There have been increased stringent AML/CFT measures worldwide, particularly since the,September 11, 2001 terrorist attacks in the U.S. Nigeria, not being left out in the global efforts to,fight the menace, has taken some AML/CFT measures in recognition of the dangers posed.,With the enactment of AML legislations in Nigeria, the country is giving increased attention to,implementing these laws. The AML and KYC Compliance Manual was developed for Circle’s,guidance under the regulatory purview of the CBN.,The Manual has been enriched by the enabling AML/CFT legislation enacted by Nigeria, particularly,by the relevant FATF-Recommendations, the Guidelines of the Basle Committee on Banking,Supervision and some international best practices documents.
PURPOSE AND OVERVIEW OF THE COMPLIANCE MANUAL
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 fruits or proceeds of,their criminal activities. It is, thus, a derivative 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.
Money laundering and terrorist financing are global phenomena and there has been growing,recognition in recent times, and indeed well-documented evidence, that both money laundering,and terrorist financing pose major threats to international peace and security which could seriously,undermine Nigeria’s development and progress.
Consequently, concerted global efforts have been made to check these crimes. Financial,institutions, in particular, have come under unprecedented regulatory pressure to enhance their,monitoring and surveillance systems with a view to preventing, detecting and responding,appropriately to money laundering and terrorist financing.,This Manual covers the following key areas of AML/CFT policy; compliance officer designation and,duties; the need to cooperate with the competent/supervisory authorities; customer due diligence;,monitoring and responding to suspicious transactions; reporting requirements; record keeping;,AML/CFT employee training program, among others. Diligent implementation of the provisions of,this Manual would not only minimize the risk of being used to launder the proceeds of crime but,also provide protection against fraud and reputational and financial risks.,The Manual is structured in two parts. Part A is made up of the new AML/CFT Directives while Part,B provides guidance on KYC.
