Money Laundering (ML): The process by which criminals attempt to conceal the origin and/or illegitimate ownership of property and assets resulting from criminal activities. Terrorism Financing: Involves both legitimate and illegitimate money characterized by the concealment of the origin or intended criminal use of the funds. Know Your Customer (KYC): Obtaining and verifying customer identity, preserving customer records, and mandatory disclosure of transactions to authorized statutory bodies. Nigeria Financial Intelligence Unit (NFIU):
The Nigerian arm of the global Financial Intelligence Unit (FIU). Politically Exposed Persons (PEPs): Individuals entrusted with prominent public functions, posing higher risks for potential involvement in bribery and corruption. Enterprise Risk Management (ERM): Methods and processes used by organizations to manage risks and seize opportunities related to achieving their objectives. Client: Any entity with a business relationship with Neuma Digital Services Ltd or any entity connected with a financial transaction that can pose significant reputational or other risks to the company.
Policy Mandate:
This policy is connected to a more comprehensive in-house Anti-Money Laundering (AML), Know Your Customer (KYC), and the Combating the Financing of Terrorism Policy (CFT). It sets out an abbreviated version of the guidelines for Neuma Digital Services Ltd (herein referred to as ‘the Company’) compliance with AML/CFT obligations under the law and regulatory directives. It prevents any transaction that facilitates criminal activities. Neuma Digital Services Ltd understands its vital role in preventing criminals from using its services for money laundering and terrorist financing.
Policy Description:
Money Laundering and financing terrorism are financial crimes with economic effects. This policy aims to eradicate the adverse effects of criminal economic activity, promoting integrity and stability in financial markets. Compliance with this policy is critical to preserving the Company’s corporate integrity, reputation, and operational efficiency.
Purpose of this Policy:
Guide the standard of conduct and practice for AML, KYC, and CFT regulations.
Protect the Company against fraud, reputational, and other financial market risks.
Minimize risks from proceeds of crime.
Prevent money laundering and establish ERM systems to monitor the Company’s exposure to financial crime.
Compliance with Policy:
The Company shall:
- Formulate and implement internal controls to deter criminals from using its facilities for money laundering and terrorist financing.
- Embark on Enterprise Risk Management (ERM) and maintain an ERM register.
- Designate a Money Laundering Reporting Officer (MLRO) to implement the Company’s AML/KYC compliance policy.
- Comply with the Money Laundering (Prohibition) Act, the Money Laundering (Prohibition) (Amendment) Act, and the Economic and Financial Crimes Commission Act.
- Identify and report suspicious transactions as defined in AML/KYC Regulations.
- Ensure the implementation of the AML/KYC Act requirements is not inhibited through the Company’s Confidentiality Agreement or Policy.
- Effectively communicate and raise staff awareness on AML/KYC issues.
- Establish and maintain a risk-based approach to assessing and managing money laundering and terrorist financing risks.
Know Your Client (KYC):
Establish and maintain a risk-based approach to Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD).
Issue a KYC compliance form to clients.
Obtain necessary documents and information from every client.
Report suspicious activities and transactions to regulatory authorities.
Update client information as available.
Identify and verify the client’s identity using reliable, independent source documents.
Verify the legal status of business names, incorporated trustees, and companies.
Refuse to transact business with “shell companies” as described under International Conventions.
Conduct due diligence for higher-risk clients, business relationships, or transactions.
Record Keeping and Reporting:
Keep records of a customer’s identification for at least six years after account closure.
Make records related to AML/CFT compliance or clients available upon request by regulatory or law enforcement agencies.
In case of any illegal transaction, draw up a report, take appropriate action to prevent money laundering, and send a copy to the Nigerian Financial Intelligence Unit (NFIU).
Politically Exposed Persons (PEPs):
Evaluate risks to business operations when dealing with PEPs and their family members or close associates.
Sanctions:
A breach of AML/CFT is a severe offense and could lead to investigations, imposition of fines, and criminal sanctions, including imprisonment.