Anti-Money Laundering Policy For Provest Limited

Provest Limited is committed to maintaining the highest standards of integrity and compliance in all its operations. In alignment with the Money Laundering (Prevention and Prohibition) Act, 2022 of Nigeria, this Anti-Money Laundering (AML) Policy outlines our framework to prevent, detect, and report money laundering activities. This policy applies to all employees, directors, and affiliates of Provest Limited.

1. Objectives

  • To ensure compliance with all applicable AML laws and regulations in Nigeria.
  • To establish robust internal controls to detect and prevent money laundering activities.
  • To protect Provest Limited from being used as a conduit for illicit activities.

2. Scope

This policy applies to all products and services offered by Provest Limited and covers all transactions conducted by or on behalf of the company.

3. Customer Due Diligence (CDD)

  • Identification and Verification: Provest Limited will conduct thorough due diligence to identify and verify the identity of all customers, including individuals and corporate entities, before establishing any business relationship. This includes obtaining and verifying information such as name, address, date of birth (for individuals), and registration details (for corporate entities).
  • Beneficial Ownership: For corporate customers, Provest Limited will take reasonable measures to understand the ownership and control structure and identify the ultimate beneficial owners.
  • Ongoing Monitoring: Continuous monitoring of customer transactions will be conducted to ensure that they are consistent with the customer’s profile and to detect any unusual or suspicious activity.

4. Enhanced Due Diligence (EDD)

Enhanced due diligence measures will be applied in higher-risk situations, including but not limited to:

  • Politically Exposed Persons (PEPs): Provest Limited will implement measures to determine whether a customer or the beneficial owner is a politically exposed person and, if so, obtain senior management approval before establishing a business relationship.
  • High-Risk Countries: Additional scrutiny will be applied to relationships involving countries identified as high-risk for money laundering or terrorist financing.

5. Record Keeping

All records related to customer identification and transactions will be maintained for a minimum of five years following the termination of the business relationship or the completion of the transaction, in compliance with regulatory requirements.

6. Reporting Obligations

  • Cash Transactions: By the Money Laundering (Prevention and Prohibition) Act, 2022, Provest Limited prohibits cash payments exceeding ₦5,000,000 for individuals and ₦10,000,000 for corporate entities, except through a financial institution.
  • Suspicious Transactions: Employees must report any transaction that appears suspicious or unusual to the Compliance Officer immediately. Suspicious transactions include those that are unjustifiably complex, lack economic justification, or deviate from the customer’s known transaction patterns. Such reports must be submitted to the Nigerian Financial Intelligence Unit (NFIU) within 24 hours.
  • International Transfers: All international transfers of funds or securities exceeding $10,000 must be reported to the NFIU and the Securities and Exchange Commission (SEC) within one day of the transaction.

7. Internal Controls and Compliance

  • Compliance Officer: Provest Limited will designate a Compliance Officer responsible for overseeing AML compliance, including the development and implementation of policies and procedures, monitoring adherence, and reporting to senior management and regulatory authorities.
  • Training: Regular AML training programs will be conducted for all relevant employees to ensure they understand their obligations and can recognize and handle transactions related to money laundering.
  • Independent Audit: An independent audit function will be established to periodically test the effectiveness of the AML program and recommend improvements.

8. Prohibition of Anonymous Accounts and Shell Banks

Provest Limited prohibits the opening or maintaining of anonymous accounts or accounts in fictitious names. Additionally, the establishment or operation of shell banks is strictly forbidden.

9. Penalties for Non-Compliance

Non-compliance with AML laws and regulations can result in severe penalties, including fines and imprisonment for individuals, and substantial fines and potential revocation of licenses for corporate entities. Employees found to violate this policy may also face disciplinary action, up to and including termination of employment.

10. Review and Updates

This policy will be reviewed and updated regularly to reflect changes in laws, regulations, and the risk environment. All employees are required to familiarize themselves with this policy and adhere strictly to its provisions.

By implementing this AML policy, Provest Limited demonstrates its commitment to combating money laundering and upholding the integrity of the Nigerian financial system.