The Bank's AML/CFT framework
encompasses the following
Board and Management
Responsibilities
The Board of Directors is our naught line of defence and assumes overall
responsibility for the AML/CFT risk management framework in the bank.
The Board reviews and approves the policies on an annual basis to ensure
that they are fully aligned with the bank's strategic vision.
The Board ensures that the Bank's Management and all
employees conform strictly with all regulatory and internal procedures
relating to AML/CFT and that the Bank maintains a zero tolerance to
regulatory infraction.
Reports to the Board and Senior
Management
AML & CFT reports are submitted periodically to Board and senior
management
respectively.
These reports provide the Board and senior management with information
to
enable them to assess the Bank's compliance with its regulatory
obligations.
The reports also ensure that Directors and senior
management are kept abreast on current trends and developments in the
financial industry, particularly in the area of AML/CFT risk management.
Customer Identification and
Verification
Globus Bank has put in place a strict Know Your
Customer (KYC) program to ensure all categories of customers (natural or
legal persons or legal structures) are subject to adequate
identification,
verification and risk rating.
KYC includes not only knowing the customers and entities the Bank deals
with
(either as a single transaction or ongoing relationship), or renders
services to, but also the Ultimate Beneficial Owners (UBOs), legal
representatives, directors and authorized signatories as appropriate.
The program includes strict identification requirements, name screening
procedures and the ongoing monitoring and regular review of all existing
business relationships.
Financial Crimes
Surveillance
Globus Bank monitors all customer transactions, applying a risk-based
approach. Adequate notice and justification are taken on frequency,
volume
and size of transactions, in the context of the assessed customer and
product risks.
There are four aspects to the monitoring of transactions:
-
Pre-execution transaction monitoring to identify transactions which
would if executed result in a breach of applicable sanctions or
embargos
-
Post-execution transaction monitoring to identify transactions which
are
considered suspicious and required to be reported to the relevant
authorities
-
Based on the result of the initial Customer Due Diligence (CDD)
assessment, risk-based approach ongoing monitoring of customer
activity
will be carried out using appropriate software.
This monitoring process will also ensure that the KYC information
held
about the customer is up-to-date
-
Ad-hoc monitoring to identify suspicious activity, but as implied,
it is
an activity which is undertaken on a more informal basis.
It is a procedure which should be undertaken by all members of staff
of
Globus Bank, and can be one of the most effective means of
identifying
suspicious activity.
-
Employees are protected if they report, in good faith, any
suspicious
activity.
Reporting Obligations
The bank is obligated to make certain reports and returns to regulatory
and
intelligence bodies under the Money Laundering (Prohibition) Act 2011 as
amended ('The Act') and the CBN AML/CFT Regulations 2013.
Threshold reports are covered under Section 2 and Section 10 of the Act.
Section 2 provides that financial institutions must submit a report on
all
international transfer of funds and securities of a sum exceeding ten
thousand dollars ($10,000) or its equivalent in other foreign currencies
Similarly, Section 10 of the Act provides that any lodgement or transfer
of
funds in excess of N5 million and above for individuals and N10 million
and
above for corporate customers must be reported.
On the other hand, Section 6 of the Act provides that a financial
institution must submit a report on all unusual and suspicious
transactions.
International Sanctions
The bank prohibits the use or access of its products and services by or
for
the benefit of any person named on a sanctioned list.
All new/existing customers will be screened against publicly available
sanctions lists (including the bank's internal watch list) and against
updates to any applicable lists within a reasonable time of these
updates
being made available.
Customer transactions are also screened to ensure that they are not made
to
sanctioned individuals and entities.
All staff are required, as part of the Bank's policy, to refrain from
any
relationship and/or transaction which yield a true or positive match and
follow the escalation procedure.
Politically Exposed Persons (PEPs)
To a certain degree, holders of public functions and those holding
senior,
prominent or important positions with substantial authority over policy,
operations or the use or allocation of government own resources are
exposed
to the possibility of corruption or the abuse of their position.
This set of people and the entities beneficially owned by them are
considered as posing greater risk to a bank and are accordingly
categorized
as Politically Exposed Persons for the purposes of AML control and
oversight.
In dealing with PEPs, Globus Bank will undertake enhanced due diligence
to
satisfy itself of the legitimacy of the customer's source of wealth as
well
as funds and nature of the business.
Senior management approvals are required before such customers are
on-boarded and when any existing customer becomes PEP.
The bank will also consider the requirement for ongoing transaction
monitoring for potentially suspicious behaviour.
Relationship with Correspondent Banks
Correspondent banking relationships are subject to appropriate customer
due
diligence and review which includes, among other things, confirmation
that
the entity has the appropriate licences to operate in its country of
origin
and due diligence to avoid working with or through shell banks.
Awareness and Training
Globus bank has implemented a comprehensive AML/CFT training program to
ensure that all Board members, Senior Management and staff (in
particular
individuals responsible for transaction processing and/or initiating
and/or
establishing business relationships,) undergo AML/CFT awareness training
Globus Bank's training is tailored to the
business to ensure that staff are aware of different possible patterns
and
techniques of money laundering which may occur in their everyday
business.
Training also covers the general duties
arising from applicable external (legal and regulatory), internal
requirements and the resulting individual duties which must be adhered
to in
everyday business as well as typologies to recognise money laundering or
financial crime activities
Anti-Bribery and
Corruption
Globus Bank has strict prohibitions against bribery and corruption when
dealing with both clients and suppliers.
The use of position/office and taking advantage of the institution to
enrich
oneself is prohibited.
Offering/acceptance of gratification to/from customers/potential
customers/suppliers/vendors to do business is prohibited.
Bribery and corruption are also offences that attract well known
consequences such as warning, suspension, termination or dismissal,
depending on the gravity of the offence.
Record Keeping and
Retention
As provided for in the Act, customer
identification documents are retained throughout the life of the account
and
for five (5) years after the cessation of the banking relationship,
except
in cases of litigation and/or regulatory investigations. In the case of
the
latter, the records will be kept for as long as they are required.
Upon request by a regulatory or law
enforcement agency, Globus Bank shall make available records related to
AML/CFT compliance or its customers as soon as possible from the date of
the
request.
Cooperation with
Regulators,
Law Enforcement and Intelligence Agencies
Globus Bank gives full cooperation to law enforcement and intelligence
agencies within the limits of the rules governing confidentiality.
In full understanding of the crucial role financial institutions play in
the
fight against money laundering and terrorism financing,
the bank promptly complies with all requests validly made pursuant to
extant
laws and provides necessary information to authorized agencies.
Where the bank becomes aware of facts which lead to the reasonable
presumption that money held on deposit derives from criminal activity or
that transactions entered into are themselves criminal in purpose,
appropriate measures, consistent with the law, are taken, for example,
to
deny assistance, sever relations with the customer, close or freeze
accounts
and give full disclosure to the regulatory and intelligence agencies.
Independent Assessment of AML/CFT Compliance program
Adherence to the requirements of Globus Bank's AML program is subject to
independent testing by the bank's Internal Audit function on a biannual
basis.
The report and findings of the audit are circulated to various levels of
senior management.
A follow-up to the audits takes place to ensure that the relevant issues
are
closed out and highlighted recommendations have been implemented.