KYC Onboarding Policy

This policy defines FidemIt's Know Your Customer (KYC) onboarding requirements for all users of the FidemIt Escrow platform, in support of AML/CTF obligations and wallet tier limits.

It applies to all individual and business users who register, verify identity, or use wallet and escrow services.

1. All users must complete onboarding appropriate to their requested wallet tier.
2. Identity and address information must be accurate, complete, and kept up to date.
3. FidemIt may request additional verification where risk indicators are identified.
4. Failure to complete or pass KYC may result in account restrictions, suspension, or termination.

Providing both BVN and NIN is encouraged for stronger compliance alignment.

4.1 Registration

Users create an account with unique credentials and agree to platform terms and the privacy policy.

4.2 Identifier Verification (Tier 1+)

Users must provide at least one approved identifier:

• BVN — Bank Verification Number
• NIN — National Identification Number

4.3 Identity Verification (Tier 2+)

Users must submit:

• Government-issued ID: National ID, Passport, or Driver's Licence
• ID number
• Front and back images of the ID document
• Selfie with ID document

Submissions are reviewed by authorized FidemIt personnel before approval.

4.4 Address Verification (Tier 3)

Users must submit residential address details and proof of address:

• Utility Bill, or
• Bank Statement

Business account holders must additionally provide:

• Legal business name and registration number
• Business address and industry
• Director identification and contact details

Users must:

• Keep profile and verification information accurate
• Report changes to identity or address promptly
• Cooperate with additional verification requests when required
• Not use false, misleading, or third-party identity documents

• KYC submissions are reviewed manually by authorized admin staff
• Outcomes: pending, approved, or rejected
• Rejected users may resubmit with corrected information
• FidemIt may restrict wallet tier or apply Post No Debit (PND) pending review

KYC data is handled per our Data Protection Policy. BVN and NIN are stored using encryption and hashing controls. ID images and selfies are access-restricted to authorized roles.

Non-compliance may result in:

• Wallet and transaction limits restricted to the lowest approved tier
• Withdrawal restrictions where verification is incomplete
• Account suspension or termination
• Reporting to relevant authorities where required by law