Minie Educational Finance Limited (hereinafter referred to as MinieMoney) supports global, regional, and national efforts to combat money laundering and terrorist financing (ML/TF), and is committed to establishing and maintaining appropriate policies, procedures, systems, and controls to ensure that MinieMoney complies with Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) requirements. It is committed to the highest standards of AML/CFT compliance and requires management and employees to adhere to these standards to prevent the use of its products, services, channels or resources for money laundering, terrorist financing purposes or other financial crimes. Adherence to the MinieMoney AML/CFT Program is the responsibility of all employees.

The AML/CFT Program of MinieMoney includes the following minimum requirements:
• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for higher risk categories of customers;
• Customer and transaction screening and monitoring;
• Sanction screening;
• Reporting of suspicious transactions and activities;
• Record keeping;
• AML/CFT Training; and
• Independent testing of the AML/CFT compliance programme.

The objectives of this Policy are:

• To ensure that all applicable statutory and regulatory requirements are complied with.
• To provide a framework and minimum requirements which MinieMoney will adopt for combating the money laundering, terrorist financing and Proliferation financing risks it is exposed to. The framework and minimum requirements are intended to protect MinieMoney, its products, services, channels, resources, or employees from being misused for money laundering, financing of terrorism or other financial crimes; and
• To ensure that the reputation and integrity of the company is protected by taking all reasonable steps to prevent its use for ML/TF purposes.

This Policy applies to all employees of MinieMoney, whether permanent, contract or temporary, regardless of their position in the company, with no exception. It also applies to all branches, divisions, departments, and units of MinieMoney.

This Policy shall be reviewed at least once every two years. However, an ad hoc review may be triggered by major statutory or regulatory developments.

a. MinieMoney supports global efforts against Money Laundering, and Terrorist Financing.
b. MinieMoney shall comply with the Money Laundering Prohibition Act (amended) 2011, the Prevention of Terrorism Act (amended) 2012, the CBN AML/CFT regulation 2013 and best practice requirements.
c. MinieMoney shall not in any way inhibit the implementation of the provisions of AML/CFT regulations but co-operate with the regulators and law enforcement agencies in the implementation of a robust AML/CFT regime in Nigeria.
d. MinieMoney shall define persons and entities that they would be prohibited from entering any business relationship with e.g., sanctioned persons and entities as defined by Office of Foreign Assets Control “OFAC”, local regulators as well as known fraudsters.
e. MinieMoney shall ensure a structure is in place for identifying and reporting unusual, suspicious, or criminal activities to the Compliance Unit and ultimately to the appropriate authorities.
f. MinieMoney shall comply promptly with requests made in relation to AML/CFT legislations and provide information to the Central Bank of Nigeria (CBN), Nigeria Financial Intelligence Unit (NFIU)and other competent authorities.

Prohibition of Money Laundering
In line with the United Nations 2000 Convention against Transnational Organized Crime, also known as the “Palermo Convention,” conducts which are deemed to be money laundering (as described below) are prohibited:
• The conversion or transfer of property, knowing it is derived from a criminal offense, for the purpose of concealing or disguising its illicit origin or of assisting any person who is involved in the commission of the crime to evade the legal consequences of his actions.
• The concealment or disguising of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property knowing that it is derived from a criminal offense.
• The acquisition, possession, or use of property, knowing at the time of its receipt that it was derived from a criminal offense or from participation in a crime.

Stages of Money Laundering
The following activities are prohibited:

• Placement stage: The physical disposal of cash or other assets derived from criminal activity.
• Layering stage: The separation of illicit proceeds from their source by layers of financial transactions intended to conceal the origin of the proceeds.
• Integration stage: Supplying apparent legitimacy to illicit wealth through the re-entry of the funds into the economy in what appears to be normal business or personal transactions.

Prohibition of Terrorist Financing
In accordance with Article 2 of the United Nations International Convention for Suppression of Terrorist Financing, this Policy hereby prohibits activities that are deemed to be Terrorist Financing as defined hereunder:
Any activity of any person who by any means, directly or indirectly, unlawfully, and willfully, providing or collecting funds with the intention that they should be used or in the knowledge that they are to be used, in full or in part, to carry out:
a. An act that constitutes an offence within the scope of and as defined in one of the treaties listed in the annex; or
b. Any other act intended to cause death or serious bodily injury to a civilian, or to any other person not taking an active part in the hostilities in a situation of armed conflict, when the purpose of such act, by its nature or context, is to intimidate a population, or to compel a government or an international organization to do or to abstain from doing any act.

