ANTI-MONEY LAUNDERING POLICY
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets.
Generally, money laundering occurs in three stages:
- Placement: Cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions.
- Layering: Funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.
- Integration: Funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.
It is the policy of Naira Direct to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorists or criminal activity. Naira Direct is committed to full compliance with all applicable laws and regulations regarding anti-money laundering procedures. Naira Direct has adopted and will enforce the provisions set forth in Anti-Money Rules & Regulations in order to prevent and detect money laundering, terrorist financing and other illegal activities. Key components of our AML and CTF framework include the following:
Compliance Office
Naira Direct’s compliance officer is tasked with the following responsibilities:
- To oversee compliance with the relevant legislation, regulations, rules and industry guidance;
- Monitor transactions to detect unusual suspicious activities;
- Establish procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- Communicate AML/CFT issues to all stakeholders;
- Coordinate enhanced due diligence procedures regarding Clients; and responding to both internal and external inquiries regarding Naira Direct’s anti-money laundering policies and procedures.
- Reports to our board of directors regularly on all risk and compliance matters using a risk-based approach to the assessment and management of money laundering and terrorist financing risks and comply with the requirements of the Money Laundering (Prohibition) Act, 2011 (as amended), Terrorism (Prevention) Act, 2011 (as amended) and other related laws and regulations.
Know your Customer
Establishing and maintaining a risk-based approach to Customer Due Diligence (CDD), including customer identification, verification and KYC procedures. To ensure we meet these standards, our customers are required to provide certain personal details and documents when opening a Naira Direct Account. The nature, and extent, of what is required is guided by the customer’s deposit and withdrawal limits and, in some cases, the customer’s country of residence. In certain circumstances, Naira Direct may perform enhanced due diligence procedures for customers presenting a higher risk, such as those transacting large volumes etc.maintaining appropriate KYC records for the minimum prescribed periods.
Training Awareness
All relevant employees are made aware of AML/CFT law and are trained regularly to recognise and deal with transactions that may be related to AML/CFT, as well as to identify and report anything that gives grounds for suspicion.
Suspicious transactions shall include but not limited to the following:
- Entity that belongs to a person or organization considered as terrorist.
- Transactions which are structured to avoid reporting and record keeping requirements.
- Inconsistent information or false identification or any transaction involving criminal activity in Naira Direct’s view.