KYC and KYB Policy

Last updated 12 October 2026

This policy is issued by Ricardian Labs Ltd (RC 7947032), which runs Milo, and applies the customer due diligence standards of the Company's Board-approved AML/CFT/CPF Policy. Milo knows every person and every business it serves. No account is opened, and no money moves, for anyone we have not identified. This policy is part of our Terms and Conditions.

1. Who it covers

Every individual customer (KYC, Know Your Customer) and every business customer (KYB, Know Your Business), from the first sign-up for as long as the relationship lasts.

2. Individuals: what we check before an account opens

Your phone number, proved by a one-time code sent to it. Your Bank Verification Number (BVN), checked with the Nigeria Inter-Bank Settlement System through our licensed partners. Your full legal name, which must match your BVN exactly. Your date of birth, and that you are at least 18. Your email address. Where a partner or the law requires it, your National Identification Number (NIN), a photo of yourself, or a valid ID document.

3. Businesses: what we check before an account opens

Registration with the Corporate Affairs Commission (certificate and registration number), the registered address, the nature of the business and where its money comes from, and the directors and every person who owns or controls 5% or more of it (beneficial owners). Each director and beneficial owner is identified as an individual under section 2. A business account opens only when all of this is verified.

4. Limits

Every account has single and daily transaction limits set by risk. Limits are raised only after further verification and only where activity fits the customer's profile.

5. Ongoing checks

We keep your details current and may ask you to confirm or update them at any time. We review activity that does not fit what we know of you. We may ask for more, such as proof of address, source of funds or source of wealth, before or after any transaction. We may limit what an account can do until a check is complete.

6. Enhanced checks

We apply closer checks to politically exposed persons and their family and associates, to higher-risk businesses and countries, and to unusual or large activity. Senior approval is required before such a relationship begins or continues.

7. Refusal and closure

We will not open, or will freeze or close, an account where identity cannot be verified, where details are false, borrowed or do not match, where a person or business appears on a sanctions list, or where a check is refused. We are not required to give a reason where the law forbids it.

8. Records

Identification records and transaction records are kept for at least five years after the relationship ends, or longer where the law or a regulator requires.

9. Partners

Accounts, cards and payments are provided by CBN-licensed partners, who carry out their own checks under their own licences. Milo's checks are in addition to theirs, never in place of them.

Milo is a service of Ricardian Labs Ltd (RC 7947032), a private company limited by shares incorporated in Nigeria on 22 September 2024 under the Companies and Allied Matters Act 2020. Registered office: 5, Ladipo Latinwo Crescent, Lekki, Lagos State, Nigeria. Contact: support@milo.ng.

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