AML/KYC

AML/KYC Policy

INTRODUCTION

MAPLETRITE INC. AML/KYC POLICY

1.1 This Policy aims at simplifying the practices and details of the Anti-money Laundering/Combating the Financing of Terrorism and Know your Customer (AML/CFT/KYC) obligations of Mapletrite Inc., Canada. And its international money transfer and remittance products and services trade- named Mapletrite (collectively and individually referred to as the “Company,” “we,” “us,” “ours,” or “Mapletrite”).

1.2 The Company is committed to the highest AML/CFT compliance standards and mandates. The Company's directors, management, and employees must adhere to these standards to prevent using Mapletrite Inc. platforms for money laundering, financing terrorism, or other illegal purposes.

1.3 The Company is aware of the high risks associated with international money transfer services, and we are attentive to our responsibilities to ensure that our platform is not used to perpetrate money laundering, financing of terrorism and other illegal activities.

1.4 This Policy is subject to periodic compliance reviews and changes; it will continue to be reviewed periodically or as needed to reflect changes in laws, regulations, and global best practices.

2 POLICY STATEMENT

2.1 The Company complies with all competent authorities and jurisdictions' AML/CFT/KYC laws and regulations. In addition to adopting best practices, ethical and legal considerations shall always guide our commercial decisions and activities. Our Directors, Management, Staff and Other relevant stakeholders shall fully understand and be guided by these AML/CFT/KYC standards.

2.2 Protecting our Company's good name and reputation shall be the primary consideration in all actions taken by the Directors, Management, and Staff. In this regard, the Company has acquired the necessary software to verify our users and clients and identify suspicious transactions based on specified parameters for further investigation and Reporting.

2.3 The Company shall continue to protect its products and services from being used for Money Laundering, Terrorism Financing, and other crimes through investment in training, adequate staffing, and appropriate Technology.

2.4 We aim to maintain the highest operation standards to advance the interests of our stakeholders. We shall cooperate fully with all global regulations and law enforcement agencies in all AML/CFT/KYC activities.

2.5 Adherence to this AML/CFT policy is the responsibility of all Directors, Management, Employees and Partners. The Company's Compliance Officer (CO) formulated and directed the Policy. Our AML/CFT programme includes user or client screening and monitoring requirements, “Know Your Customer (KYC)/ Customer Due Diligence (CDD)” policies (including the need to establish the identity of beneficial owners), record-keeping requirements, the reporting of suspicious circumstances by relevant laws, and AML/CFT training.

3. POLICY SCOPE AND OBJECTIVES

The standards in this Policy reflect the requirements based on applicable legal and regulatory requirements. These requirements are intended to prevent Mapletrite Inc., our employees, and our clients from being instruments for money laundering, terrorist financing, or other financial crimes. The Policy establishes the general framework for the fight against money laundering and terrorism financing.

This Policy outlines our approach to identifying, mitigating, and managing the AML/CFT risks we can reasonably anticipate. We have been guided by relevant local and international laws and regulations and internationally established financial practices and standards; this Policy also focuses on record keeping, verifying identity, reporting and retention for prescribed periods.

4. DEFINITION OF TERMS

4.1 For the proper understanding of this Policy, specific terms used are defined as follows:

4.2 “Money laundering”:

The responsibilities connected with this Policy are:

Money laundering is the introduction of assets derived from illegal and criminal activities (predicate offences) into the legal financial and business cycle. Violations are, for example, forgery of money, extortionate robbery, drug crime as well as fraud, corruption, organized crime, or terrorism etc.

Predicate offences for money laundering are defined by local law. The money laundering process consists of three “stages”.

“Placement”: The introduction of illegally obtained monies or other valuables into financial or non-financial institutions.

“Layering”: Separating the proceeds of criminal activity from their source through layers of complex financial transactions. These layers are designed to hamper the audit trail, disguise the origin of funds and provide anonymity.

“Integration”: Placing the laundered proceeds back into the economy in such a way that they re-enter the financial system as apparently legitimate funds. These stages are not static and overlap broadly. Financial and non-banking institutions may be misused at any point in money laundering.

