Wednesday, May 1, 2024

AML/CFT Policy

Introduction

TecheraX Global Tech Ltd. (hereafter, the “Company”) is committed to complying with all applicable laws and regulations, including those related to anti-money laundering (AML) and countering financing of terrorism (CFT), as well as the guidelines provided by the Central Bank of Nigeria (CBN).

The purpose of this policy is to establish a framework for the Company’s AML/CFT program to prevent and detect potential money laundering and terrorist financing activities.

Scope

Money laundering is the criminal process of converting illegally obtained funds into legal investments by hiding their true source. It is a serious global issue that can have devastating economic, social, and political consequences. The government of every country fights against money laundering and terrorist financing to prevent the entry of criminal funds into the economy.

As a financial institution, TecheraX Global Tech Ltd. is aware of the vulnerabilities of its products and services to illegal activities, especially digital currency services. Therefore, we have implemented strict measures to prevent money laundering and financing of terrorism.

Our AML/CFT Policy

  • Risk Assessment: The Company will conduct a risk assessment to identify and assess the money laundering and terrorist financing risks associated with its business. The risk assessment will take into consideration the nature of the Company’s products, services, customers, geographic locations, and delivery channels. The risk assessment will be reviewed and updated on a regular basis to ensure it remains current and relevant.
  • Customer Due Diligence (CDD): The Company will perform customer due diligence (CDD) on all new and existing customers to verify their identity and assess the level of risk associated with the customer. The CDD process will include obtaining identifying information, such as name, address, and date of birth, and may include obtaining additional information, such as the source of funds, nature of the business, and expected transaction activity. Enhanced due diligence (EDD) measures will be applied to high-risk customers.
  • Transaction Monitoring: The Company will monitor all transactions for unusual or suspicious activity. The transaction monitoring system will be designed to identify and analyze patterns of activity that may indicate potential money laundering or terrorist financing. The Company will document and report suspicious transactions to the relevant authorities as required by law.
  • Transaction Limits: To comply with AML/CFT regulations, TecheraX Global Tech Ltd. has established transaction limits for its customers. The transaction limits are based on the level of customer verification and the type of transaction being conducted.
    • Customers who have completed the basic verification process will have lower transaction limits than customers who have completed the enhanced verification process.
    • The transaction limits may also vary depending on the payment method used and the country of the customer.
    • The transaction limits may be adjusted at any time at the sole discretion of TecheraX Global Tech Ltd., and customers will be notified of any changes.
  • Record Keeping: The Company will maintain accurate and complete records of all customer transactions, including identifying information, transaction details, and supporting documentation. The records will be retained for the minimum period required by law and may be retained for longer if required by the Company’s risk assessment or regulatory requirements.
  • Reporting: The Company will report suspicious transactions to the relevant authorities as required by law. The Company will also cooperate with law enforcement agencies and regulatory authorities in their investigations of potential money laundering or terrorist financing.
    • Employees of TecheraX Global Tech Ltd. are required to report any suspicious activity to the designated compliance officer. Suspicious activity includes but is not limited to:
      • Transactions involving large amounts of money or digital assets that appear to have no legitimate purpose.
      • Transactions that are structured to avoid reporting requirements or other regulatory obligations.
      • Transactions that involve persons or entities that are known or suspected to be involved in illegal activities.
      • Transactions that involve persons or entities that are subject to economic sanctions or other regulatory restrictions.
  • Training: The Company will provide training to all employees on AML/CFT policies and procedures. The training will be tailored to the employee’s job function and will include information on the identification and reporting of suspicious transactions.
  • Compliance Officer: TecheraX Global Tech Ltd. has appointed a compliance officer who is responsible for ensuring compliance with all AML/CFT laws and regulations. The compliance officer is responsible for implementing and overseeing the Company’s AML/CFT program, including the risk assessment, customer due diligence, transaction monitoring, and reporting of suspicious activity.
    • The compliance officer also provides training to employees on AML/CFT policies and procedures and ensures that the program is reviewed and updated on a regular basis.
  • Review and Update: The AML/CFT program will be reviewed and updated on a regular basis to ensure it remains current and effective. The review will include an assessment of the effectiveness of the program and any changes to the regulatory environment or the Company’s business that may impact the AML/CFT program.