Stages of the Terrorist Financing Process
The process of financing terrorist organizations can be broken down into three stages or phases, allowing one to accurately identify the three main motivations behind the process.

a. Fundraising stage: The initial phase, also referred to as the collection phase, consists of the search by terrorist organizations for financing sources.
b. Disposition stage: The intermediate phase seeks to place the collected funds at the disposition of the terrorist organization, to await their final use. It is also called the transmission/dissimulation phase.
c. Utilization stage: This is the last phase, in which the collected, transferred, and accumulated funds are used for the financing of the terrorist organization’s structural logistics, or the operating logistics related to the planning and execution of terrorist acts. It is also called the use phase.

Prohibition of Proliferation Financing
Activities such as providing funding or financial services which are used, in whole or in part, for the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical or biological weapons and their means of delivery and related materials (including both technologies and dual-use goods used for non-legitimate purposes), in contravention of national laws or, where applicable, international obligations (Proliferation financing) are hereby prohibited by this Policy in line with the mandates of the Financial Action Task Force (FATF).

Prohibition of Cybercrime
This Policy hereby prohibits any crime committed through a computer system or network (“Cybercrime”). Due to the rapid adaption of technology money launderers, terrorist financiers, and criminal groups have become more sophisticated in their methods and techniques. These criminals use computer system to move money offshore from the comfort of their homes and convert illegally obtained funds to virtual currencies which becomes difficult to trace and confiscate. MinieMoney shall adopt and operate a cybersecurity framework that covers cybersecurity practices and information security processes.

Board of Directors

a. The ultimate responsibility for AML/CFT compliance is placed on the Board and top management of MinieMoney.
b. The Board shall ensure that a comprehensive operational AML/CFT Policy and Procedure is formulated by Management and presented to the Board for consideration and formal approval; and
c. Receive regular, periodic reports from the Compliance Department on the implementation of the AML/CFT policy and any material AML/CFT issues.

Executive Compliance Officer (ECO)

a. Oversee the management of MinieMoney’s Compliance risk.
b. Supervise the Compliance function and make recommendations to the Board on the approval of the AML/CFT policy.
c. Ensure adequate supervisory role over the Chief Compliance Officers and his/her duties
d. Provide oversight on the Compliance program at the Board level.
e. Ensures the Board and Management’s participation in the AML/CFT Training.

Senior Management

a. A senior management staff shall be designated as the Chief Compliance Officer with the relevant competence, authority, and independence to implement MinieMoney’s AML/CFT compliance programme; and
b. Approve every exception allowed with regards to the AML/CFT Policy.

Compliance Department

a. The Chief Compliance Officer shall be appointed at management level and shall report directly to the Executive Compliance Officer on all matters under this policy.
b. Develop and implement an AML/CFT Compliance Programme including policies, procedures, systems, and controls.
c. Receive and vet suspicious transaction reports from staff.
d. File Suspicious Transaction Reports (“STRs”) with the Nigerian Financial Intelligence Unit (NFIU).
e. File other regulatory returns with the CBN, SEC, NFIU and other relevant regulatory and supervisory authorities, as applicable.
f. Render "nil" reports to the CBN, SEC and NFIU, where necessary to ensure compliance.
g. Monitor the day-to-day operations to detect unusual customer activity.
h. Co-ordinate the training of staff in AML/CFT awareness, detection methods and reporting requirements,
i. Serve both as a liaison officer between MinieMoney, the CBN, SEC, NFIU and other relevant authorities, as appropriate; and
j. Serve as a point-of-contact for all employees on issues relating to money laundering and terrorist financing.

Employees

a. All employees must familiarize themselves with this policy;
b. Take responsibility for ensuring compliance with this policy as it relates to their job functions;
c. Report any violations or other forms of misconduct relating to this policy through the designated channels; and
d. Report suspicious transactions or activities to the Compliance department.

Internal Audit

a. Periodically review and test compliance with the AML/CFT program, CDD/KYC policies and procedures and follow up on findings.
b. Risk-based internal audit and specific review of compliance with policies and procedures for PEPs and other high-risk clients and activities.

Risks Identification and Assessment
MinieMoney’s business encompasses a wide range of financial products and services, which are associated with different ML/TF risks. Examples of ML/TF risk associated with the different activities include: Attempts to launder money, finance terrorism, or conduct other illegal activities through MinieMoney can emanate from many different sources. However, certain products, services, customers, entities, and geographic locations may be more vulnerable or have been historically abused by money launderers and criminals. This step involves identifying and assessing the money laundering and terrorism financing risks that may be associated with MinieMoney’s unique combination of:


a. Customers;
b. Products and services;
c. Geographic locations; and
d. Delivery channels.