4.3 Cross-Border Transaction

Cross-border transaction means any transaction where the originator and beneficiary operators are in a different jurisdiction. This term also refers to any transaction chain with at least one cross-border element.

4.4 Domestic Transactions

Domestic transaction means any wire transfer between the originator and beneficiary institutions in Canada or Nigeria. This term, therefore, refers to any chain of wire transfers that occurs entirely within Nigeria’s or Canadian borders, even though the system used to affect the wire transfer may be in another jurisdiction.

4.5 False Disclosure

False disclosure refers to a misrepresentation of the value of currency or bearer negotiable instruments being transported or a misrepresentation of other relevant data asked for in the disclosure or otherwise requested by the authorities.

4.6 Suspicious transaction

For this Policy, a suspicious transaction may be unusual because of size, volume, type, pattern, or otherwise suggestive of known money laundering or terrorism financing methods. It includes marketing inconsistent with a client’s or user’s availability, legitimate business for that type of account or lacking an apparent economic rationale.

4.7 Designated categories of offences

Designated categories of offences mean:

  1. Participation in an organized crime group and racketeering
  2. Terrorism, including terrorist financing
  3. Trafficking in human beings and migrant smuggling
  4. Sexual exploitation, including sexual exploitation of children
  5. Illicit trafficking in narcotic drugs and psychotropic substances
  6. Illicit arms trafficking
  7. Illegal trafficking in stolen and other goods
  8. Corruption and bribery
  9. Fraud
  10. Counterfeiting currency
  11. Counterfeiting and piracy of products
  12. Environmental crime
  13. Murder, grievous bodily injury
  14. Kidnapping, unlawful restraint and hostage-taking
  15. Robbery or theft
  16. Smuggling
  17. Extortion
  18. Forgery
  19. Piracy
  20. Insider trading and market manipulation
  21. Internet fraud and scam
  22. Kidnapping
  23. Smuggling
  24. Any other act is defined as a money laundering offence in Canada, Nigeria, or any other country.

4.8 Terrorist

It refers to any natural person who;

  1. Commits, or attempts to commit, terrorist acts by any means, directly or indirectly, unlawfully and willfully.
  2. Participates as an accomplice in terrorist acts.
  3. Organizes or directs others to commit terrorist acts or
  4. Contributes to the commission of terrorist acts by a group of persons acting with a common purpose where the contribution is made intentionally and to further the terrorist act or with the knowledge of the intention of the group to commit a terrorist act.

5. THE POLICY ADOPTS THE RISK-BASED APPROACH (RBA) TO SPECIFY THE MINIMUM STANDARDS IN HANDLING THE VARIOUS ASPECTS OF AML/CFT COMPLIANCE WITH REGARDS TO:

  1. Know your customers (KYC)
  2. Simplified Due Diligence
  3. Enhanced Due Diligence
  4. Cross-Border Collaboration
  5. Sanction screening
  6. New Technologies and Non-face to face transaction
  7. Wire transfers
  8. User Risk Profiling
  9. Reporting
  10. Monitoring of Transactions
  11. Record Preservation
  12. AML/CFT compliance Training
  13. Record keeping and identity verification

6. AML/CFT COMPLIANCE OFFICER DESIGNATION AND DUTIES

The duties of the AML/CFT Compliance Officer, among others, include:

  1. Developing an AML/CFT compliance program
  2. Receive and vet suspicious transaction reports from Staff.
  3. Filing suspicious transaction reports with the regulatory bodies and law enforcement agencies
  4. Rendering “nil” reports with the regulatory bodies and law enforcement agencies to ensure compliance.
  5. Coordinating staff training in AML/CFT awareness, detection methods and reporting requirements.
  6. Review and update the AML/CFT policy periodically in line with developments in the law, international standards, and best practices.
  7. I served as a liaison officer with the regulatory bodies and law enforcement agencies and a point-of- contact for all employees on issues relating to money laundering and terrorist financing.
  8. Reporting any suspicious transaction to the Company.

7. MEASURES TO BE TAKEN AGAINST MONEY LAUNDERING AND TERRORISM FINANCING.

The Company shall not, in any way, inhibit the implementation of the requirements in this Policy given the provisions of the laws on Money Laundry, giving the relevant authorities the Power to access information to properly perform their functions in combating money laundering and financing of terrorism, the sharing of information between relevant authorities, either domestically or internationally.

