AML / CFT / CPF Policy

The Board of Directors holds ultimate responsibility for our AML/CFT/CPF programme. Day-to-day execution sits with the Chief Compliance Officer (CCO), who reports independently to the Board Risk & Compliance Committee. The CCO is registered with the NFIU.

We assess customer, product, channel, geography and transaction risk at onboarding and continuously thereafter. High-risk relationships (PEPs, cross-border, cash-intensive businesses) receive Enhanced Due Diligence (EDD) and senior-management approval.

• Tier 1 — basic ID, BVN/NIN verification, ₦300k single / ₦300k balance limit.
• Tier 2 — passport photo + valid government ID, ₦500k single / ₦500k balance limit.
• Tier 3 — full KYC with address verification, no cap (subject to internal limits).
• Corporate accounts require CAC documents, beneficial ownership disclosure (≥5%) and director KYC.

Every customer and counterparty is screened against UN, OFAC, EU, UK HMT, Nigerian sanctions list and the NFIU/CBN watch lists at onboarding, before every funds transfer, and on every list update. Matches trigger immediate freeze and escalation.

Our monitoring engine applies risk-tuned scenarios (structuring, smurfing, rapid in-out, unusual cross-border, dormant-revived) in near-real time. Alerts are investigated by trained analysts and disposed within regulatory timelines.

• Currency Transaction Reports (CTRs) for cash transactions ≥ $10,000 equivalent.
• Suspicious Transaction Reports (STRs) filed with NFIU via goAML within statutory timelines.
• Foreign Currency Transfer Reports and other returns as required by CBN/NFIU.

All KYC files, transaction records, alerts and reports are retained for a minimum of 5 years after account closure or transaction date, and longer where required by court or regulator.

All staff complete AML/CFT/CPF training on hire and at least annually thereafter, with role-specific deep-dives for front-office, compliance and operations. Board members receive tailored briefings each year.

Disclosing to a customer or third party that an STR has been or may be filed is a criminal offence under Nigerian law. Staff and agents are bound by strict confidentiality.

We perform due diligence on all agents, partners and correspondent relationships, including review of their own AML/CFT programmes. Shell-bank relationships are prohibited.

An independent audit of the AML/CFT/CPF programme is conducted at least annually, with findings reported to the Board and remediation tracked to closure.