Customer Risk
Certain customers may pose specific risks. MinieMoney shall take an overall account of a customer’s background, geographic areas, and such other required measures to identify the customer’s ML/TF risks. Some factors that MinieMoney shall consider are:


a. Politically exposed persons (PEPs). Individuals who are or have been entrusted with prominent public functions (both foreign and local), for example, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned corporations, important political party officials. Business relationships with family members or close associates of PEPs may involve reputational risks like those with PEPs.
b. Geographic risk of the customer: Determine the level of risk of the customer’s nationality and country of residence based on a list of areas that are exposed to ML/TF risks defined by MinieMoney.
c. The channel used by the customer to open account and establish business relation.
d. The transaction amount with which the customer first establishes business relation.
e. Products or services that the customer applies.
f. Whether the customer has other high ML/TF risk characteristics. For example, the customer fails to provide a reasonable explanation regarding the significant geographic distance between the customer and the branch; frequent and unexplained movement of accounts to different institutions; frequent and unexplained movement of funds between institutions in various geographic locations.

Product, Service and New Technology Risks
MinieMoney shall consider the potential money laundering and terrorism financing risks associated with each of its specific products, service, and new technology. Some factors to consider are:
a. MinieMoney shall identify products, services, transactions, or delivery channels that have higher ML/TF risk based on the nature of the individual product, service, transaction, or delivery channel.
b. MinieMoney shall, before launching a new product, service, or business (including a new payment method, applying new technology on existing or new products or services), perform ML/TF risk assessment and establish relevant risk management measures to mitigate the risks identified.
c. Examples of such individual product, service, transaction or delivery channel risk factors are as follows:
• The extent of associating with cash.
• The channel to establish business relations or process transactions, including whether it allows non-face-to-face transactions, and whether it is a new payment method such as electronic banking.
• Whether it allows a high amount of money or value transfer.
• Anonymous transactions.
• Payment received from unknown or un-associated third parties.

Geography/Country Risk
This involves identifying geographic locations that may pose a higher risk to MinieMoney’s business. MinieMoney will seek to understand and evaluate the specific risks associated with doing business in, opening, and servicing accounts, offering products and services and/or facilitating transactions involving certain geographic locations. The Geography/Country risk may also be analyzed with respect to the location of the business division, unit, or business line, and may also include subsidiaries, affiliates, and offices, both internationally and domestically. MinieMoney shall identify domestic and international geographic locations that may pose a higher risk to its AML/CFT compliance program. Each case should be evaluated individually when assessing the risks associated with doing business, such as opening accounts or facilitating transactions, in certain geographic locations. Factors that may result in a country or region posing a higher risk include:
• Countries that are subject to sanctions, embargoes or similar measures issued by credible organizations such as the United Nations and the Financial Action Task Force.
• Countries identified by credible sources as lacking appropriate AML/CFT laws, regulations, and other measures.
• Countries identified by credible sources as providing funding or support for terrorist activities or that have designated terrorist organizations operating within them.

Delivery Channel Risk
MinieMoney has various modes of transaction and distribution (delivery channels) of its products and services. Some delivery channels may be more susceptible to ML/TF risk. Consequently, it should be assessed whether, and to what extent, the method of delivery, such as non-face-to-face or the involvement of third parties, including intermediaries and agents, could increase the inherent money laundering risk.

New Technology
MinieMoney shall assess the AML/CFT risk associated with technologies prior to implementation. Efforts should be made in assessing the new technology’s susceptibility to ML/TF risk and the applicable mitigation factors for each type of risk. Consequently, it should be assessed whether, and to what extent, the new technology could increase the inherent money laundering risk.

It is the paramount duty and responsibility of MinieMoney to know and understand its customers fully in terms of identity and activity to the extent of establishing the correctness/genuineness of the credentials for extending better customer service. This exercise also helps MinieMoney to identify adverse conditions, if any, associated with the applicant/customer (at the time of establishing a business relationship) and guard against criminals/fraudsters making use of MinieMoney’s channels/services for their nefarious activities. With the present-day multifarious dimensions of the delivery of financial services and products, the need for a structured methodology for understanding customers at the time of establishing a relationship has assumed great importance.

