Anti-Money Laundering Policy

Anti-Money Laundering & Combating the Financing of Terrorism (AML/CFT) Policy

1. Policy

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

2. 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 policies help mitigate the adverse effects of criminal economic activity and promote integrity and stability in the financial markets. It is also pivotal in preserving Stow’s corporate integrity, reputation and operational efficiency.

3. 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 use of the funds for criminal purposes.
Know Your Customer - This entails obtaining and verifying customer identity, preservation of records of customers and mandatory disclosure of transactions to authorised statutory bodies.
Customer Due Diligence - This covers steps taken by STOW 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 or have held in the past.

4. Purpose

The purpose of this Policy manual is to:
1. 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 for Stow’s transactions
2. Protect Stow against fraud, reputation and other financial market risks
3. Minimise the risks faced by Stow from proceeds of crime
4. Protect the integrity of the Nigerian financial services market against all forms of abuse, fraudulent and unfair trade practices

5. Policy Statement

The following statements shall guide the principles and procedures for AML/CFT compliance programme. Stow shall:
1. 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
2. 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 policies.
3. 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, Central Bank of Nigeria (Anti-Money laundering and Combating the Financing of Terrorism for Banks and Other Financial Institutions in Nigeria) Regulations, 2013 including related laws and Regulations
4. Comply promptly with all the requests made pursuant to subsisting laws and Regulations and shall provide relevant information to the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU) and other relevant law enforcement agencies on AML/CFT matters
5. Identify and report to the NFIU, in the course of its business, any suspicious transactions derived from the criminal activities defined in AML/CFT CBN Regulations
7. Exit relationships which pose heightened money laundering risks to Stow
8. Effectively communicate this Policy to raise the level of staff awareness on AML/CFT issues
6. Ensure the implementation of the requirements of the AML/CFT Act are not inhibited through Stow’s Confidentiality Agreement or Policy

6. Know Your Customer (KYC)

KYC is the due diligence that Financial Institutions, Financial Market Operators, Capital Market Operators, Financial Market Infrastructures and other regulated companies must perform to identify their clients and ascertain relevant information before carrying-out any financial businesses with them. A client for the purposes of KYC policy is defined as:
1. An entity that has a business relationship with Stow
2. Any entity connected with a financial transaction, which can pose a significant reputational or other risk to Stow
Specifically, Stow’s KYC policies and procedures emphasize the following:
3. Obtaining the necessary documents and information from every client (anyone who Stow receives money from to provide a business)
4. Obligation to report to the regulatory authorities on suspicious transactions, which may ultimately have a bearing on money laundering activities
5. Updating client information as frequently as practicable
6. Identifying the client as well as their beneficial owners and verifying such client’s identity using reliable, independent source documents, data or information
7. Independent verification of legal status of incorporated entities and sole proprietorships with the Corporate Affairs Commission, in writing.
8. Refusal to transact business with “shell companies” as described under the International Conventions
9. Performing enhanced due diligence for higher risk clients, business relationships or transactions including:
i. Politically Exposed Persons (PEP), cross border transactions and business relationships
ii. Any other businesses, activities or professions as may be prescribed by regulatory, supervisory and competent authorities

7. Record Keeping and Retention Requirements

Upon request by a regulatory or law enforcement agency, Stow shall make available records related to AML/CFT compliance or its clients as soon as possible from the date of the request.

8. Transaction Reporting

Stow shall exercise due diligence in identifying and reporting a suspicious transaction. Suspicious transactions shall include:
1. Transactions which are structured to avoid reporting and record keeping requirements
2. Altered or false identification or inconsistent information or any transaction involving criminal activity in Stow’s view
3. Entity that belongs to a person or organization considered as terrorist
Stow shall ensure timely and accurate rendition of all AML/CFT returns as specified in relevant Regulations/Act/Guidelines/Circulars that may be issued from time to time by various government agencies.

9. Awareness and Training

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

10. Politically Exposed Persons (PEPs)

Business relationships with family members or close associates of PEPs involve reputation risks similar to those PEPs themselves. Stow shall evaluate the risks to its business operations when dealing with PEPs. The following factors shall guide identification of PEPs’ risk characteristics:
1. Nature of the client and the client’s businesses - The source of the client’s wealth, the nature of the client’s business and the extent to which the client’s business history presents an increased risk for money-laundering and terrorist financing
2. Purpose and activity – The size, purpose, services involved in the relationship
3. Relationship – The nature and duration of Stow’s relationship with the client
4. Client’s corporate structure
5. Public information – Information is known or reasonably available to Stow about the client

11. Responsibilities

1. Stow’s Board of Directors is responsible for:
i. Approving the AML/CFT Compliance Policy
ii. Reviewing all periodic report on AML/CFT matters
iii. Ensuring that Management forwards all required periodic reports to the relevant regulatory authorities
iv. Providing guidelines regarding the management of AML/CFT compliance risks.
2. Stow’s Compliance Officer is responsible for:
i. Coordinating and monitoring day-to-day compliance with applicable money laundering laws and regulations.
ii. Monitoring transactions to detect unusual suspicious activities
iii. Prompt preparation and delivery of all relevant returns to the regulatory bodies in line with CBN and FIU Rules and Regulations
iv. Communicating AML/CFT issues to all stakeholders
3. All Staff Members:
i. Familiarizing themselves with guidelines, policies and best practices relating to their respective areas of responsibility
ii. Implementing the measures and approaches diligently and to the best of their ability
iii. Reporting any legal violations or other forms of misconduct in accordance with Stow Policies and Procedures

12. Scope

This Policy manual applies to Stow and its Board of Directors, 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 Stow.

13. 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).

14. Contact Information

If you have any questions or comments about these our policy as outlined above, you can contact us at: Stow Technologies Limited is a private company incorporated in Canada with Corporation Number 1296287-0 and in Nigeria under the Companies and Allied Matters Act with Registration Number RC 1763645.