Anti-Money Laundering and Countering the Financing of Terrorism Policy for Bramp Africa Limited.
Sections 1–2
Bramp Africa Limited (the "Company") is a private company limited by shares registered under the laws of the Federal Republic of Nigeria that provides digital products and services.
This Policy serves as a comprehensive guide for the employees, management, and partners of the Company to establish measures that prevent it from being used as a channel for money laundering activities. Its primary objective is to equip the staff and management with essential knowledge about the Company's anti-money laundering and counter-terrorism financing (AML/CFT) prevention framework, thereby reducing the risks associated with such illegal activities.
The Company is fully dedicated to upholding compliance with all relevant local and international laws, regulations, and standards mandated by authorities concerning the prevention of money laundering and terrorist financing.
The broad definition of money laundering means that potentially anyone could commit a money laundering offence, and this includes all employees of the Company.
Our Policy is to enable the Company to meet its legal and regulatory requirements in a way which is proportionate to the risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring.
All employees must be familiar with their legal responsibilities and failure to comply with this Policy may lead to disciplinary action.
As a result, the employees of the Company shall be vigilant for any suspicious activity and report it immediately to the compliance officer for immediate reporting to the Nigerian Financial Intelligence Unit (the NFIU) of the Economic and Financial Crimes Commission (EFCC), in accordance with specified policies and procedures, so that they may in turn notify the relevant authorities.
Adherence to this Policy is absolutely fundamental to ensuring that the Company comply fully with anti-money laundering and terrorism financing legislations. Employees are required to be actively involved in the implementation and development of this Policy.
Section 3
The relevant legislations are the Money Laundering (Prevention and Prohibition) Act, 2022, the Terrorism (Prevention and Prohibition) Act 2022, the Anti-Money Laundering, Combating the Financing of Terrorism and Countering Proliferation Financing of Weapons of Mass Destruction in Financial Institutions Regulations, 2022, and the National Insurance Commission Anti-Money Laundering and Combating the Financing of Terrorism (NAICOM AML/CFT) Regulations 2013.
Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: participation in an organised criminal group or racketeering; terrorism, including terrorism financing; financing the proliferation of weapons of mass destruction; bribery; corruption; fraud; etc.
Terrorism financing is defined as the providing, depositing, distribution or collecting of funds, by any means, directly or indirectly, intended to be used, or knowing that they are to be wholly or partially used, for the committing of terrorist acts.
There are also several secondary offences, such as failure to disclose knowledge or suspicion of money laundering to the Compliance Officer (CO); failure by the CO to disclose knowledge or suspicion of money laundering to the Nigerian Financial Intelligence Unit; and 'tipping off' whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.
Any member of staff could potentially be caught by the money laundering provisions, if they suspect money laundering and either become involved with it in some way, and/or do nothing about it. This Policy sets out how any concerns should be raised.
Sections 4–5
The Company will appoint a CO to receive disclosures about money laundering activity and be responsible for anti-money laundering activity within the Company. The officer nominated to do this is Aloaye Daniel.
The CO will ensure that appropriate training and awareness is provided to new and existing employees of the Company and that this is reviewed and updated as required.
The CO will ensure that appropriate anti-money laundering systems and processes are incorporated by the Company.
The Company considers that the potential threat of becoming involved in any money laundering or terrorism activity is directly related to the type of business carried out by the Company and that such threat can be more effectively and efficiently managed if the potential risk linked to the business and products of the Company is known before.
Classifying its products by risk levels shall enable the Company to design and implement measures and controls to mitigate such risk. Likewise, it shall enable the Company to focus on those business lines and products that present greater risk. The Company shall apply a procedure that shall enable them to determine the risk of the business lines in which they participate and the products they distribute, with respect to money laundering or terrorism financing.
Risks inherent in money laundering or terrorism financing can be managed more effectively and efficiently if the potential risk linked to the different types of customers and their transactions is known beforehand. The Company shall design a procedure, based on the risk consideration of their own business, which shall provide an appropriate framework for segmenting their own customers by levels of money laundering or terrorism financing risk.
In compliance with the international standards on countering money laundering and the financing of terrorism & proliferation based on FATF Recommendation 1, the Company shall apply a risk-based approach (RBA) to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified.
Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction.
The Company shall adopt a risk-based approach in respect of profiling AML/CFT along the following lines: a. Client; b. Geographies; c. Product & services; and d. Distribution channels.
For money-laundering and terrorism financing risk control purposes, the Company shall not accept the following categories of customers:
Clients classified as Political Exposed Persons (PEPs) shall only be accepted as customers with prior authorization from any member of senior management in line with regulation 9(7) of the NAICOM AML/CFT 2013.
The most effective means of preventing the use of the financial system for money laundering or terrorism financing is to identify and know your customers, regardless of whether they are established customers or otherwise.
Along these lines, the Company shall establish regulations, procedures, and internal controls aimed at obtaining effective and complete knowledge of their customers and their activities, in order to:
For customer identification, the Company shall consider the following criteria:
In these cases, all requirements must be fulfilled, including identification of the beneficial owner of the account, in accordance with the provisions of established AML/CFT regulations. The Company shall have procedures for determining that person's identity and relationship to the customer.