When to carry out Customer Due Diligence
MinieMoney will undertake Customer Due Diligence (“CDD”) measures when -

a. Business relationships are established.
b. Carrying out occasional transactions above the MinieMoney applicable and designated threshold or its equivalent in other currencies or as may be determined by the CBN from time to time, including where the transaction is carried out in a single operation or several operations that appear to be linked.
c. Carrying out occasional transactions where credit or debit cards are used as a payment system to effect money transfer.
d. There is a suspicion of money laundering or terrorist financing, regardless of any exemptions or any other thresholds referred to in this section; or
e. There are doubts on the veracity or adequacy of previously obtained customer identification data.
MinieMoney must not after obtaining all the necessary documents and being so satisfied, repeatedly perform identification and verification exercises every time a customer conducts a transaction except if there is a suspicion that the previously obtained information is not complete or has changed.
Furthermore, MinieMoney shall:
a. Identify its customers, whether permanent or occasional, natural, or legal persons, or legal arrangements, and verify the customers' identities using reliable, independently sourced documents, data, or information; and
b. Conduct ongoing due diligence on a business relationship. Types of customer information to be obtained and identification data to be used to verify the information may be provided by the Compliance Department in a supplementary policy to this policy.

Who must undergo MinieMoney’s KYC Procedure?

a. The Customer: This includes the individual account holder establishing a business relationship with MinieMoney.
b. Person acting on behalf of another (proxy): Identification evidence must be obtained for both the agent and the principal.
c. Principal controller of an account (Promoter or Signatory): The person(s) authorized to provide instructions for running the account or business relationship.
d. Intermediate parties: Identify the relevant parties where an account is managed by an intermediary or get assurance that the intermediary has conducted due diligence on the customer and is able to provide documents/evidence in that regard.
The extent of measures required or the documentary evidence to be obtained in relation to corporate entities depends on the nature of the business or service that the company requires from MinieMoney, and a risk-based approach shall be taken.

Risk-based approach to customer due diligence

MinieMoney shall adopt a risk-based approach to AML/CFT. A risk-based approach to AML/CFT means that MinieMoney is expected to identify, assess, and understand the ML/TF risks to which it is exposed and adopt AML/CFT measures commensurate to those risks to mitigate them effectively. This will allow MinieMoney to adopt a more flexible set of measures to channel its resources more effectively and apply preventive measures that are commensurate to the nature and extent of risks. The risk-based approach requires that:

a. Where higher risks are identified, MinieMoney shall take enhanced due diligence measures to manage and mitigate the risks; and
b. Where lower risks are identified, MinieMoney shall take simplified measures to manage and mitigate the risks, provided that simplified customer due diligent measures are not permitted whenever there is suspicion of money laundering or terrorist financing.

MinieMoney will adopt the following risk categorizations of customers based on the risks of money laundering and terrorist financing that they pose.
A. Prohibited - MinieMoney will not tolerate any dealings of any kind given the risk. The following prohibitions apply:

a. MinieMoney will not open and/or maintain anonymous accounts, numbered accounts, or accounts in obviously fictitious names.
b. MinieMoney will not open payable through accounts; and
c. MinieMoney will not open accounts or enter any business relationship with individuals and entities listed on recognized sanctions lists.
d. MinieMoney will not open accounts or enter any business relationship with individuals and/or business entities transacting, trading, or dealing with crypto currency exchanges.
e. MinieMoney will not finance or process any transaction that involves arms & ammunition or military equipment for unauthorized individuals & entities.

B. High Risk - The risks here are significant but are not necessarily prohibited. To mitigate the heightened risk presented, MinieMoney should apply enhanced due diligence measures. MinieMoney shall carry out enhanced due diligence measures by:
a. Establishing the purpose for opening an account.
b. Establishing the level and nature of business activities intended.
c. Obtaining senior management approval to establish or continue (if a relationship is already existing) the business relationship.
d. Establishing the source of funds and source of wealth of the customer; and
e. Identifying and verifying the ultimate beneficial owners of the customers.

C. Medium Risk- Medium risks are more than a low- or standard risk of money laundering, and merit additional scrutiny, but do not rise to the level of high risk. Normal due diligence requirements should apply here.

D. Low or Standard Risk- This represents the baseline risk of money laundering. Simplified due diligence requirements should apply here. There are low risks in circumstances where:
a) The risk or money laundering or terrorist financing is lower.
b) Information on the identity of the customer and the beneficial owner of the customer is publicly available; or
c) Adequate checks and controls exist elsewhere in the national systems.

