Anti Money Laundering Statement
Effective Date: January 1st 2025
Last Updated: May 30th 2025
 
1. Introduction
etcetera ("we," "us," or "our") is committed to combating money laundering, terrorist financing, and other financial crimes in accordance with Nigerian laws and international standards. This Anti Money Laundering (AML) Statement outlines our policies and procedures to prevent our platform from being used for illicit financial activities.
 
2. Legal Compliance
We comply with all applicable Nigerian anti-money laundering laws and regulations, including but not limited to:

• Money Laundering (Prevention and Prohibition) Act 2022

• Economic and Financial Crimes Commission (EFCC) Act

• Central Bank of Nigeria (CBN) Anti-Money Laundering and Combating the Financing of Terrorism Regulations

• Nigerian Financial Intelligence Unit (NFIU) guidelines

• International anti-money laundering standards and best practices
   

3. Risk Assessment
We conduct regular risk assessments to identify and evaluate money laundering and terrorist financing risks associated with our business operations, including:

• Customer risk assessment

• Geographic risk evaluation

• Product and service risk analysis

• Transaction monitoring and analysis
   

4. Customer Due Diligence (CDD)
4.1 Identity Verification
We implement robust customer identification procedures that include:

• Verification of customer identity using reliable, independent source documents

• Collection and verification of beneficial ownership information for corporate customers

• Enhanced due diligence for high-risk customers and politically exposed persons (PEPs)
   

4.2 Ongoing Monitoring
We continuously monitor customer accounts and transactions to:

• Identify unusual or suspicious patterns

• Ensure customer information remains current and accurate

• Detect potential money laundering or terrorist financing activities
   

5. Suspicious Transaction Reporting
We have established procedures to:

• Identify and analyse suspicious transactions or activities

• Report suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) within the prescribed timeframes

• Maintain confidentiality of suspicious transaction reports

• Preserve records and documentation as required by law
   

6. Record Keeping
We maintain comprehensive records including:

• Customer identification documents and information

• Transaction records and supporting documentation

• Suspicious transaction reports and related correspondence

• Training records and compliance documentation

All records are retained for a minimum period as required by Nigerian law (typically 5 years after the business relationship ends or transaction is completed).
 
7. Training and Awareness
We provide regular AML training to our staff to ensure:

• Understanding of money laundering and terrorist financing risks

• Knowledge of relevant laws, regulations, and internal policies

• Ability to identify and report suspicious activities

• Awareness of their roles and responsibilities in AML compliance
   

8. Sanctions Screening
We screen customers and transactions against:

• Nigerian sanctions lists

• United Nations sanctions lists

• Other applicable national and international sanctions regimes

• Politically exposed persons (PEPs) lists
   

9. Technology and Systems
We employ appropriate technology solutions to:

• Automate customer screening processes

• Monitor transactions for suspicious patterns

• Maintain secure record-keeping systems

• Generate required reports and documentation
   

10. Governance and Oversight
10.1 AML Compliance Officer
We have appointed a designated AML Compliance Officer responsible for:

• Overseeing AML compliance program implementation

• Serving as the primary contact for regulatory authorities

• Ensuring staff training and awareness

• Managing suspicious transaction reporting
   

10.2 Management Oversight
Our senior management is committed to:

• Providing adequate resources for AML compliance

• Regular review and update of AML policies

• Ensuring accountability throughout the organisation

• Fostering a culture of compliance
   

11. Third-Party Relationships
We conduct appropriate due diligence on third-party service providers and business partners to ensure they maintain adequate AML controls and do not pose unacceptable money laundering risks.
 
12. Reporting and Communication
12.1 Regulatory Reporting
We submit all required reports to Nigerian regulatory authorities, including:

• Suspicious Transaction Reports (STRs)

• Currency Transaction Reports (CTRs)

• Other regulatory filings as required
   

12.2 Customer Communication
We may request additional information from customers as part of our AML compliance obligations and appreciate their cooperation in providing requested documentation promptly.
 
13. Consequences of Non-Compliance
Customers who fail to comply with our AML requirements may face:

• Account restrictions or limitations

• Transaction blocks or delays

• Account closure

• Reporting to relevant authorities as required by law
   

14. Contact Information
For questions regarding this AML Statement or to report suspicious activities, please contact:
AML Compliance Officer
Email: hello@etcetera.com

 
15. Updates and Amendments
This statement may be updated from time to time to reflect changes in laws, regulations, or business practices. The current version will always be available on our website.