ANTI-MONEY LAUNDERING AND COUNTER-FINANCING OF TERRORISM POLICY

Last Updated: December 2020

The Paylot Technologies Limited (“Paylot”) Anti-Money Laundering (“AML”) and Counter-Financing of Terrorism (“CFT”) Policy is designed to prevent money laundering, including the need to have adequate systems and controls in place to mitigate the risk of Paylot and its products being used to facilitate financial crime.

POLICY STATEMENT

These AML and CFT Policy and Procedures adopted by Paylot are in compliance with the Money Laundering (Prohibition) Act, the Money Laundering (Prohibition) (Amendment) Act, the Economic and Financial Crimes Commission Act and the Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism in Banks and Other Financial Institutions in Nigeria) Regulations, the Recommendations of the international Financial Action Task Force (FATF) as at 1 December 2014 and other Acts which impose significant obligations in relation to AML/CFT procedures. As used in this AML Policy, "Paylot", "we", "us" or "our" refers to Paylot Limited, registered with the Corporate Affairs Commission (CAC) of the Federal Republic of Nigeria, with its registered address at No. 19 Garden Avenue, GRA, Enugu, Nigeria. Paylot is a data controller under this AML Policy, which sets out the manner in which Paylot, as data controller, may use your Personal Data.

Paylot will actively prevent and take measures to guard against Obiex Finance being used as a medium for money laundering and financing terrorism activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

This AML and CFT Policy sets out the minimum standards which must be complied with and includes:

  • The appointment of an Anti- Money Laundering and Counter Financing REPORTING Officer (AMLCFTRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to Paylot;
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
  • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • The maintenance of appropriate records for the minimum prescribed periods;
  • Training and awareness for all relevant employees.

Counter Financing of Terrorism (CFT)

Paylot takes a risk-based approach when adopting and implementing Counter Financing of Terrorism (CFT) measures and in conducting AML risk assessments.

Paylot's adopted internal CFT controls and undefended decisions regarding CFT matters supersedes any business, strategic or other operating tasks.

Know Your Customer (KYC) Procedures

Individuals can be identified by passport or other identification document and utility bills stating their current post address. Companies have to be identified by extracts from the Memorandum and Articles of Association or by Incorporation Certificate from CAC. Copies have to be made and archived in files securely.

To this end:

The identities of all new and existing customers will be verified to a reasonable level of certainty;

  • A risk-based approach will be taken to the monitoring of customers.
  • Any suspicious activity will be reported, and all AML activities recorded.
  • Paolo Abamwa (amlcftro@paylot.co) will act as the Anti Money Laundering and Counter Financing of Terrorism Reporting Officer (AMLCFTRO) to coordinate the AML policies and procedures of the business.
  • All staff that meet or contact customers and potential customers of Paylot are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting customers.

ANTI-MONEY LAUNDERING PROCEDURES FOR ONBOARDING CUSTOMERS

1. CUSTOMER DUE DILIGENCE

Paylot has established a Know-Your-customer (KYC) policy to ensure that the identities of all new and existing customers are verified to a reasonable level of certainty. This will include all individual customers, all directors and shareholders with a stake holding of 25% or more of customer companies, all partners of customer partnerships, and every board member of customer charities.

  1. Proof of Identity showing First & last name, Date of Birth, Date of issue & Expiry, and Document number (list of acceptable documents below):
    • Current Valid Passport (Top and Bottom page)
    • Current Valid Driving License (Front and Back side)
    • Current valid government-issued identity card such as National ID, Voter's Card (Front and Back side)
  2. Proof of Address showing First & last name, Address, and Date of issue (list of acceptable documents below):
    • Bank, debit card, credit card or mortgage statement dated within the previous three calendar months (either hard copy or electronic statements are acceptable)
    • Statement may be in the joint name of the buyer and his/her partner.
    • Utility (water, gas or electricity), telephone landline, cable dated within the previous three calendar months (either hard copy or electronic statements are acceptable
    • Rental Agreement dated within the previous three calendar months
    • Tax Statement
  3. Bank Account Verification (list of acceptable documents below):
    • For Personal Bank Account

  4. Bank Statement showing Name, Account Number and SWIFT/BIN/Sortcode (either hard copy or electronic statements are acceptable)

    • Business Bank Account
  5. Company Name & RegistrationNumber that can be verified with the CAC.
  6. Director or Owner listed with the company.

  7. A business debit card issued under their name to prove they are an account signatory.

    OR

    • Bank statement showing Name, Account Number and SWIFT/BIN/SortCode (either hard copy or electronic statements are acceptable).
    • For Sole Trader Business Bank Account.
  • A business debit card issued under their name to prove they are the account holders
  • Business Bank statement dated within the previous three calendar months showing the Business Name they are “Trading as” (either hard copy or electronic statements are acceptable).
    Or Tax documentation under the Business name dated within the previous three calendar months.
  • Or Bank Verification Number (BVN).

