Large Transfers and AML Checks

Why we ask more on larger transfers

CrossPay is a regulated cross-border payments service. The Nigerian Money Laundering (Prohibition) Act 2011, the Central Bank of Nigeria's AML regulations, and the Financial Action Task Force (FATF) recommendations require us to collect additional information on transfers above defined reporting bands. The bands and the information we ask for are documented below.

The same logic applies whether you send via the web or the mobile flow — the wizard tells you exactly what's needed before you confirm.

Threshold 1 — Transaction details (purpose of payment)

For Individual accounts, transfers AT OR ABOVE the following amounts trigger a "Transaction details" step in the send-money wizard:

Business accounts see the Transaction details step on every transfer, regardless of amount — this is a CBN requirement for corporate FX.

In this step we ask for:

1. Purpose of payment — short free-text or a category (family support, supplier payment, salary, freelance income, etc.). This is the single most important compliance datum on every wire.
2. Beneficiary type — individual or company.
3. Payment destination — bank account or mobile money.

The wizard pre-fills "Personal transfer" as a sensible default for Individual users below the threshold; if you cross the threshold mid-flow we re-open Step 2 so you can confirm before the confirmation screen.

Threshold 2 — Supporting document

For transfers AT OR ABOVE the following amounts, we additionally ask you to upload a supporting document that evidences the payment purpose:

The lower band for company beneficiaries matches FATF's standard for B2B "occasional transactions"; the individual band matches the FATF "designated threshold" for cross-border wire transfers.

Acceptable documents depend on the purpose:

1. Supplier payment / B2B: pro-forma invoice, commercial invoice, or purchase order naming the beneficiary.
2. Salary / contractor: signed contract excerpt or pay slip.
3. Family support: relationship affidavit or a previous regulator-acceptable equivalent (rarely needed under the threshold).
4. Education: school invoice or admission letter.
5. Medical: hospital invoice or treatment plan.

Documents are uploaded over HTTPS, encrypted at rest, retained for the regulator-mandated 7 years, and visible only to authorised compliance reviewers.

What happens above the threshold

1. The wizard asks for the extra fields on Step 2.
2. If a supporting document is required, an upload widget appears on the same step. You can drag-and-drop or pick a file.
3. The transfer enters review the moment you click Continue — no payment yet.
4. If our compliance team needs more information, you'll receive an email and the transfer status will stay at "Awaiting payment" until resolved.
5. Approval typically lands the same business day; complex cases may take up to 3 business days.

What you can do BEFORE you hit a threshold

1. Complete full KYC. Approved (Tier 2) accounts have higher daily and monthly limits AND skip some duplicate-document asks.
2. Save your recipients. A previously-validated beneficiary lets us reuse parts of their record so you only fill new compliance fields.
3. Keep documents handy. A clear scan of the supplier's invoice or your contract makes the upload step a 30-second job.

Who sees this information

1. Our compliance reviewers (named individuals under a formal access-control policy).
2. The Nigerian Financial Intelligence Unit (NFIU), if law requires us to file a Suspicious Transaction Report — we're prohibited from telling you when this happens (the "tipping-off" rule).
3. The destination bank's compliance team, in summary form, where the payment rails require it.

We never share supporting documents with marketing, partners, or aggregators.

Need help on a specific transfer?

The wizard's blue info banner on Step 2 explains the exact reason it's asking each time. If the explanation isn't clear, contact our compliance team at compliance@crosspay.me with your transfer reference — we respond within one business day.

For the underlying policy in full, see our AML Policy.