MinieMoney shall perform Enhanced Due Diligence for high risk customers, business relationship or transactions including:

a. Politically Exposed Persons (PEPs)
b. Non-resident customers
c. Private customers
d. Legal persons or legal arrangements such as trusts that are personal-asset-holding vehicles
e. Companies that have nominee-shareholders or shares in bearer form
f. Cross-borders and business relationships such as correspondent company relationships where MinieMoney is the correspondent company
g. Customers from jurisdictions or territories designated by the Financial Action Task Force or other relevant body as having a higher risk for money laundering and financing of terrorism, or as having weak and/or ineffective AML/CFT controls.
h. Any other businesses, activities or professionals as may be prescribed by regulatory, supervisory, or competent authorities

Politically Exposed Persons (PEPs)
According to the extant local AML/CFT Regulations, Politically Exposed Persons (PEPs) are individuals who are or have been entrusted with prominent public functions in Nigeria or in foreign countries, and people or entities associated with them and include:
a. Heads of State or Government.
b. State Governors.
c. Local Government Chairmen.
d. Senior politicians.
e. Senior government officials.
f. Judicial or military officials.
g. Senior executives of state-owned corporations.
h. Important political party officials.
i. Family members or close associates of PEPs; and
j. Members of royal families.
PEPs also include persons who are or have been entrusted with a prominent function by an international organization, including members of senior management including directors, deputy directors and members of the board or equivalent functions other than middle ranking or more junior officers. Family members are individuals who are related to a PEP either directly (consanguinity) or through marriage or similar (civil) forms of partnership. Close associates are individuals who are closely connected to a PEP, either socially or professionally.

Enhanced Due Diligence Measures for High Risk Relationships
Enhanced Due Diligence measures for PEPs and other high risk accounts include the following:

a. Obtain senior management approval (preferably from the Managing Director/Chief Executive or his alternate who must be an Executive Director) before establishing the business relationships or continuing the relationship where one already exists.
b. Identify and verify the legal status and existence of the legal person or legal arrangement
c. Identify and verify the ultimate beneficial owners of a high-risk corporate entity. Where this is not feasible, identify and verify all the directors of the corporate entity.
d. Take reasonable measures to establish the source of wealth and the source of funds of customers. This may be achieved by comparing information provided during onboarding with the relationship manager’s knowledge of the customer, by confirming the veracity of the information provided with publicly available information, or by comparing the actual source of funds and operation of the account with the information provided during onboarding
e. Put in place appropriate risk management systems to determine whether a potential customer or existing customer or the beneficial owner is a PEP.
f. Where a customer has been accepted or has an ongoing relationship with MinieMoney and the customer or beneficial owner is subsequently found to be or becomes a PEP, the business shall obtain senior management approval to continue the business relationship (preferably from the Managing Director/Chief Executive or his alternate who must be an Executive Director).
g. Conduct enhanced and ongoing monitoring of the relationship and in the event of any transaction that is abnormal, shall flag the account and report the transaction immediately to the Nigeria Financial Intelligence Unit (NFIU) as a suspicious transaction.
h. Verification of the operating address of the company and signatories
i. Verification of the purpose of account opening by reviewing the transactions on the account to confirm that it is in line with the stated purpose.\
j. Ensure PEPs monthly returns are rendered to the CBN and NFIU

Where there are low risks, MinieMoney shall apply reduced or simplified measures. There are low risks in circumstances where:

a. the risk of money laundering or terrorist financing is lower.
b. information on the identity of the customer is publicly available; or
c. adequate checks and controls exist elsewhere in the national systems In circumstances of low risk, MinieMoney shall apply the simplified or reduced CDD measures when identifying and verifying the identity of their customers.
MinieMoney shall not apply the simplified CDD measures to a customer where there is suspicion or money laundering or terrorist financing or specific higher risk scenarios and in such a circumstance, enhanced Due Diligence is mandatory.
MinieMoney shall adopt CDD measures on a risk sensitive-basis and have regard to risk involved in the type of customer, product, transaction or the location or the customer.

MinieMoney shall:

a. ensure that documents, data, or information collected under the customer due diligence process is kept up-to-date and relevant by undertaking reviews of existing records, particularly for higher risk categories of customers or business relationships; and
b. scrutinize transactions undertaken during the relationship to ensure that the transactions are consistent with the knowledge of the customer, their business and risk profile and where necessary, the source of funds.
MinieMoney shall ensure that ongoing due diligence is performed based on a customer’s assigned risk rating. It must establish and maintain adequate procedures to ensure that all KYC information and supporting documents are reviewed and updated periodically where there is an ongoing business relationship with the customer. In this regard, as a minimum, periodic customer reviews must be performed in accordance with the following time periods.
a. high risk: on an annual basis.
b. medium risk: every two (2) years; and
c. low risk: every three (3) years.
Furthermore, the following events could trigger a need to review customer information:
a) a transaction of significant value takes place.
b) a customer documentation standard changed substantially.
c) there is a material change in the way that the account is operated.
d) MinieMoney becomes aware that it lacks sufficient information about an existing customer.
e) Where the customer voluntarily advises MinieMoney that its KYC information has changed; or
f) Where a staff member conducts a review on the customer in the normal course of business and ascertains that the customer information has changed.