    • 2. RISK ASSESSMENT AND ONGOING MONITORING

    Paylot shall take a risk-based approach in monitoring the financial activities of its customers. This will be carried out whilst preparing the accounts, or conducting any other business with the customer.

    Paylot will classify all Users as high-risk, medium-risk or low-risk, and will periodically update the KYC records for all Users as follows:

    i. once every two years for high-risk Users;

    ii. once every eight years for medium-risk Users; and

    iii. once every ten years for low-risk Users.

    The business will actively not accept high-risk customers that are identified as follows:

    • customers with complex business ownership structures with the potential to conceal underlying beneficiaries.
    • Situations where the source of funds for large transactions cannot be easily verified.
    • Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
    • Money sent to or received from areas known to have high levels of criminality or terrorist activity.

    Paylot will conduct ongoing monitoring of business relationships with customers, to ensure that the documents, date or information held evidencing the customer’s identity are kept up to date.

    The following are examples of changes in a customer’s situation that may be considered suspicious:

    • A sudden increase in business from an existing customer;
    • Uncharacteristic transactions which are not in keeping with the customer’s known activities;
    • Peaks of activity at particular locations or at particular times;
    • Unfamiliar or untypical types of customer or transaction.
    • Whenever there is cause for suspicion, the customer will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.
    • No action need be taken if there is no cause for suspicion.

    3. INTERNAL CONTROLS AND COMMUNICATION

    Internal controls and Communication are not applicable as the business only has one employee (Paolo Abamwa) involved in customer compliance and they are also the AMLCFTRO (amlcftro@paylot.co).

    4. TRANSACTION MONITORING AND MANAGING COMPLIANCE

    The AMLCFTRO will regularly monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of the business:

    • customer identity verification;

    • reporting suspicious transactions;

    • record keeping.

    The AMLCFTRO will also monitor any developments in the AML and CFT regulation and the requirements of the AMLR supervisory body. Changes will be made to the AML policies and procedures of the business when appropriate to ensure compliance.

    5. SUSPICIOUS ACTIVITY REPORTING

    A Suspicious Activity Report (SAR) will be made to either the Economic and Financial Crimes Commission (EFCC), the National Drug Law Enforcement Agency, the Central Bank of Nigeria, the Nigeria Police Force, the Nigerian Customs Service or any other competent authority as soon as the knowledge or suspicion that criminal proceeds exist arises.

    The AMLCFTRO will be responsible for deciding whether or not the suspicion of illegal activity is great enough to justify the submission of a SAR.

    6. RECORD-KEEPING

    Records of all identity checks will be maintained for up to 5 years after the termination of the business relationship or 5 years from the date when the transaction was completed. The business will ensure that all documents, data or information held in evidence of customer identity are kept up to date. Copies of any SAR, together with any supporting documentation filed will be maintained for 5 years from the date of filing the SAR.

    All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.

    7. TRAINING

    The training of staff is not applicable as the business only has one employee involved in AML compliance who is also the AMLCFTRO.

    All affected employees are provided with training that explains the Money Laundering (Prohibition) Act, the Money Laundering (Prohibition) (Amendment) Act, the Economic and Financial Crimes Commission Act and the Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism in Banks and Other Financial Institutions in Nigeria) Regulations, the Recommendations of the international Financial Action Task Force (FATF) as at 1 December 2014 and other Acts which impose significant obligations in relation to AML/CFT procedures and how these affect Paylot, its customers and its employees.

    All affected employees are trained on their responsibilities in relation to money laundering and counter financing of terrorism legislation, and are aware of how to identify and deal with transactions that may involve money laundering and financing of terrorism.

    8. INTERNATIONAL SANCTIONS AND MONITORING POLICY (ISMP)

    Paylot is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Paylot will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists.

    9. PEPs AND ENHANCED DUE DILIGENCE CHECKS

    “Politically exposed persons” means natural persons ‘who is or has, at any time in the preceding year been entrusted with a prominent public function by a state or Country other than Nigeria, a community institution or an international body’ or a family member or known close associate of such a person.’

    • Individuals who have, or have had, a high political profile, or hold, or have held, public office, can pose a higher money laundering risk to Paylot as their position makes them vulnerable to corruption. This risk also extends to members of their immediate families and to known close associates. PEP status itself does not, of course, incriminate individuals or entities. It may, however, put a customer into a higher risk category.
    • An individual is not considered to be a PEP, after he has left office for one year.
    • Enhanced Due Diligence Checks have been specifically designed for dealing with Politically Exposed Persons, high-risk or high-net worth customers and large transactions
    • They take into consideration all relevant adverse information. Whether an official document or something posted publicly on the Internet, any information that pertains to money laundering and financing of terrorism is thoroughly considered.

    10. CONTACT US

    Please contact us with questions, comments, or concerns regarding our AML/CFT Policy at amlcftro@paylot.co

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