8. CUSTOMER DUE DILIGENCE POLICY (Know Your Customer – KYC)

8.1 General

  1. The Company is not permitted to keep anonymous accounts or accounts in fictitious names, provided that where nominee accounts are maintained, details of the beneficial owners shall be provided on request.
  2. The Company shall undertake the client’s due diligence (CDD) measures when:
    1. Business relationship is established, and
    2. Carrying out occasional transactions above the stipulated threshold or as may be determined occasionally, including where the transaction is carried out in a single operation or several operations that appear to be linked.
  3. there is a suspicion of money laundering or terrorist financing, regardless of any exemptions or any other threshold referred to in this Policy or
  4. There are doubts about the veracity or adequacy of previously obtained client identification data.

 

8.2 Customer Due Diligence Measures

The Company shall determine and document the identity of its users and clients and obtain background information as well, verifying the following: -

For Individuals:

  1. i. Name: through any of the following documents:
    • - International passport
    • - National identity
    • - Voter Registration Card
    • - Driving License
    • - Letter from a recognized public authority or public servant verifying the identity and residence.
    • - National Identification Number (NIN)
  2. ii. Residence:
    • - Telephone Bill
    • - Bank Account Statement
    • - Letter from any recognized public authority
    • - Electricity Bill
    • - Tenancy Agreement
  3. For Corporate Entities:

    Name of Company: - Certificate of incorporation and memorandum and Articles of Association

    1. Principal Place of Business – Certificate of Incorporation/published annual report and account.
    2. Mailing address of the Company: - Certificate of Incorporation and Memorandum and Articles of Association:
    1. Name of the firm
    2. Registration certificate if registered
    3. Partnership Deed
    4. Power of attorney granted to a partner or employee by the firm to do business on its behalf.
    5. Any officially valid document identifying the positions, persons holding the Power of Attorney, and addresses.
    6. Address of firm
    7. Name of all partners and their physical addresses.
    8. In addition to the above, concerning clients that are legal persons, Mapletrite Inc. shall:
    9. Verify any person purporting to have been authorized to act on behalf of such a client by obtaining evidence of their identity and verifying the identity of such a person; and
    10. Verify the status of the legal person by obtaining proof of incorporation from the Corporate Affairs Commission (CAC) or similar evidence of establishment or existence and any other relevant information.
    11. The natural persons include those who exercise ultimate and effective control over the legal person. Examples of types of measures needed to perform this function satisfactorily include:
    12. For Companies – The natural people are those who own the controlling interests and those who comprise the mind and management of the Company.
    13. For Trusts – The natural persons are the settler, the trustee and the person exercising effective control over the trust and the beneficiaries.
    14. Where the client or the owner of the controlling interest is a public company subject to regulatory disclosure requirements (i.e. a public company listed on a recognized securities exchange), it is not necessary to identify and verify the identity of the shareholders of such a public company.
    15. The Company shall obtain information on the purpose and intended nature of the business relationship of its potential clients.
    16. The Company shall conduct ongoing due diligence in the business relationship as stated by the clients.
    17. the ongoing due diligence includes scrutinizing the transaction undertaken by the client throughout the Mapletrite/client relationship to ensure that the transactions being conducted are consistent with Mapletrite’ knowledge of the client, its business and risk profiles, and the source of funds (where necessary)
    18. Mapletrite Inc. shall ensure that documents, data, or information collected under the CDD process are kept up-to-date and relevant by undertaking reviews of existing records, particularly those concerning relationships or clients’ categories.
    19. For clients or users that may require additional caution to be exercised when transacting with them, activities in the client’s accounts shall be monitored regularly for suspicious transactions.
    20. While extra care shall be exercised in such cases, Mapletrite Inc. shall refuse to do business with such clients or automatically classify them as high-risk and subject them to an enhanced customer process. In this regard, Mapletrite shall weigh all the situation's circumstances and assess whether there is a higher- than-normal risk of money laundering or financial terrorism.
    21. The Company shall consider reclassifying a client as higher risk if, following initial acceptance of the clients, the pattern of account activity of the clients does not fit in with Mapletrite' knowledge of the clients. A suspicious transaction report shall also be considered.
    22. Mapletrite Inc. shall not commence business relations or perform any transaction, or in the case of existing business relations, shall terminate such business relations if the client fails to comply with the client’s due diligence requirements.
    23. Mapletrite shall also consider lodging a suspicious transaction report with the relevant authority.

