Accordingly, BeepPay affirms its commitment to comply with Anti-Money Laundering and Combating Financing of Terrorism Policy under extant laws and regulatory directives. These include without limitation the regulatory obligations and requirements under the Money Laundering (Prohibition) Act 2011 (as amended); the Terrorism (Prevention) Act of 2011 (as amended), the Central Bank of Nigeria (CBN) AML/CFT Regulations 2013; the Terrorism Prevention Regulations 2013, the Financial Action Task Force (FATF) recommendations; and all other relevant regulations and principles relating to AML/CFT as may be prescribed by regulators. For this purpose, we will actively prevent any transaction that otherwise facilitates criminal activity or terrorism and our internal control systems and procedures have been structured to identify such potential incidences and to prevent criminals from using our facilities for money laundering and terrorist financing.
Purpose and Overview of the AML/CFT Policy
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 crime. Financing of Terrorism (FT) is defined here to include both legitimate and illegitimate money characterized by concealment of the origin or intended criminal use of the funds. We support and cooperate with the concerted global efforts to enhance monitoring and surveillance systems with a view to preventing, detecting and responding appropriately to money laundering and terrorist financing.
We have provided this Policy to you our Customers for guidance, to establish the essential standards which will be applied in all transactions and to inform you of your obligation to cooperate with us and regulators to promptly report suspicious transactions and activities which compromise the AML/CFT framework. The key areas of the AML/CFT Policy are highlighted as follows:
Our Internal AML/CFT Compliance Responsibilities:
Our Board of Directors has oversight function over the AML/CFT Policy implementation. However, the Board has further constituted a Compliance Unit supervised by a Director of Compliance who exercises daily oversight function on the operation of the Compliance Unit and reports to the Board of Directors. The Compliance Unit receives and vets suspicious transaction reports, files suspicious transaction reports with the CBN and NFIU, engages in the continuing process of developing and co-ordinates initiatives for AML/CFT awareness, detection methods and reporting.
Know Your Customer (KYC) principles:
The Company promotes the Know-Your-Customer as a foundation for business ethics and practices. Accordingly, we ensure that due diligence and KYC requirements are carried out on all new customers. These include, but are not limited to obtaining proof of identity (name and address), verification of the identity using reliable, independent source documents, data or information and where the customer is believed not to be acting on his or her own account, information on the true identity of the principal is sought and obtained.
We also verify and maintain records on the nature of business carried out by the customer and the financial status of the customer. This is to enable us identify any significant change in pattern or any unusual transaction pattern. Our Affiliates and Agents are also required to scrutinize all on-going transactions undertaken by the customer during the duration of the relationship in order to ensure that the customer’s transactions are consistent with the business and risk profile of the customer. The Company takes the requisite regulatory measures when dealing with politically exposed persons and other high risk customers.
We pay special attention to all complex, unusual large transactions or unusual patterns of transactions that have no apparent or visible economic or lawful purpose. Examples of such transactions or patterns of transactions include significant transactions relative to a relationship, transactions that exceed certain limits, very high account turnover inconsistent with the size of the balance or transactions which fall out of the regular pattern of the transaction activity. We will examine as far as possible the background and purpose of such transactions and report such findings to the CBN, NFIU, SCUML and other competent authorities. The main objective of our transaction monitory procedure is to ensure the timely identification of significant changes in patterns or unusual transaction behaviour. This would also enable us conduct further investigation that would ascertain if such transactions can be classified as 'suspicious' and disclosed to the relevant authorities. Monitoring unusual transactions is the collective responsibility of all Affiliates of the Company.
International best practice and regulatory requirements stipulates that certain reports and returns are made to regulatory bodies. In Nigeria, the Nigerian Financial Intelligence Unit (NFIU) is the regulatory agency responsible for receipt of the following core transaction based reports: Currency Transaction Report (CTR), Foreign Currency Transaction Report (FTR), Suspicious Transaction Report (STR) .
