INTRODUCTION
By definition, Anti-money laundering refers to the regulations, laws and procedures used in curbing criminals from disguising money obtained illegally as legal. Despite the fact that Anti-money laundering covers a restricted scope of financial exchanges and criminal conduct, their implications are expansive. For instance, AML guidelines require banks and other monetary foundations that issue credit or accept client’s deposits to adhere to rule as that guarantee they are not aiding money laundering.
These rules allow financial institutions to monitor customers’ transactions and report on suspicious financial activities. ‘Suspicious activities’ is a quite ambiguous term to characterize on the grounds that it can vary from one financial exchange to another based on every one of the conditions encompassing the financial exchange or group of financial exchanges. For instance, transaction by one client might be normal from our own point of view while similar transaction by another client might be suspicious. A number of considerations are involved in ascertaining whether transactions are suspicious. These include, the amount, the nature of the transaction and frequency of deposits/withdrawals from the system.
Cardvest Nigeria Limited is obligated to fighting money laundering and abiding fully with anti-money laundering laws in the Nigeria. We understand beyond reasonable doubts and accept our responsibilities to help in the global fight against money laundering. These commitment will overrule all other privacy responsibilities present in our policies.
Cardvest will not hesitate to take all reasonable and appropriate steps to block individuals involved in money laundering, fraud, or other financial crimes from using our products and services.
Our AML policies, procedures and internal controls have been prepared to guarantee adherence with all applicable BSA regulations and FINRA rules and will be reviewed and updated regularly to guarantee appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our services. Key components of our AML and CTF framework include the following:
RISK MANAGEMENT – Anti-money Laundering
We have prepared an independent around the clock risk management. Their utmost purpose being to report to the board of directors regularly all risk and compliance issues using a risk-based approach to the evaluation and management of money laundering and terrorist financing risks and 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.
INTERNAL CONTROL
This office sees to the implementation of procedures that will prevent criminals from using Cardvest’s services for money laundering and terrorist financing. They also guarantee that Cardvest’s responsibility under subsisting laws and regulations are met.
COMPLIANCY
This office has been specifically set aside to supervise and coordinate day-to-day compliance with the applicable legislation, regulations, rules and industry guidance as well as applicable money laundering laws and regulations. They keep the stakeholders on track by regularly communicating all AML issues.
They provide timely preparation and delivery of all relevant returns to the regulatory bodies in line with SEC and FIU Rules and Regulations. They also monitor closely all transactions to detect any unusual suspicious activities.
CUSTOMER/USER MANAGEMENT
Here is where we get to know our users. We do this by creating and managing a risk-based approach to Customer Due Diligence (CDD), including customer identification, verification and KYC procedures. In order for us to do this, our customers/users are required to provide certain personal information when creating a Cardvest account and also generate tokens, OTP and PIN for any withdrawal request. The nature, and extent, of what is required is prompted by the customer’s transactions, account to be used and in some cases, the customer’s country of residence.
Occasionally, Cardvest may perform heightened due diligence procedures for customers exhibiting a higher risk, such as those transacting large volumes.
Cardvest shall diligently identify and report any suspicious transaction. Suspicious transactions shall include:
I. Transactions which are integrated to avoid reporting and record keeping requirements.
II. Altered or false identification or inconsistent information or any transaction involving criminal activity in Cardvest’s view.
III. Transaction that belongs to a person or organization considered as terrorist.