Anti-Money Laundering & Combating the Financing of Terrorism Policy

Introduction

Akuuk recognizes the importance of preventing money laundering, terrorism financing and proliferation financing and is committed to the highest standards of Anti-Money Laundering, Combating Terrorist Financing and Countering Proliferation Financing in Nigeria.

Akuuk, as a financial technology company, is subject to applicable legislation designed to prevent Money Laundering. This legislation includes legislation such as: Terrorism (Prevention and Prohibition) Act 2022, Money Laundering (Prevention and Prohibition) Act, 2022, Anti-Money Laundering/Combating the Financing of Terrorism/Countering Proliferation Financing regulation 2022, and others.

To fulfil this commitment, Akuuk has established internal policies and procedures. This Policy establishes standards which every employee, contractor and business partner must observe.

1. Scope

   Money Laundering is the process of any activity by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins.

   Criminal proceeds may take any form, including money or money's worth, securities, tangible property and intangible property.

   Terrorism Financing is defined as providing, depositing, distributing or collecting funds, directly or indirectly, intended to be used, or knowing that these funds are to be wholly or partially use, for the committing of terrorist acts.

   Proliferation Financing is the act of providing funds or financial services which are used in whole or in part for the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical or biological weapons and their means of delivery and related materials (including both technologies and dual-use goods used for non-legitimate purposes), in contravention of national laws or, where applicable, international laws.

   This Policy is aimed to prevent any company or individual from using Akuuk for money laundering or terrorist financing activities.

2. Our Policy

   2.1. Customer Due Diligence

   To prevent Money Laundering, Akuuk have implemented processes and procedures in its Line of Businesses (LOBs) to conduct appropriate customer due diligence through the Akuuk's Business Partner Screening Questionnaire, identifying the customer and verifying the customer's identity based on the following “Know Your Customer” principles:

   • Customer provided documentation (Verification Checking).
   • Information on the customer obtained from reliable and independent sources (Ownership Checking).
   • Compliance with Akuuk's Business Codes.

   Unusual activity during the customer due diligence process or customer engagement should be reported immediately to the designated compliance department.

   2.2. Risk-Based Approach

   For Akuuk, the threat of being involved in money laundering and terrorist financing activities depends directly on the type of business that Akuuk's customers carry out or on the country where customers are located.

   Akuuk classify its customers based on a risk level in its applicable line of business processes and procedures. Identifying the potential risk will help to effectively manage these risks, implementing controls to mitigate the identified risk, if any.

   2.3. High Risk Customers

   Akuuk will not do business with the following segments of customers:

   • Persons included in any official lists of sanctions, in line with the Akuuk Sanctions Policy;
   • Persons indicating possible involvement in criminal activities, based on available information about them;
   • Persons with businesses in which the legitimacy of activity or source of funds can't be reasonably verified;
   • Persons refusing to provide the required information or documentation; or
   • Entities whose shareholder or control structure cannot be determined.

   2.4. Record Keeping

   Customer documentation can either be submitted in physical or electronic form. An appropriate record of the received documentation, steps taken and copies of, or reference to, the documentation of the customer are kept.

   Records are kept for as long as the relationship endures with the customer and for at least five (5) years after the relationship ends. In countries where this period exceeds the established period of time, the legally established time period will be considered to comply with local law.

   2.5. Designation of Anti-Money Laundering Reporting Officer (AMLO)

   Akuuk have designated an Anti-Money Laundering Officer (AMLO). The AMLO is responsible for:

   • Reviewing and proposing AML/CFT/CPF compliance policies from time to time.
   • Investigating internal reports of money laundering, terrorism financing and proliferation financing.
   • Reporting suspicions of money laundering to the Nigerian Financial Intelligence Unit (NFIU) and other necessary authorities.
   • Acting as key liaison with the money laundering authorities.
   • Training the business and its employees on money laundering.
   • Submitting weekly reports to the Economic and Financial Crimes Commission.
   • Advising on proceed after a report of suspicion on money laundering has been raised; and
   • Designing and implementing Anti-Money Laundering processes and procedures.

3. Reporting Suspicious Activity

   Akuuk expects that, if any employee, contractor or business partner becomes aware of any suspicion or knowledge of possible Money Laundering activity, this is reported without undue delay to the AMLO. This can either be done contacting directly the AMLO or the assistant.

   A report on suspicious activity should contain, at least, the following information, which will be confirmed by the AMLO:

   • Identity of the person raising the suspicion;
   • Date of the report;
   • Who is suspected of money laundering or terrorist financing activities;
   • Other individuals involved otherwise;
   • Deliverance of facts;
   • What is suspected and why; and
   • Any possible involvement of Akuuk.

   The AMLO may make reasonable enquiries within Akuuk or obtain additional information to confirm these suspicions. After this assessment, the AMLO will determine whether it is necessary to file an official report to the NFIU and other necessary authorities.

   Details of internal reports will be held by the AMLO separately, excluded from customer files, to avoid inadvertent or inappropriate disclosure.

4. Training

   Akuuk has a high commitment to compliance and all employees and contractors are required to complete mandatory compliance training, including provisions on anti-money laundering, on an annual basis.

   Job-specific and comprehensive anti-money laundering training are provided to the relevant employees to help recognize and deal with transactions which may lead to money laundering, terrorist financing, or proliferation financing. Attendance of training is mandatory for all staff. A record of all formal training which is to include the name and position of the participants shall be maintained.

5. Policy Review and Audits

   Regular reviews of the effectiveness of this Policy are carried out in addition to audits periodically undertaken by the Akuuk's Internal Audit function. This provides Executive Management and the Board's Audit Committee with the necessary assurance and information regarding the operating effectiveness of Akuuk's controls and processes relating to this Policy.