TAJBANK LTD

Anti-Money Laundering / Combatting the Financing

of Terrorism / Combatting the Proliferation of
Financing (AML/CFT/CPF) Compliance Training

Presentation by Compliance to newly Inducted staff

 Venue: Training Academy,No.50 Ebitu Ukiwe Street, Jabi,

Abuja, Jabbi, FCT

 Date : Thursday, May 25, 2023

Date: 22

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2
 Table of Content

• Introduction • 3-Tiered KYC

• Money Laundering • High Risk Categorization of Customers
• Terrorism Financing • Risk Categorization of Customers: Products
• Acts of Terrorism • Monitoring of Transactions & STR
• Proliferation Financing

• Predicate Offenses • Red Flags: Money Laundering & Terrorism-Related

• ML/TF/PF Risk areas • PEPs
• Stages of Money Laundering • Law Enforcement Enquiries
• Financial Institution as Veritable Tools for Money • Conclusion
Laundering
• Customer Due Diligence(Benefit of KYC / CDD)
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 Training Objectives:

1. In compliance with Section 41 (AML/CFT & CPF employee education training

programme) of the CBN AML/CFT/CPF Regulation 2022

2. In line with the Banks AML/CFT Institutional Policy framework

3. To demonstrate Managements commitment to the fight against ML/TF & PF

4. To safeguard the Bank against being used as conduit by money launderers,

terrorism financiers & Financiers of proliferation of weapons of massive
destruction (WMD)

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Compliance July 2022
Glossary of AML/CFT/CPF terminologies …
1. ML = Money Laundering
2. AML = Anti-Money Laundering
3. AMLO = Anti-Money Laundering Officer
4. MLRO = Money Laundering Reporting Officer
5. FT = Financing Terrorism
6. CFT= Combatting the Financing of Terrorism
7. CDD = Customer Due Diligence
8. EDD = Enhanced Due Diligence
9. FATF = Financial Action Task Force
10. FSRBs = FATF Styled Regional Bodies
10. KYC = Know Your Customer
12. NFIU = Nigerian Financial Intelligence Unit
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13. EFCC = Economic and Financial Crimes Commission
14. SCUML = Special Control Unit against Money Laundering
15. STR = Suspicious Transaction Report
16. PEP = Political Exposed Person
17. TFS = Targeted Financial Sanction
18. UBO = Ultimate Beneficial Ownership
19. BOFIA = Bank and Other Financial Institutions Act
20. CAMA = Companies and Allied Matters Act
21. CB = Correspondent Banking
22. PO = Predicate Offences
23. DNFBPs = Designated Non-Financial Businesses and Professionals
24. TMS = Transaction Monitoring System
 Some impacts of Money Laundry, Terrorism financing &
Proliferation financing …

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 Introduction

Money Laundering is simply defined as making illegal

money legal.

Compliance July 2022

 Money Laundering
According to Palermo Convention (United Nations 2000 Convention
Against Transnational Organized Crime), Money Laundering is:

the concealment the acquisition, the conversion or

or disguise of the possession or use of transfer of property,
true nature, property, knowing at knowing it is derived from
source, location, the time of its a criminal offense, for the
disposition, receipt that it was purpose of concealing or
movement, rights derived from a
criminal offense or disguising its illicit
with respect to or origin or of assisting any
ownership of from participation in
a crime. person who is involved
property knowing
that it is derived
in the commission of the
from a criminal crime to evade the legal
offense; consequences of his or
her actions

Compliance July 2022

 Terrorism Financing

• Any person or entity who solicits, acquires, provides, collects,

receives, possesses or makes available funds, property or
other services by any means to terrorists or terrorist
organizations, directly or indirectly with the intention or
knowledge or having reasonable grounds to believe that
such funds or property shall be used in full or in part to
carry out a terrorist act by a terrorist or terrorist
organization

(Section 5 CBN AML/CFT/CPF Regulation 2022 (as amended))

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Compliance July 2022
 Act of Terrorism

 Section 1(2)…an act which is deliberately done with malice, aforethought

and which:
(a) may seriously harm or damage a country or an international
organization;
(b) is intended or can reasonably be regarded as having been intended to
unduly compel a government or international organization to perform or
abstain from performing an act or seriously intimidate a population or
seriously destabilize or destroy the fundamental political, constitutional,
economic or social structures of a country or an international organization;
or otherwise influence such government or international organization
by intimidation or coercion; and involves or causes attack upon a person’s
life…or kidnapping of a person; destruction to a Government or public facility

…Section 2 Terrorism (Prevention Prohibition) Act 2022

(Prohibition of Acts of Terrorism)
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Compliance July 2022
 Proliferation Financing

 Proliferation is defined by the Financial Action Task Force (FATF) as the

illegal manufacture, acquisition development, export, trans-shipment,
brokering, transport, transfer, stockpiling or use of nuclear, chemical,
or biological weapons and their means of delivery and related materials
 Preventing proliferation financing is an important part of combatting
proliferation. It is essential to disrupt the financial flows available to
proliferators and to obstruct and complicate the procurement of the illicit
goods, services and technology needed for the development of weapons
of mass destruction and their means of delivery.
 Recommendation 7 of the FATF Standards requires countries1 to
implement proliferation financing-related Targeted Financial Sanctions
(TFS) made under United Nations Security Council Resolutions
(UNSCRs or resolutions)

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Compliance July 2022
 PREDICATE OFFENSES