MinieMoney recognizes the official sanctions list issued by competent authorities. The following official lists are recognized and embedded in MinieMoney’s sanctions screening system:

a) The United Nations Security Council Sanctions List.
b) The Office of Foreign Asset Control Sanctions List.
c) The European Union Sanctions List.
d) Her Majesty Treasury Sanctions List; and
e) Sanctions list developed by local regulators.
MinieMoney will ensure that prospective and existing customers and transactions are screened against relevant sanctions list and will not establish business relationships, discontinue existing business relationships and/or block funds where sanctioned individuals or entities are involved.

In accordance with local and international norms, it is an offence to fail to report a suspicion of money laundering and terrorist financing. Failure to report such circumstances is punishable on conviction by heavy fines and/or imprisonment. MinieMoney shall have an AML/CFT transaction monitoring system to enable MinieMoney to:

a. Monitor transactions for red flags of suspicious transactions.
b. Investigate potential suspicious transactions.
c. Report suspicious activities to the Nigerian Financial Intelligence Unit (NFIU).
d. Document and keep records of all suspicious transactions reported to the NFIU for the period specified by law; and
e. Avoid tipping off customers involved in suspicious transaction reports.
According to the Money Laundering Prohibition Act 2011 (as amended in 2012), a suspicious transaction is:
a) A transaction that involves a frequency which is unjustifiable or unreasonable.
b) A transaction that is surrounded by conditions of unusual or unjustified complexity.
c) A transaction that appears to have no economic justification or lawful objective; or
d) In the opinion of the Financial Institution or Designated Non-Financial Institution involves terrorist financing or is inconsistent with the known transaction pattern of the account or business relationship.

Monitoring of transactions for Suspicious Activities
MinieMoney shall have systems in place to monitor transactions with the aim of detecting, investigating, and reporting suspicious transactions of potential money laundering and terrorist financing.
Staff members, especially front-office and sales staff, shall receive adequate training to enable them to identify and report suspicious transactions to the Compliance Department.
Further, MinieMoney shall consider, based on its risk profile and regulatory requirements, implementing an automated system to monitor transactions for suspicious activities. The system shall be capable of monitoring all transactions consummated by MinieMoney on any its core applications and automatically generate alerts on suspicious transactions.

Investigation and Reporting of Suspicious Transactions
a) Staff members who identify a suspicious transaction shall immediately report their suspicions to the Compliance Department through the channels established for such reporting.
b) Staff members who report suspicious transactions or who have knowledge of a reported suspicious transaction are prohibited from informing the customer who is the subject of the report.
c) The Compliance Department shall have the responsibility to review all suspicious transactions reported by employees, and all suspicious transactions detected by any transaction monitoring system that MinieMoney may have implemented.
d) The Compliance Department shall, on a timely basis, report unresolved suspicious transaction to the NFIU.
e) The Compliance Department shall document and keep records of all suspicious transactions reported to the NFIU for the period specified by law and/or regulations.
f) It is very important that there is no delay in reporting. It is the duty of all employees to report suspicion as soon as they have established reasonable grounds and collected the relevant supporting material.
g) MinieMoney may make further enquiries within the parameters of its own records, but it does not need to carry out more detailed criminal investigations. It is the responsibility of law enforcement agencies to do so.

Protection of staff members who report suspicious transactions
Employees are advised to make their reports confidential, and no employee shall be victimized for making a report pursuant to this policy provided the report is made in good faith.

Know Your Employee (KYE)
In line with Section 38 of the Central Bank of Nigeria AML/CFT regulation 2013, employee accounts shall be monitored for potential signs of money laundering. In this regard, the account of the Chief Compliance Officer shall be reviewed by the Chief Internal Auditor. Where there is a violation involving the Chief Compliance Officer, employees shall report the violations to the Managing Director. MinieMoney’s KYE procedure shall include background screening for prospective employees, verification of references, experience, professional qualifications and obtain approval from the CBN. For Staff of the grade Assistant Manager (AGM) and above, clearance is to be obtained from the CBN prior to resumption of duty. Other Staff below the grade of AGM may assume duty without CBN’s prior approval but approval must be gotten within 30 days of their assumption of duty.

