This Anti-Money Laundering and Counter-Terrorist Financing Policy (the "AML Policy") describes the measures MedicsLink ("MedicsLink", "we", "us" or "our") takes to detect, prevent and report money laundering, terrorist financing and related financial crime across the MedicsLink platform (the "Platform"). It supports our Terms of Service and Privacy Policy and applies to every User of the Platform.
1. Our commitment
MedicsLink operates a marketplace where payments for healthcare Engagements are funded by Organizations, held in escrow, and paid out to Professionals. We are committed to ensuring the Platform is not used to launder the proceeds of crime or to finance terrorism. We maintain a risk-based AML/CFT programme aligned with applicable Nigerian law and the guidance of relevant authorities, including the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, and the regulations of the Nigerian Financial Intelligence Unit ("NFIU") and the Central Bank of Nigeria.
2. Scope
This AML Policy applies to all Users — Professionals and Organizations — and to all transactions processed through the Platform, including escrow funding, payouts, subscriptions and refunds. Payment processing itself is performed by licensed third-party payment gateways that operate their own regulated AML programmes; this Policy describes the controls MedicsLink applies in addition to theirs.
3. Know Your Customer (KYC) and Customer Due Diligence
We verify the identity of Users before they can transact:
- Professionals provide identity details and professional credentials (licence/registration numbers and issuing body) that are checked as part of onboarding and hire eligibility.
- Organizations provide business registration and contact information and may be required to complete additional verification.
- Payout accounts are validated through our payment gateway before any disbursement, and account numbers are encrypted at rest.
We may request additional information or documentation at any time, and we may apply enhanced due diligence to higher-risk Users or transactions.
4. Transaction monitoring
We monitor activity on the Platform for indicators of money laundering, terrorist financing or fraud, including:
- Payments or payouts that are inconsistent with a User's expected activity.
- Attempts to move funds off-Platform to avoid fees or controls.
- Rapid funding and withdrawal patterns, structuring, or use of unrelated third-party accounts.
- Mismatches between the named party and the underlying payout account.
5. Prohibited activity
Users must not use the Platform to:
- Launder, conceal or move the proceeds of any criminal activity.
- Finance terrorism or any sanctioned or unlawful activity.
- Make or receive payments for services not genuinely provided through the Platform, including fictitious or collusive Engagements.
- Provide false identity, credential or payment information.
6. Sanctions screening
We do not knowingly transact with individuals or entities subject to applicable sanctions. Where screening or other information indicates a User may be a sanctioned person, we may decline, suspend or reverse the relevant transaction and restrict the account.
7. Reporting and cooperation
Where we identify activity that we reasonably suspect involves money laundering, terrorist financing or other financial crime, we may file reports with the NFIU and other competent authorities as required by law. We may do so without notifying the User, where notification is prohibited or would prejudice an investigation. We cooperate with lawful requests from regulators and law enforcement.
8. Suspension, holds and termination
To comply with this Policy and applicable law, we may, at our discretion and without liability: place a hold on escrowed funds or payouts; request further information; decline or reverse a transaction; and suspend or terminate access to the Platform. These measures are in addition to the rights set out in our Terms of Service.
9. Record keeping
We retain identity, verification and transaction records for the period required by applicable law and regulation, and handle them in accordance with our Privacy Policy.
10. Governance and training
MedicsLink maintains internal procedures and assigns responsibility for AML/CFT compliance, reviews this programme on a risk basis, and provides relevant staff with appropriate awareness of their obligations.
11. Changes to this Policy
We may update this AML Policy from time to time to reflect changes in law, regulation or our practices. Where changes are material, we will provide notice through the Platform.
12. Contact
Questions about this AML Policy, or to report a concern, can be sent to MedicsLink through the in-app Help & Support channel, or by email at medicslinkng@gmail.com.