8.3 Higher Risk Categories of Clients/Users

  1. The basic principle of a risk-based approach is that reporting institutions adopt an enhanced CDD process for higher-risk categories of clients, business relationships or transactions. Similarly, a simplified CDD process is adopted for lower-risk clients, business relationships or transactions.
  2. For determining a client’s risk profile, the following are examples of high-risk clients that Mapletrite Inc. shall consider exercising greater caution when conducting transactions:
    1. Non-resident clients
    2. Clients from locations known for their high crime rate (e.g., drug production, trafficking, smuggling)
    3. Clients from or in countries or jurisdictions which do not or insufficiently apply the FATF Recommendation (such as jurisdictions designated as Non-Cooperative Countries and Territories (NCCT) by the FAFT or those known to the reporting institutions to have inadequate AML/CFT laws and regulations.
    4. Politically exposed persons (PEPs) and persons /companies related to them.
    5. Complex legal arrangements such as unregulated investments
    6. Vehicles/ Special purpose vehicles (SPV) or
    7. Companies that have nominee shareholders.
    8. Upon determining clients as “high-risk,” Mapletrite Inc. shall undertake the enhanced CDD process on the clients, which shall include enquiries on:
    9. The purpose of opening an account.
    10. The level and nature of transaction activities intended.
    11. The ultimate beneficial owners
    12. The source of funds
    13. Senior management’s approval is needed to open the account.

8.4 The Company must establish whether the customer or User is acting on behalf of another matured person or a legal entity such as a BROKER, AGENT, TRUSTEE, a NOMINEE or any other professional representative, i.e. (Legal Counsel, Accountant, etc.) in such cases a necessary pre- condition for customer acceptance is the provision of satisfactory proof of identity of the persons upon whose behalf they are acting, as well as the nature of the relationship with customers.

8.5 Additional Due Diligence for Intermediaries:

The Company must undertake additional due diligence measures while establishing and maintaining relationships with agents and other intermediaries.

  1. Obtain additional information about the client’s identity to avoid unwittingly dealing with PEPs and precarious individuals.
  2. Determine from publicly available documents the agent's reputation, including whether such intermediary has been subject to a money laundering/terrorism financing investigation or other regulatory action.
  3. Assessing the intermediary’s anti-money laundering and terrorism financing controls periodically.

8.6 Definition of Politically Exposed Person (PEP)

Politically exposed persons (PEPs) are individuals who are or have been entrusted with prominent public functions both in foreign countries and in Nigeria.’ Examples of PEPs include but are not limited to.

  1. Heads of state or government
  2. Governors
  3. Local government chairmen
  4. Mayors
  5. Senior politicians
  6. Senior government officials
  7. Judicial or military officials
  8. Senior executives of state-owned corporations.
  9. Important political party officials
  10. Family members or close associates of PEPs; and
  11. Members of Royal Families

8.7 Mapletrite Inc. shall do the following.

  1. In addition to performing CDD measures, Mapletrite shall put appropriate risk management systems in place to determine whether a potential client, existing clients, or the beneficial owner is a politically exposed person.
  2. Mapletrite Inc. shall obtain senior management approval before establishing business relationships with PEPs and render monthly returns on PEP transactions with PEPs to the NFIU or other relevant agencies.
  3. Where a client has been accepted or has an ongoing relationship with Mapletrite and the client or beneficial owner is subsequently found to be or becomes a PEP, Mapletrite must obtain senior management approval to continue the business relationship.
  4. Mapletrite Inc. shall take reasonable measures to establish the source of wealth, and the sources of funds of clients and beneficial owners identified as PEPs and report all anomalies immediately to the EFCC and SFIU.
  5. Mapletrite Inc., in a business relationship with PEPs, shall conduct enhanced Due Diligence, flag suspected transactions in the account, and report immediately to the NFIU, the SCUML, or any other relevant agency.