Co-operation with Regulators and Law Enforcement Agencies
We co-operate fully with regulators and law enforcement agents and make available required documents/information as requested by the relevant regulatory or law enforcement agencies, based on the powers conferred on these agencies by the provisions of the Act. The Company will not use confidential or secrecy laws to inhibit implementation of any request from regulators but will promptly comply with all requests made, pursuant to the law, and provide information to regulators. Upon receipt of a regulatory request for information or document, we will conduct a search on our database with a view to promptly providing the required information or document where available. Confidentiality and security of such requests must be protected at all times.
Customer Risk Assessment
There is no universal consensus as to which customers pose a higher risk, but the below listed characteristics of customers have been identified with potentially higher money laundering risks and we apply stricter due diligence measures in such situations:
- arms manufacturing,
- cash intensive business;
- unregulated charities and other unregulated "non-profit" organizations
Politically Exposed Persons (PEPs)
Enhanced measures of due diligence are applied to high-risk customers such as PEPs to ensure that the Company is not unknowingly supporting fraudulent activities such as money laundering and/or the financing of terrorism. In line with FATF's recommendation, the Company employs the use of appropriate discretionary risk based systems based on the definition of a PEP which includes all persons that might have some form of relationship with an actual current political office holder or all persons who have been political office holders at one time or another. This is achieved through the thorough review of details provided by the customer and transaction trends which help in determining which customers should be classified as PEPs.
Scope of Offensive Proceeds
BeepPay identifies and reports to relevant regulators the following:
- Suspicious property ownership regardless of its value,
- Serious offences of participation in organized criminal group and racketeering;
- Offence of association with or conspiracy to commit, attempt, aiding and abetting, facilitating and counselling the commission;
- and other categories of offences that may be designated under any law applicable in Nigeria.
Attention for Higher Risk Countries
We give special attention to business relationships and transactions with persons (including legal persons and other financial institutions) from or in countries which do not or insufficiently apply the FATF recommendations. We report transactions that have no apparent economic or visible lawful purpose.
Customer Due Diligence and Know Your Customer Requirement and Guidance
We do not establish business relationship until all relevant parties to the relationship have been identified and the nature of the business they intend to conduct ascertained. However, where there is an on-going business relationship, we examine any inconsistent activity to determine whether or not there is an element of money laundering or any criminality.
Accordingly, we do the following:
- obtain documentary proof of identification and address to ascertain that a prospective customer is who he/she is or claims to be and can be found at the address indicated.
- ascertain the nature and level of the business the Customer intends to undertake, including the expected or predictable pattern of transactions,
- Assess customer risk
- establish the customer identity at all times as far as the business relationship subsists for the purpose of confirming and updating identity and address,
- establish whether the Customer is acting on behalf of another natural person or legal entity as trustee, nominee or professional intermediary. In such cases a necessary precondition for Customer acceptance is receipt of satisfactory evidence of the identity of any intermediaries and of the persons upon whose behalf they are acting, as well as the nature of the trust arrangements in place.
Record Keeping and Retention Policy
The Company maintains a secured storage of all documents and transaction records. Customer identification documents are retained throughout the life of the account and for five (5) years after the cessation of the relationship, except in cases of litigation and/or regulatory investigations. In the case of the latter, the records will be kept for as long as they are required.
Please note that BeepPAY Transactions Limited under aforementioned laws has the right to refuse a transaction at any time should suspicion arise that it may be connected to money laundering or any other criminal activity. In addition, BeepPay Transactions Limited will be obliged to report this suspicious activity in order to comply with said regulations and laws.
Providing us with false identification or contact details will be deemed as a breach of our terms of service and we are legally bound to report such conducts to the Nigeria authorities and you may be exposed to criminal investigation and prosecution.
BeepPAY Transactions Ltd will NOT do business with anyone suspected of, or directly involved in Money Laundering, or where funds have been sourced by any illegal activity.
I have read BeepPay Transactions Limited’s Anti-Money Laundering and Combating Financing of Terrorism Policy “the Policy” and understand and accept all the terms and conditions contain therein. I also agree to be bound by obligations under the policy and other applicable laws and regulations on Anti-Money Laundering and Combating Financing of Terrorism.