Introduction
Nuach Consults recognizes the importance of preventing money laundering and terrorism financing and is committed to the highest standards of Anti-Money Laundering and combating terrorist financing in Nigeria.
Nuach Consults, as a designated non-financial institution (DNFI), is subject to applicable legislation designed to prevent money laundering. This legislation includes legislation such as: Terrorism Prevention Act 2103, Money Laundering Prohibition Act, 2011 (as amended), and others.
To fulfill this commitment, Nuach Consults has established internal policies and procedures. This Policy establishes standards that every employee, contractor, and business partner of Nuach Consults should observe.
Scope
Money laundering is the process of any activity by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins.
Criminal proceeds may take any form, including money or money’s worth, securities, tangible property, and intangible property.
Terrorism financing is defined as providing, depositing, distributing, or collecting funds, directly or indirectly, intended to be used, or knowing that these funds are to be wholly or partially used, for the committing of terrorist acts.
This Policy is aimed at preventing any company or individual from using Nuach Consults for money laundering or terrorist financing activities.
Our Policy
Customer Due Diligence
To prevent Money Laundering, Nuach Consults will implement processes and procedures in its Line of Businesses (LOBs) to conduct appropriate client due diligence through the Nuach Consults’ Business Partner Screening Questionnaire, identifying the client and verifying the customer’s identity on the basis of the following “Know Your Customer” principles, to wit:
i. Customer-provided documentation (Verification Checking)
ii. Information on the client obtained from reliable and independent sources (Ownership Checking);
iii. Compliance with Nuach Consults’ Business Codes.
Unusual activity during the client’s due diligence process or customer engagement should be reported immediately to the designated Nuach Consults’ compliance department.
Risk-Based Approach
For Nuach Consults, the threat of being involved in money laundering and terrorist financing activities depends directly on the type of business that Nuach Consults’s clients carry out or on the country where Nuach Consults’s clients are located.
Nuach Consults will classify its clients based on a risk level in its applicable line of business processes and procedures. Identifying the potential risk will help to effectively manage these risks by implementing controls to mitigate the identified risk, if any.
High-Risk Clients
Nuach Consults will not do business with the following segments of customers:
i. Persons included in any official lists of sanctions, in line with the Nuach Consults Sanctions Policy;
ii. Persons indicating possible involvement in criminal activities, based on available information about them;
iii. Persons with businesses in which the legitimacy of activity or source of funds cannot be reasonably verified;
iv. Persons refusing to provide the required information or documentation, or
v. Entities whose shareholder/control structure cannot be determined.
Record Keeping
Client documentation can either be submitted in physical or electronic form. An appropriate record of the received documentation, steps taken, and copies of, or reference to, the documentation of the customer must be kept.
Records should be kept for as long as the relationship endures with the client and for at least five (5) years after the relationship ends.
Designation of Anti-Money Laundering Reporting Officer (AMLO)
Nuach Consults will designate an Anti-Money Laundering Officer. The Anti-Money Laundering officer will be responsible for:
i. Considering internal reports of money laundering,
ii. Reporting suspicions of money laundering to the responsible authorities;
iii. Acting as key liaison with the money laundering authorities;
iv. Training the business and its employees on money laundering;
v. Submitting weekly reports to the Special Control Unit Against Money Laundering (SCUML);
vi. Advising on the procedure after a report of suspicion of money laundering has been raised; and
vii. Designing and implementing Anti-Money Laundering processes and procedures.
Reporting Suspicious Activity
Nuach Consults expects that, if any employee, contractor, or business partner becomes aware of any suspicion or knowledge of possible money laundering activity, this is reported without undue delay to the AMLO.
This can either be done by contacting the AMLO or his deputy directly.
A report on suspicious activity should contain, at least, the following information, which will be confirmed by the AMLO:
- Identity of the person raising the suspicion;
- Date of the report;
- Who is suspected of money laundering or terrorist financing activities;
- Other individuals involved otherwise;
- Deliverance of facts;
- What is suspected and why; and
- Any possible involvement of Nuach Consults.
The AMLO may make reasonable enquiries within Nuach Consults to confirm these suspicions or obtain additional information. After this assessment, the AMLO will determine whether or not it is necessary to file an official report to the responsible money laundering authority.
Details of internal reports will be held by the AMLO separately, excluded from customer files, to avoid inadvertent or inappropriate disclosure.
Training
Nuach Consults has a strong commitment to compliance, and all employees and contractors are required to complete mandatory compliance training, including anti-money laundering provisions, annually.
Job-specific and comprehensive anti-money laundering training should be provided to the relevant employees to help recognize and deal with transactions that may lead to money laundering or terrorist financing.
Policy Review and Audits
Regular reviews of the effectiveness of this Policy are carried out in addition to audits periodically undertaken by the Nuach Consults Internal Audit function.
This provides Executive Management and the Board Audit Committee with the necessary assurance and information regarding the operating effectiveness of Nuach Consults’s controls and processes relating to this Policy.