8.8 MONITORING AND REPORTING OF SUSPICIOUS TRANSACTIONS: -Customers

  1. All staff must diligently monitor any unusual or suspicious transactions/ activity, basing their action on the relevant applicable criteria.
  2. the reporting of suspicious transactions/activity must comply with the requirements of the AML/CFT regulations as provided in this Policy and as reviewed from time to time by the Compliance Officer.
  3. The Compliance Officer will be notified about all suspicious transactions’ activity every week.
  4. To further facilitate the detection and prevention of money laundering, a cash transaction report CTR shall be forwarded to the Compliance Officer occasionally.
  5. All Officers involved in processing unusual and suspicious transactions/activities are expected to ensure that safety measures are employed to prevent disclosure of information on such transactions/tip-offs.

8.9 Monitoring of Employee Conduct

The Compliance Officer shall monitor the employees’ accounts for potential signs of money laundering. They must also subject employees’ reports to the same AML/CFT procedures as applicable to other clients’ accounts. The internal Auditor, a person of adequate/similar seniority, will review the latter’s account. Compliance reports and findings will be rendered to the EFCC/SFIU or any relevant authority.

8.10 MAINTENANCE OF RECORDS TRANSACTIONS

Mapletrite Inc. shall:

Maintain all necessary records of transactions, including identification data, accounts, files, and business correspondence, both domestic and international, for ten years from the commencement of the transaction. This requirement applies regardless of whether the account or business relationship is ongoing or has been terminated.

Ensure that all clients –transaction records and information are available on a timely basis to the relevant authority. Some of the necessary components of transaction records to be kept include clients’ and beneficiaries’ names, addresses (or other identifying information usually recorded by the intermediary), the nature and date of the transaction, the type and amount of currency involved, the type and identifying number of any account involved in the transaction,

8.11 TRAINING

Mapletrite Inc. is highly committed to compliance, and all employees and contractors must complete mandatory compliance training annually, including provisions on anti-money laundering. 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 financing terrorism. Regular training on anti-money laundering and combating the financing of terrorism will be provided to all employees who work directly with customers and those who work in other areas that may be exposed to money laundering and terrorist financing threats. Refresher courses and follow-up training will be arranged at least twice a year and as frequently as possible to update Staff on developments in regulation and procedures in anti-money laundering and terrorism financing.

9.0 TERMINATING CUSTOMERS RELATIONSHIPS

Mapletrite Inc. shall terminate the business relationship with a customer where an AML/CFT offence is established against the customer. This is subject to:

  1. Approval of Compliance Officer
  2. Communication of decision to terminate to the customer.

10. VIRTUAL CURRENCY OPERATIONS

10.1 Virtual currency or virtual money was defined in 2012 by the European Central Bank as “a type of unregulated, digital money, issued and usually controlled by its developers, used, and accepted among the members of a specific virtual community.

10.2 Virtual or cryptocurrencies are largely untraceable and anonymous, making them susceptible to abuse by criminals, especially in money laundering and financing terrorism. Given the lack of adequate regulation on these activities, consumers may lose their money without legal redress if these exchanges collapse or close business.

10.3 Examples of Virtual Currency include Bitcoin, Ethereum, Ripples, Monero, Litecoin, Darkcoin, Peercoin, Primecoin, Dogecoin etc.

10.4 Until the regulatory environment around these virtual assets becomes more transparent and mature, Mapletrite does not allow the use of virtual currencies on its platforms.

11. ROLES AND RESPONSIBILITIES

11.1 Board of Directors:

  1. The Board of Directors approves the AML/CFT/KYC policy.
  2. Understand the significant risks confronting Mapletrite and set acceptable levels for these risks.
  3. The Board shall also ensure that Senior Management takes steps necessary to identify, measure, monitor, and control these risks,
  4. The Board shall provide governance guidance and oversight to Senior Management.
  5. Overseeing the Management of the AML/CFT/KYC Risks by Senior Management.
  6. Appointment of the Compliance Officer (CO).
  7. At least annually, through Internal Audit or AML/CFT Consultants, assess the extent to which the Institution manages its AML/CFT/KYC Compliance.
  8. Receives and reviews AML/CFT/KYC Compliance reports from the CO. However, you may delegate this to the Chief Executive Officer.

