Draft — pending counsel review
This page is a placeholder we're publishing early for transparency. It has not been reviewed by qualified Nigerian legal counsel and does not yet form part of any binding agreement. Commercial terms are governed by your executed contract with Pokopay.
Legal
Acceptable use policy
Last updated 12 September 2026
This Acceptable Use Policy ("AUP") lists uses of the Pokopay platform that are prohibited. It applies to every Merchant, Partner, staff user and cardholder-facing interaction on the Services, and it is incorporated by reference into our Terms of Service.
Breach of this AUP is a breach of the Terms. The escalation path below applies in every case; the choice of step depends on severity, recurrence and regulatory exposure.
1. Illegal goods & services
You must not use the Services to transact in goods or services that are unlawful under Nigerian law, including controlled drugs, weapons and munitions, wildlife and other trafficked goods, and any activity that facilitates human trafficking, forced labour or the sexual exploitation of minors.
2. Fraud & structuring
You must not knowingly submit fraudulent Transactions, present a card you are not authorised to use, or structure activity to evade Transaction limits, reporting thresholds or AML controls. This includes running your own card through your own Terminal to generate fake volume or manipulate settlement.
3. Restricted MCCs
Some Merchant Category Codes are restricted or require specific written approval before we will onboard or continue to serve:
- Adult content and adult services.
- Unlicensed financial services (including unlicensed lending and unlicensed money transmission).
- Unregulated cryptocurrency exchange or off-ramp businesses.
- Multi-level marketing (MLM) without the appropriate SEC / CAC registrations.
- Gambling and lottery activity outside the licensing envelope of the relevant Nigerian regulator.
- Pharmaceuticals sold to consumers without the applicable licence.
4. Sanctions & embargoes
You must not use the Services to transact with, on behalf of, or to the benefit of, any person, entity or jurisdiction subject to Nigerian, UN, EU, UK or US sanctions or trade embargoes.
5. Scheme rules
You must not circumvent card scheme rules, including surcharging where the scheme forbids it, splitting a Transaction to avoid a limit, misrepresenting the nature of the sale to obtain a different interchange rate, or laundering another business's Transactions through your MID (factoring).
6. Platform integrity
You must not:
- Scrape, crawl or otherwise programmatically extract data from the dashboard or marketing site outside of documented APIs.
- Reverse-engineer, decompile or disassemble the Terminal firmware, mobile applications, or backend services.
- Conduct port scans, vulnerability scans or exploitation attempts against Pokopay infrastructure without an executed written testing agreement.
- Attempt to open, reflash, tamper with or physically compromise a Terminal, or to extract cryptographic keys from any component of the platform.
- Introduce malware, submit deliberately malformed input, or otherwise interfere with the availability or integrity of the Services.
7. Reporting abuse
Report suspected abuse of the platform to abuse@pokopayng.com. For security vulnerabilities, use security@pokopayng.com instead. Include enough detail that we can act — the Merchant name or MID, timestamps, the behaviour observed, and any supporting evidence — and expect an acknowledgement within one business day.
8. Consequences of breach
The typical escalation path, adjusted for severity and regulatory exposure:
- Warning — written notice with the specific breach and a window to remediate.
- Suspension — access to the dashboard, Terminals or specific features paused pending remediation.
- Termination — the commercial relationship ends, in line with the Terms and the commercial contract.
- Freeze pending investigation — where fraud, AML or sanctions risk is credible, Settlement may be held while we investigate and, where required, engage the acquirer and the relevant regulator.
Nothing in this AUP limits our obligation to file suspicious activity reports or otherwise cooperate with regulators and law enforcement.
