform. It is an app-owned policy document and is not a certification or legal opinion issued by any third party.

MamaSave Eliozu Multipurpose Co-operative Society Limited (MamaSave Cooperative Ltd), operating the MamaSave scheme, is committed to preventing the misuse of its platform and field networks for Money Laundering (ML), Terrorist Financing (TF), and Proliferation Financing (PF). Technology and payment gateways are powered by Pearl Systems Ltd.

Every member, field agent, and circle organizer is verified before transacting, using a risk-based, tiered KYC framework:

• Identification: Verification via Bank Verification Number (BVN) and National Identification Number (NIN) through automated identity corroboration.
• Tiered Limits: Transaction and daily savings limits are enforced strictly based on verification depth. Accounts or field transactions failing verification are restricted automatically.
• Agent & Organizer Screening: Enhanced Due Diligence (EDD) applies to Field Collection Agents and Circle Organizers, including physical address verification, guarantor checks, and security bond requirements.

We utilize automated systems combined with field audit logs to monitor contributions, rotations, and withdrawals for suspicious activity, including:

• Rapid pass-through funds, cash structuring (smurfing to beat reporting thresholds), or sudden volume spikes.
• OTP verification failures, unexpected agent location mismatches, or field cash collection anomalies.
• Discrepancies between declared income/occupations and observed transaction patterns.

• Suspicious Activity Reporting: Transactions flagged with high ML/TF/PF risk are reviewed internally by the Designated Compliance Officer and escalated to the Nigerian Financial Intelligence Unit (NFIU) and relevant regulatory bodies.
• Statutory Reporting: Mandatory reporting thresholds for cash deposits or large transfers are fulfilled in compliance with the Money Laundering (Prevention and Prohibition) Act 2022.
• No Tipping-Off: As mandated by law, members under investigation will not be notified of internal flags or regulatory reports filed regarding their accounts.

Members, agents, and corporate administrators are screened against local and international sanctions lists (including UN, OFAC, and local law enforcement databases), Politically Exposed Person (PEP) lists, and adverse media at onboarding and periodically thereafter.

• Data Retention: All identification records, transaction ledgers, OTP logs, and verification data are retained securely for a minimum statutory period of five (5) years following account closure or transaction date.
• Training: Staff, field supervisors, and collection agents receive regular AML/CFT/CPF training proportionate to their operational roles.

If you have questions, grievances, or wish to submit a data rectification request, please contact our internal compliance desk:

• Corporate Legal Entity: MamaSave Eliozu Multipurpose Co-operative Society Limited (MamaSave Cooperative Ltd)
• Proprietary Brand Platform: MamaSave
• Corporate Website Address: https://mamasave.ng
• Compliance & Regulatory Enquiries: compliance@mamasave.ng
• Registered Physical Address: 74 G.U. Ake Road (Eliozu Road), Eliozu, Port Harcourt, Rivers State