1.0          POLICY

The Anti-Money Laundering & Combating the Financing of Terrorism Policy (“AMF/CFT Policy”) sets out the guidelines for IGHREENATECH’s compliance with AML/CFT obligations under the law, as well as regulatory directives, and actively prevents any transaction that facilitates criminal activities.

1.1          DESCRIPTION

Money laundering and financing terrorism are financial crimes with economic effects. It requires an underlying primary profit-making crime such as corruption, drug trafficking, market manipulation, fraud, tax evasion, etc., with the intent to conceal the proceeds of the crime and to further the criminal enterprise. AML/CFT compliance programme helps mitigate the adverse effects of criminal economic activity and promote integrity and stability in financial markets. It is also critical to preserving the Company’s corporate integrity, reputation and operational efficiency.

1.2          DEFINITIONS

  • Money Laundering – Money laundering (ML) has been defined as the process whereby criminals attempt to conceal the illegal origin and/or illegitimate ownership of property and assets that are the proceeds of their criminal activities. It is, thus, a derivative crime (Central Bank of Nigeria Manual)
  • Terrorism Financing – includes both legitimate and illegitimate money characterised by concealment of the origin or intended criminal use of the funds
  • Know Your Customer – This entails obtaining and verifying customer identity, preservation of records of customers, mandatory disclosure of transactions to authorised statutory bodies
  • Customer Due Diligence – This covers steps taken by IGHREENATECH to identify its clients and validate their identities
  • Nigeria Financial Intelligence Unit – The Nigerian arm of the global Financial Intelligence Unit (FIU)
  • Politically Exposed Persons – Individuals who are or have been entrusted with prominent public functions in any country; generally presenting a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold

1.3          PURPOSE

The purpose of this Policy manual is to:

  • Provide guidance on the standards of conduct and practice that must be followed in the implementation of the Know Your Customer (KYC) and Customer Due Diligence (CDD) requirements of the capital market
  • Protect the Company against fraud, reputational and other financial market risks
  • Minimise the risks faced by the Company from proceeds of crime
  • Protect the integrity of the securities market against all forms of abuse, fraudulent and unfair trade practices

1.4          POLICY STATEMENT

The following statements shall guide the principles and procedures for AML/CFT compliance programme. IGHREENA TECHNOLOGIES shall:

  • Formulate and implement internal controls and other procedures that will deter criminals from using its facilities for money laundering and terrorist financing and to ensure that its obligations under subsisting laws and Regulations are met
  • Designate AML/CFT Chief Compliance Officer at the Management level, with the relevant competence, authority and independence to implement the institution’s AML/CFT compliance programme
  • Comply with the requirements of the Money Laundering (Prohibition) Act, 2011 (as amended), Terrorism (Prevention) Act, 2011 (as amended) and Terrorism Prevention (Freezing of International Terrorists Funds and other Related Measures) Regulations 2013, including related laws and Regulations
  • Identify and report to the EFCC, in the course of its business, any suspicious transactions derived from the criminal activities defined in AML/CFT SEC Regulations
  • Ensure the implementation of the requirements of the AML/CFT Act are not inhibited through the Company’s Confidentiality Agreement or Policy
  • Exit relationships which pose heightened money laundering risks to IGHREENA TECHNOLOGIES.
  • Effectively communicate this Policy to raise the level of staff awareness on AML/CFT issues.

1.5          TRANSACTION REPORTING

IGHREENA TECHNOLOGIES shall exercise due diligence in identifying and reporting a suspicious transaction. Suspicious transactions shall include:

  • Transactions which are structured to avoid reporting and record keeping requirements
  • Altered or false identification or inconsistent information or any transaction involving criminal activity in IGHREE’s view
  • Entity that belongs to a person or organisation considered as terrorist

IGHREENA TECHNOLOGIES shall ensure timely and accurate rendition of all AML/CFT returns as specified in the SEC AML/CFT Rules and Regulations as well as other relevant Regulations/Act/Guidelines/Circulars that may be issued from time to time by various government agencies.

1.6          AWARENESS AND TRAINING

IGHREENA TECHNOLOGIES shall create awareness amongst its employees on AML/CFT through a well-structured training program that will include formal courses, workshops and newsletters. Such trainings shall incorporate current developments and changes to relevant guidelines as well as internal Policies, procedures, processes and monitoring systems.

IGHREENA TECHNOLOGIES shall also utilise other avenues such as e-mails, laptop screensavers, display screens, posters etc.

to disseminate compliance issues arising from new rules and regulations to all Staff members

1.7          SCOPE

This Policy manual applies to IGHREENA TECHNOLOGIES, Management and Staff with respect to compliance with rules and regulations that govern its operations. Specifically, the AML/CFT Compliance Procedures shall be incorporated into the operations of Business Marketing, Business Origination, Market Regulation, Examination Groups, as well as any other relevant Groups in IGHREENA TECHNOLOGIES.

 1.8        CONSEQUENCES

A breach of the anti-money laundering and combating the financing of terrorism laws is a serious offence and could result in lengthy investigations, significant fines and criminal sanctions (including imprisonment of employees)

 1.9        REFERENCES

This Policy is in line with the requirements of the Securities and Exchanges Commission (SEC) regulations on Capital Market Operators Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT).