AML & CFT Policy Statement

We are committed to complying with the Money Laundering (Prevention and Prohibition) Act, 2022, the Terrorism (Prevention and Prohibition) Act, 2022, and applicable regulations and guidance issued by the Securities and Exchange Commission (SEC), the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU), and the Special Control Unit against Money Laundering (SCUML), together with the recommendations of the Financial Action Task Force (FATF) and applicable United Nations Security Council Resolutions on targeted financial sanctions and proliferation financing. We take a zero-tolerance approach to the use of our services, knowingly or otherwise, to facilitate money laundering, terrorist financing, or proliferation financing.

We apply risk-based customer due diligence (CDD) to all clients before establishing a business relationship. This includes verifying a client's identity using reliable, independent documentation, identifying the beneficial owners of corporate and trust clients, and understanding the intended purpose and nature of the relationship. Enhanced due diligence (EDD) is applied to higher-risk clients, including Politically Exposed Persons (PEPs), clients connected to higher-risk jurisdictions, and clients whose transactions are complex, unusually large, or inconsistent with their known profile. Where EDD applies, this may include obtaining additional information on source of wealth and funds, and requiring senior management approval before onboarding.

We screen clients, beneficial owners, and transactions against applicable sanctions lists, including those issued by the United Nations Security Council, and against Politically Exposed Person databases, both at onboarding and on an ongoing basis throughout the relationship. Where a potential match is identified, it is escalated for review, and any confirmed match involving a sanctioned party results in the relevant transaction being blocked and reported to the appropriate authority without delay.

We monitor client transactions on a risk basis, using a combination of automated and manual review, to detect activity that may be suspicious or inconsistent with a client's expected profile.

Where a transaction or pattern of activity is assessed as suspicious, we are legally required to file a Suspicious Transaction Report (STR) with the Nigerian Financial Intelligence Unit. In accordance with our No Tipping-Off Policy, we do not disclose to a client, or to any third party, that a report has been made or is under consideration.

We retain customer identification, transaction, and compliance records, including Suspicious Transaction Reports and the outcome of any related investigation, for the period required by applicable law, which is currently a minimum of five years from the date of the relevant transaction or the end of the business relationship, whichever is later.

Oversight of our AML/CFT/PF Program sits with our Board of Directors, which approves our AML/CFT/PF policies and reviews periodic reporting on financial crime risk, and our Compliance Officer, who is responsible for the day-to-day operation of the Program, including customer due diligence, transaction monitoring, regulatory filings, and acting as our primary liaison with the SEC and NFIU.

All employees receive mandatory AML/CFT/PF training appropriate to their role, covering the identification and escalation of suspicious activity, customer due diligence requirements, and applicable legal and regulatory obligations. Training is refreshed periodically to reflect regulatory developments and emerging financial crime risks.

This Statement should be read alongside our Privacy Policy, Terms and Conditions, Legal Disclaimer, Risk Management Policy, and Whistleblower Policy. We may update this Statement from time to time to reflect changes in our practices or applicable law.