11.2 Executive Management

  1. Approves and minutes any exceptions or deviations allowed in this Policy.
  2. Adopts the AML/CFT/KYC Policy and Procedure Manual before the Board approves.
  3. Ensures appropriate AML/CFT/KYC Policies, Procedures and Processes (“systems and controls”) have been set up.
  4. Ensures Staff receive appropriate and timely AML/CFT/KYC Compliance Training.
  5. Ensures AML compliance function is adequately resourced with personnel and funding.
  6. Ensures appropriate AML/CFT/KYC compliance culture exists within Mapletrite Inc.
  7. Ensures non-compliance is appropriately sanctioned.

11.3. Compliance Officer

  1. Ensure full compliance with all Anti-Money Laundering, Combating the Financing of Terrorism and Combating Proliferation. Financing Laws and Regulations. Prompt Reporting of all Regulating and Statutory Requirements from Regulatory Bodies and Agencies.
  2. Daily, review all existing and newly opened accounts and ensure complete Account Opening Documentation (KYC) is in place. Follow-up on accounts with incomplete documents and deferrals for full compliance.
  3. Ensures review of high-risk customer account transactions to determine money laundering and terrorist financing transactions. In case of suspicious transaction detection, escalate suspicious activities to fraudalert@mapletrite.com. Also, forward the Suspicious Transaction Report (STR) immediately and without delay to the Compliance Officer for their review, approval, and filling to the NFIU and the FINTRAC Centre.
  4. Ensure all employees comply with Know Your Customer (KYC)/Know Your Customer Business (KYCB) and conduct Enhanced Due Diligence (EDD) process/Procedures on all High-Risk Customers.
  5. Compilation of Politically Exposed Persons (PEPs) List and rendition of Monthly report.
  6. Ensures Enhanced Due Diligence is conducted when onboarding PEP accounts or other high-risk accounts.
  7. Ensuring the use of the Blacklisted Individuals and Organizations Portal to screen existing and prospective Customers on the Terrorist Targeted list (negative lists) to avoid opening accounts for Terrorist and Terrorist Organizations. Matching names of individuals and Organizations should be promptly reported to the Compliance Group.
  8. Review all existing and newly opened accounts to ensure Customer Account Information is correctly captured on the Institution’s Application. Ensure missing information is updated.
  9. Conduct regular AML/CFT/KYC Training for all staff to ensure sensitization of AML/CFT/KYC Laws and Regulations.
  10. Review all Regulatory Websites (CBN, NDIC, SEC. FINTRAC, NSE, etc.) to ensure compliance with Regulatory Circulars.

11.4 Employees

All employees must:

  1. Familiarize themselves with the content of the Policy.
  2. Familiarize themselves with applicable laws and regulations.
  3. Take responsibility for compliance with this Policy as it applies to them by their roles and responsibilities and
  4. Take responsibility for their compliance with laws, rules and standards and adherence to the Bank’s procedures, systems, and controls.
  5. Ensure proper and complete Customer Due Diligence procedures are performed where necessary, especially during the Account Opening for Customers.
  6. Exhibit tact in identifying and reporting suspicious transactions/activities using the appropriate reporting line. Avoid customer tip-offs.
  7. Adhere strictly to the record retention or preservation policy of the Institution, especially as it relates to the provisions of the Money Laundering Prohibition Act of Nigeria (as amended) and PCMLTRA.
  8. Attend and demonstrate competence from the knowledge and skills imbibed from AML/CFT/KYC Compliance training.

POLICY REVIEW & AUDITS

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

Produced: November 20, 2024

Approved by: Board of Directors President/CEO

Recommended by: Compliance Officer

Following Review: Annual.

 

Contact person:

Emmanuel Ariwodo

Compliance Officer

Mapletrite Inc.

Email: compliance@mapletrite.com

Mobile: 778-866-0138