Tipping off
It is an offence for an employee of MinieMoney to “tip off” (i.e., inform) a person suspected of money laundering or terrorist financing that:

1. They or someone else has made a lawful disclosure (i.e., a suspicious transaction report); or
2. There is a money laundering investigation taking place, where the tipping off is likely either to prejudice any investigation arising from the disclosure or to prejudice the investigation disclosed to the person suspected of money laundering.
Under no circumstances should the customer know that they have been reported for the activity or transaction, or that an investigation is underway or may be underway. This does not mean that MinieMoney cannot ask the customer for an explanation or continue to provide them with normal customer service. But it does mean that MinieMoney must do so without alerting them to the fact that MinieMoney may or had already notified the Authorities. If customers being investigated are alerted, MinieMoney could be blamed for tipping them off, which is a criminal offence for the individual who alerted the customer to the existence of an actual or potential investigation.
The offence of tipping off is punishable on conviction by fines and/or imprisonment.

MinieMoney shall make timely regulatory returns to the appropriate regulators as required by extant laws and regulations including:

a. Foreign Currency Transaction Returns (Section 2 of the Money Laundering Prohibition Act 2011, as amended in 2012): A transfer to or from a foreign country of funds or securities by a person or body corporate including a Money Service Business of a sum exceeding US$10,000 or its equivalent shall be reported to the Central Bank of Nigeria, Securities and Exchange Commission or the Commission in writing within 7 days from the date of the transaction.
b. MinieMoney shall report to the Nigeria Financial Intelligence Unit any single transaction, lodgment, or transfer of funds more than N5,000,000 or its equivalent, in the case of an individual; or N10,000,000 or its equivalent, in the case of a body corporate.
MinieMoney shall ensure strict compliance with other AML reporting requirements

In line with relevant laws and regulations, MinieMoney shall maintain AML/CFT records as follows:

a. the record of a customer's identification for a period of at least 5 years after the closure of the account or the severance of relations with the customer; and
b. the record and other related information of a transaction carried out by a customer and suspicious transactions reported by MinieMoney to the relevant authorities shall be preserved, for a period of at least 5 years after carrying out the transaction or making of the report.
All records maintained should be available to authorized persons promptly on request without undue delays.
MinieMoney shall maintain all necessary records of transactions, both domestic and international for at least five years after completion of the transaction or such longer period as may be required by the CBN and NFIU, provided that this requirement shall apply regardless of whether the account or business relationship is on-going or has been terminated.
The components of records of transaction to be maintained by MinieMoney include the;
a) records of customer's and beneficiary's names, addresses or other identifying information normally recorded by the intermediary.
b) nature and date of the transaction.
c) type and amount of currency involved; and
d) type and identifying number of any account involved in the transaction.
MinieMoney shall maintain records of the identification data, account files and business correspondence for at least five years after the termination of an account or business relationship or such longer period us may be required by the CBN and NFIU,
MinieMoney shall ensure that all customer-transaction records and information are available on a timely basis to the CBN, SEC and NFIU.

All staff members are required to complete mandatory training and to ensure that it is recorded. Regulatory training in Nigeria is a requirement in respect of KYC/AML issues in terms of the Money Laundering Prohibition Act of 2011 (as amended in 2012), the Central Bank of Nigeria AML/CFT Regulations 2013 and the Securities and Exchange Commission AML/CFT Regulations 2013.
MinieMoney shall develop training programmes for staff covering compliance issues and as part of the orientation programmes for new staff and those posted to the front office, company operations and branch office staff, particularly cashiers, account opening, mandate, and marketing staff, internal control and audit staff and managers.
At a minimum, the basic elements of the employee training programme of MinieMoney shall include -

• AML Regulations and offences.
• the nature of money laundering.
• money laundering 'red flags' and suspicious transactions, including trade-based money laundering typologies
• reporting requirements
• Customer Due Diligence
• risk-based approach to AML and CFT; and
• record keeping and retention policy.
Some specific units may be provided with bespoke trainings addressing issues such as

• Trade finance risks and trade-based money laundering (TBML)
• Sanctions risks management
• PEP relationship management
Various training methods could be used to ensure that employees understand the topic in question. Methods include:

• Formal education
• E-learning (computer-based)
• Facilitator-led
• Presentations
• Email communications
• Induction programmes.
Compliance officers must ensure that the information contained in all material published in any of the above formats remains correct, relevant, and applicable.
The compliance function shall work with the Human Resources Department and other departments as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees and ongoing training for all employees and managers.
The Compliance Department must ensure that training records are obtained and filed for every training conducted.

