Effective Date: May 2026
Donbaba.ng (“we”, “our”, or “the Website”) provides information and guidance related to online gaming platforms such as Pin Up Nigeria, including reviews, tools, and related services.
We are committed to maintaining transparency, integrity, and compliance with applicable standards. This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy outlines how we approach verification, partner screening, and risk management in connection with our business relationships and services.
1. Purpose of This Policy
The purpose of this policy is to prevent misuse of our platform for illegal activities such as:
- Money laundering
- Fraud and identity theft
- Terrorist financing
- Other financial crimes
It applies primarily to business partners, service providers, and affiliates we may collaborate with in the Nigerian market.
2. Risk-Based Verification Approach
We apply a risk-based approach when assessing partners and collaborations. This means not all entities are treated the same — the level of verification depends on risk factors such as:
- Country of operation
- Business structure and ownership transparency
- Nature of services provided
- Industry reputation
Based on this evaluation, partners may be subject to:
- Standard Due Diligence (SDD/CDD)
- Enhanced Due Diligence (EDD) for higher-risk cases
Regular reviews are conducted to ensure continued compliance.
3. Verification Requirements
3.1 Standard Due Diligence (CDD)
Partners may be required to provide:
- Company registration documents
- Articles of association or equivalent
- Proof of registered business address
- Identification of directors and beneficial owners
- Ownership structure showing individuals with significant control (25% or more)
All documents should be recent and valid.
3.2 Enhanced Due Diligence (EDD)
Additional checks may apply in higher-risk situations, including:
- Verification of source of funds or wealth
- Proof of licensing (where applicable)
- Independent compliance or audit reports
- Extended background and reputation checks
4. Ongoing Monitoring
Compliance is not a one-time process. We may:
- Periodically review partner information
- Request updated documentation
- Monitor for unusual or suspicious activity
If concerns arise, we reserve the right to pause or terminate cooperation until the issue is resolved.
5. Sanctions & PEP Screening
We screen relevant individuals and entities against international databases, including:
- Sanctions lists (UN, EU, OFAC)
- Politically Exposed Persons (PEP) registers
Matches may result in refusal to cooperate or additional verification requirements.
6. Record Retention
We maintain KYC-related records for a reasonable period in line with international compliance practices. This ensures transparency and supports potential audits or investigations.
7. Restricted Regions
We do not engage with entities connected to:
- Sanctioned countries or regions
- Jurisdictions identified as high-risk by global regulators (e.g., FATF)
- Any territory where online gaming operations are prohibited
8. Non-Compliance
Failure to meet verification or compliance requirements may lead to:
- Refusal to establish a partnership
- Suspension of ongoing cooperation
- Termination of agreements
- Reporting to relevant authorities where required
9. Policy Updates
We may update this policy from time to time to reflect regulatory changes or improvements in our compliance processes. Updates will be published on this page.
Contact
If you have questions about this KYC & AML Policy, please contact us via the Donbaba.ng Contact Page.