AML POLICY

Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) policy for a digital asset company operating in Nigeria: 

Definitions

  • AML/CFT: means Anti-Money Laundering/Countering the Financing of Terrorism.  Money Laundering (ML): means the process by which criminals attempt to conceal the origin and/or illegitimate ownership of property and assets that are the proceeds of criminal activities. Terrorist Financing: includes both legitimate and illegitimate money characterised by concealment of the origin or intended criminal use of the funds. Customer Due Diligence (CDD): This entails obtaining and verifying customer identity, preservation of records of customers, mandatory disclosure of transactions to authorised statutory bodies. Nigeria Financial Intelligence Unit (NFIU): The Nigerian arm of the global Financial Intelligence Unit (FIU). 
  • Money Laundering (ML): means the process by which criminals attempt to conceal the origin and/or illegitimate ownership of property and assets that are the proceeds of criminal activities.
  • Terrorist Financing: This entails obtaining and verifying customer identity, preservation of records of customers, mandatory disclosure of transactions to authorised statutory bodies.
  • Customer Due Diligence (CDD): means Anti-Money Laundering/Countering the Financing of Terrorism.  Money Laundering (ML): means the process by which criminals attempt to conceal the origin and/or illegitimate ownership of property and assets that are the proceeds of criminal activities. Terrorist Financing: includes both legitimate and illegitimate money characterised by concealment of the origin or intended criminal use of the funds. Customer Due Diligence (CDD): This entails obtaining and verifying customer identity, preservation of records of customers, mandatory disclosure of transactions to authorised statutory bodies. Nigeria Financial Intelligence Unit (NFIU): The Nigerian arm of the global Financial Intelligence Unit (FIU). 
  • Nigeria Financial Intelligence Unit (NFIU): The Nigerian arm of the global Financial Intelligence Unit (FIU). 

INTRODUCTION

The purpose of this document is to outline the Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) policies for Easyflip international Limited. As a crypto company operating in Nigeria, Easyflip international Limited recognizes the need to comply with AML/CFT laws and regulations to prevent and detect money laundering and terrorist financing activities. 

LEGAL FRAMEWORK

The laws governing AML/CFT in Nigeria include the Money Laundering (Prevention and Prohibition) Act 2022, Terrorism (Prevention and Prohibition) Act, 2022, the Central Bank of Nigeria (CBN) AML/CFT Regulations and other relevant regulations issued by regulatory bodies such as the Securities and Exchange Commission (SEC) and the Nigerian Financial Intelligence Unit (NFIU). 

RISK ASSESSMENT

Easyflip international Limited will conduct a risk assessment to identify and evaluate the money laundering and terrorist financing risks associated with its business activities, customers, and geographical locations. The risk assessment will be conducted regularly and will take into account changes in the company's business activities and external factors. 

CUSTOMER DUE DILIGENCE (CDD)

Easyflip international Limited will conduct customer due diligence (CDD) measures before onboarding a customer or allowing a transaction. CDD measures will include identifying the customer and verifying their identity, obtaining information on the purpose and nature of the business relationship, and assessing the customer's risk profile. Enhanced due diligence measures will be applied to customers who present a higher risk of money laundering or terrorist financing. 

TRANSACTION MONITORING

Easyflip international Limited will monitor transactions on its platform for suspicious activities, including unusual patterns, large transactions and high-risk customers. The company will use a risk-based approach to identify and investigate suspicious transactions. 

RECORD KEEPING

Easyflip international Limited will maintain appropriate records of its business activities, transactions, and customer identification and verification procedures. These records will be retained for at least five years from the date of the transaction or the end of the business relationship, whichever is later. 

REPORTING

Easyflip international Limited will report suspicious transactions to the appropriate authorities in accordance with applicable laws and regulations. Reports will be made to the Nigerian Financial Intelligence Unit (NFIU) and/or other relevant authorities as required by law. Employees will be trained on how to recognize and report suspicious transactions. 

TRAINING

Easyflip international Limited will provide training to its employees on AML/CFT policies and procedures. The training will cover the risks of money laundering and terrorist financing, the company's policies and procedures and how to recognize and report suspicious transactions. 

INTERNAL CONTROL

Easyflip international Limited will implement internal controls to ensure compliance with AML/CFT laws and regulations. The controls will include monitoring and auditing procedures, reporting lines and escalation procedures for suspicious transactions. 

SANCTIONS

A breach of the AML/CFT is a severe offense and could lead to investigations, imposition of fines and criminal sanctions (including imprisonment). 

CONCLUSION

Easyflip international Limited is committed to complying with AML/CFT laws and regulations in Nigeria. The company will implement the policies and procedures outlined in this document to prevent and detect money laundering and terrorist financing activities. The company will regularly review and update these policies and procedures to ensure their effectiveness in addressing the evolving risks of money laundering and terrorist financing in the industry. 

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