The AML/CFT Compliance Programme of MinieMoney shall be subject to independent testing by the Internal Audit department for its adequacy, completeness, and effectiveness. MinieMoney has entrusted Internal Audit Department with the responsibility to test the implementation and adherence of company’s AML/CFT Policy. This examination is required to be conducted annually as part of the audit plan of the Internal Audit Department. The Internal Audit department shall also conduct risk-based internal audit and specific review of compliance with policies and procedures for PEPs and other high-risk clients and activities. This shall be conducted either as a separate audit exercise or as part of the overall audit of the Compliance Department. The findings/recommendations should be reported directly to the Chief Compliance Officer and the Board Audit Committee.
In addition, the Compliance Department should also carry out periodic assessments to verify among other things the implementation and adherence of the AML Policy in MinieMoney and report any noncompliance to the Board.

MinieMoney is committed to supporting the competent authorities in carrying out their statutory functions of combating financial crimes and terrorist financing. MinieMoney shall comply promptly with all the requests made pursuant to the provisions of relevant AML/ CFT laws and Regulations and provide all requested information to the CBN, NFIU and other competent authorities. All requests for from competent authorities must be immediately report to the Compliance Department for necessary action. The Compliance department may seek advice or support from any other department, such as the Legal department, in discharging this function.

MinieMoney shall have the right to terminate a business relationship with a customer due to suspicious activities, incomplete KYC documentation or other similar or related activities that company deems unacceptable. In such a situation where MinieMoney decides to terminate a business relationship, the following measures shall apply:

a) MinieMoney shall inform the affected customer in writing of its intention to terminate the business relationship with the customer. The notice period will be at least two weeks long or as may be advised by the Legal department.
b) The termination shall be jointly coordinated by the Compliance Department, the Legal Department, and the Business Unit responsible for managing the business relationship with the customer.
c) MinieMoney must consider if termination will not prejudice any ongoing or potential investigation of the customer by law enforcement agencies.
Deviations from the above procedure must be approved by the MD/CEO or his alternate who must be a director.

MinieMoney may outsource some or all its CDD functions to a third party. MinieMoney must satisfy itself that copies of identification data and other relevant documentation relating to the CDD requirements shall be made available from the third party upon request without delay. Notwithstanding the conditions, the ultimate responsibility for customer identification and verification shall be with MinieMoney.

All deviations from this Policy must be approved in writing by the MD/CEO for MinieMoney or his alternate who must be a director.

Failure to adhere to this Policy may lead to disciplinary action in line with the Disciplinary Policy of MinieMoney.
In addition, an employee may be held personally liable for civil or criminal penalties which include fines, payment of damages and/ or imprisonment.
Employees may also report breaches of this Policy directly via the Whistleblowing Channels. MinieMoney has several Independent Third-Party Hotlines for reporting unethical practices.
Independent Third-Party Hotlines (managed by [kindly populate with the details of the independent third parties)
· Telephone Numbers:
· Email Address:
· Web Link: [Please insert link]
The telephone line will be manned between 8.00 am and 5.00 pm on workdays only while the e-mail address and web link will be available always except during periods of maintenance.
The officers manning the Whistleblowing hotline will submit periodic reports to the designated officers of MinieMoney Compliance Department, which is responsible for receiving and actioning such reports.

Central Bank of Nigeria Hotlines
· Telephone Numbers:
· Email Address:

MinieMoney’s failure to adhere to this Policy may lead to penalties in line with the Central Bank of Nigeria (CBN) sanctions/fines to preserve Anti- Money Laundering and Combating the Financing of Terrorism (AML/CFT) regulations which stipulates fines on financial institutions, their directors, and other key officials for 48 Money Laundering infractions.
The administrative sanctions shall apply for contravention of the following laws/regulations:

a. Money Laundering (Prohibition) Act, 2011 (as amended)
b. Terrorism (Preventions) Act, 2011 (as amended)
c. Terrorism Prevention (Freezing of International Terrorists Funds and Other Related Measures) Regulations 2013
d. Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism for Financial Institutions in Nigeria) Regulations, 2013
Under the new sanction’s regimes, MinieMoney, Board Members, Executive Compliance Officer, Chief Compliance Officer, Chief Risk Officer, Chief Internal Auditor, and any employee that breaches AML/CFT requirements shall be subject to applicable sanctions by the CBN in line with the CBN AML/CFT (Administrative Sanctions) Regulation 2018 as detailed in Appendix III.