Sections 6–8
All employees must immediately and as soon as possible report any knowledge of or suspicion of (or where there are reasonable grounds to suspect) suspicious activity to the CO in the prescribed form as set out in this policy document.
Once the matter has been reported to the CO, the employee must follow the directions given to him/her and must NOT make any further enquiry into the matter.
The employee must NOT voice any suspicions to the person(s) whom they suspect of money laundering, as this may result in the commission of the offence of "tipping off". They must NOT discuss the matter with others or note on the file that a report has been made to the CO in case this results in the suspect becoming aware of the situation.
Once the CO has received the report, it must be evaluated in a timely manner in order to determine whether: There is actual or suspected money laundering taking place; or There are reasonable grounds to know or suspect that this is the case; and Whether the CO needs to lodge a Suspicious Activity Report (SAR) with the NFIU.
Where the CO concludes that there are no reasonable grounds to suspect money laundering, then consent will be given for any on-going or imminent transaction(s) to proceed.
Where consent is required from the NFIU for a transaction to proceed, then the transaction(s) in question must not be undertaken or completed until the NFIU has given specific consent, or there is deemed consent through the expiration of the relevant time limits without objection from the NFIU.
All disclosure reports referred to the CO and reports made to the NFIU will be retained by the CO in a confidential file kept for that purpose, for a minimum of 5 years. The CO must also consider whether additional notifications and reports to other relevant enforcement agencies should be made.
Due diligence is performed on all customers of the Company who must provide basic information including full name, residential/business address, date of birth, and registration details for corporate bodies.
It may be necessary for the Company to carry out enhanced due diligence on certain customers where the customer or a transaction involving the customer appears to be "high risk". The following non-exhaustive list of situations may indicate a "high risk": a new customer; a customer not well known to the Company; customers in known high risk industries and/or jurisdictions; transactions that are unusual or appear to be unusual for that customer; highly complex transaction or payment arrangements; companies that have nominee-shareholders or shares in bearer form; legal persons or legal arrangements such as trusts that are personal assets-holding vehicles; cross-border and banking and business relationships; the transaction involves a politically exposed person ("PEP") or an immediate family member or a close associate of a PEP; and no face-to-face meetings take place with the customer where this is usually expected.
Employees must assess the money laundering risk for each customer and if you suspect enhanced due diligence is required, you should speak to the CO before continuing any engagement with the customer.
If enhanced due diligence is carried out, the CO must: obtain additional information on the customer and on the customer's beneficial owner(s); obtain additional information on the intended nature of the business relationship; obtain information on the source of funds and source of wealth of the customer and customer's beneficial owner(s); and conduct enhanced monitoring of the business relationship.
If satisfactory evidence of identity is not obtained at the outset, then the business relationship or one-off transaction(s) cannot proceed any further. A report should be filed with the CO who will then consider if a report needs to be submitted to the NFIU.
Section 9
Where the Company reasonably suspects that the source of funds is the proceeds of criminal activity, it shall report its suspicion to the NFIU immediately and all suspicious transactions including attempted transactions shall be reported regardless of the amount involved and the report shall include any action taken on the suspicious activity.
Where the Company reasonably suspects that a transaction is linked with terrorism, it shall report its suspicion to NFIU immediately and without delay but not later than 24 (twenty-four) hours.
Similarly, it shall amount to reasonable suspicion, where the Company has reasonable grounds to suspect that the funds in question:
Currency Transaction Reporting (CTR) timeline: immediately but not later than 7 (seven) days of occurrence.
The Company is under obligation to file all Currency Transaction Reports (CTRs) above the statutory threshold to the NFIU:
Where there are no instances of suspicious and currency transactions, the Company shall file a NIL report for industry regulatory compliance purposes.
Sections 10–14
Employees should review customers at regular intervals to ensure that the risk level of each customer's information and information held on each customer is not only accurate and up to date, but is consistent with the knowledge of the customer and its business. Further due diligence may be required if new people become involved as a customer. Any suspicious activity must be reported to the CO.
Customer details must be collected in accordance with the Nigeria Data Protection Regulation 2019 and the Nigerian Data Protection Act 2023. This data can be "processed" as defined under the Nigeria Data Protection Regulation 2019 to prevent money laundering and terrorist financing.
Customer identification evidence and details of any relevant transaction(s) for that customer must be retained for at least 5 (five) years from the end of any business relationship with that customer.
In compliance with the provisions of the NAICOM AML/CFT Regulations 2013, the Training unit shall facilitate training programs that shall make employees and agents fully aware of their obligations — e.g. identifying suspicious transactions and equipping them with the relevant skill required for the effective discharge of their AML/CFT tasks.
The Company shall adopt any of the following staff training methods: a. Classroom training; b. Electronic learning management systems (ELMS); c. Email Communication broadcast to all Staff on AML/CFT subject matter; or d. Mandatory company-wide knowledge sharing sessions.
The training programs shall consider international standards and local legislation to prevent money laundering and terrorism financing, the latest trends in criminal activity, and the Company's policies and procedures designed to counter money laundering and terrorism financing, including how to recognize and report suspicious activities.
A specific record shall be kept of all training activity given, stating the date, place and duration of each course, the number of attendees and the Unit to which they belong.
This Policy shall be deemed effective as of 30/04/2025. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
Chibuike Emmanuel Nwogbo
Chief Executive Officer, Bramp Africa Limited