Effective Date: 3rd June, 2022
Pandascrow recognizes the importance of preventing money laundering and terrorism financing and is committed to the highest standards of Anti-Money Laundering and Combating Terrorist Financing in Nigeria. Pandascrow, as a designated non-financial institution (DNFI), is subject to applicable legislation designed to prevent Money Laundering. This legislation includes legislation such as: Terrorism Prevention Act 2103, Money Laundering Prohibition Act, 2011 (as amended), and others. To fulfill this commitment, Pandascrow has established internal policies and procedures. This Policy establishes standards that every employee, contractor, and business partner of Pandascrow should observe.
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 collection 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. This Policy is aimed to prevent any company or individual from using Pandascrow for money laundering or terrorist financing activities.
To prevent Money Laundering, Pandascrow will implement processes and procedures in its Line of Businesses (LOBs) to conduct appropriate customer due diligence through the Pandascrow’s Business Partner Screening Questionnaire and Onboarding forms, identifying the customer and verifying the customer’s identity on the basis of the following “Know Your Customer” principles:
Unusual activity during the customer due diligence process or customer engagement should be reported immediately to the designated Pandascrow Chief Compliance department or commercial department.
For Pandascrow, the threat of being involved in money laundering and terrorist financing activities depends directly on the type of business that Pandascrow’s customers carry out or on the country where Pandascrow’s customers are located. Pandascrow will 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.
Pandascrow will not do business with the following segments of customers:
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 must be kept. Records should be 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.
Pandascrow will designate an Anti-Money Laundering Officer. The Anti-Money Laundering officer will be responsible for:
Pandascrow 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 by contacting directly the AMLO or his deputy. A report on the suspicious activity should contain, at least, the following information, which will be confirmed by the AMLO:
The AMLO may make reasonable inquiries within Pandascrow to confirm these suspicions or obtain additional information to confirm these suspicions. After this assessment, the AMLO will determine whether or not it is necessary to file an official report to the responsible money-laundering authority. Details of internal reports will be held by the AMLO separately, excluded from customer files, to avoid inadvertent or inappropriate disclosure.
Pandascrow 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 should be provided to the relevant employees to help recognize and deal with transactions that may lead to money laundering or terrorist financing.
Regular reviews of the effectiveness of this Policy are carried out in addition to audits periodically undertaken by the Pandascrow Internal Audit function. This provides Executive Management and the Board Audit Committee with the necessary assurance and information regarding the operating effectiveness of Pandascrow’s controls and processes relating to this Policy.