1.       participation in an organized criminal 2.       Terrorism, including terrorism financing ;;

5 the proliferation of
23.  
24.   Insider ; , market manipulation; 5 group and racketeering ;; 5
Piracy and
trading 3.       Financing
22.   Forgery ;, weapons of mass destruction ;,
21.   Extortion ;, 4.       Trafficking in persons and migrant
20.   Tax crimes, related to direct taxes smugglings ;,
and indirect taxes ; 5.       Sexual exploitation, including sexual
exploitation of children ;
19.   Smuggling, including smuggling dene
6.       Illicit trafficking in narcotic drugs and
in relation to customs and excise duties
psychotropic substances ;,
and taxes ;

7.       Illicit arms trafficking ;

18.   Robbery or theft ;,
17.   Kidnapping, illegal restraint and
hostage-tak'ng ;
16.   Grievous bodily injury ;
15.   Murder ;
14.   Environmental crime ;,
8.       Illicit trafficking in stolen and other
goods ;
9.       Corruption ;
10.   Bribery ;
11.   Fraud ;,
13.   Counterfeiting and piracy of products ; 12.   Currency counterfeiting ;,

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A typical money laundering scheme in pictures …

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Stages of Money Laundering

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Stages of Money Laundering

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Financial Institutions (FIs) as Veritable Tools for Money Laundering

 Product  Transition  Speed  Activity

 Platform

Compliance July 2022

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 Customer Due Diligence

• performing background
checks and other screening on
customers to ensure that they
are properly risk-assessed
before onboarded
……Recommendation 10, FATF
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Compliance July 2022
 Benefits of KYC and Consequences of Poor Customer Due Diligence

There are several benefits associated with KYC and proper Customer Due Diligence procedures.

 KYC helps you to determine whether the person or entity you are planning to onboard is who they
say they are; therefore, failure to complete your KYC procedure or any other part of Customer Due
Diligence procedure could put you, the organization (and the country at large) at significant risk.
This could even include prosecution, imprisonment, administrative sanctions etc.

 KYC/CDD/EDD Measures is Statutory and Mandatory

 Protect the Institution from Regulatory Fines, Prosecution from Law Enforcement Agencies (LEAs)
 KYC/CDD/EDD measures assist the Organization to Comply with International Best Practices
 Risk Management purposes
 Provides Mechanism to protect the Institution against Reputational Risk
 Fraud Prevention
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Compliance July 2022
 Some Regulatory Penalties on customer complaints & KYC infractions
S/N Regulator Description Amount / Date

1 SEC Delayed response to the queries of 2 customer requests N29 m (March 14, 2012)

2 SEC Shareholders complaints on dividend N500,000.00 (January 24, 2021

3 CBN Consumer Protection infraction N2 m (January 25, 2021)

4 CBN Failure to comply with AML/CFT/CPF requirements with respect to KYC N2.25 m (April 15, 2021)
Policies / Procedures & Customer account Documentation

5 CBN Penalty for failure to Close Cryto-currency accounts N500 m (November 30, 2021)

6 CBN Penalty for contravening CBN guideline on BVN Operations N4 m (Oct. 15, 2021)

7 CBN Non-Compliance with Customer Complaints N2 m (July 14, 2021)

8 CBN Violations against CBN Foreign Exchange (FX) Operations / guidelines N100 m (August 18, 2021)

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Compliance July 2022
 SANCTIONABLE OFFENSES AND PENALTIES

Regulatory Infractions Penalties

Non-resolution of complaints within prescribed timelines N500,000 per week
Non-acknowledgment of complaints from customer or non-
issuance of tracking numbers N2,000,000.00 per complaint
Non-response to request or failure to comply with CBN
directive N2,000,000.00 per infraction
N100,000.00, and in addition, N10,000 for each day the
False or non-rendition of Returns/Reports infraction subsists
Failure to communicate AML/CFT/CPF program of the N10million per Bank, N750,000 on the ECO; N500,000
organization to employees on CCO
Ineffective implementation of the AML/CFT/CPF Program N10million per Bank; N500,000 on each Board Member
Failure to put in place guideline for risk assessment and
profiling of customers as approved N3million per Bank; N100,000 per account
Failure to establish screening mechanism for PEP, UN-
Sanctioned Persons etc N15million per Bank

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 SANCTIONABLE OFFENSES AND PENALTIES CONT’D

Regulatory Infractions Penalties

Failure to implement AML/CFT/CPF policies in branches N20million per Bank, N1,250,000 on the ECO; N1,000,000 on CCO

Failure to implement CDD measures for customer

identification N1million per customer, N750,000 on the ECO; N500,000 on CCO

Failure to implement CDD measures for verification

customer identification N1million per customer, N750,000 on the ECO; N500,000 on CCO

Failure to obtain information on beneficial ownership N1million per customer, N1,250,000 on the ECO; N1,000,000 on CCO

Failure to maintain record for minimum of 5 years N10million per Bank

Failure to maintain a record system that facilitate easy

retrieval N5million per Bank

Failure to render suspicious transactions to NFIU N20million per Bank, N2.5million on the ECO; N2million on CCO

Failure to render other reports to relevant authorities N15million per Bank, N1.25million on the ECO; N1million on CCO

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 SANCTIONABLE OFFENSES AND PENALTIES CONT’D

Regulatory Infractions Penalties

Failure to observe confidentiality
procedures/tipping off N500,000 per staff
Failure to sanction staff that failed to adhere to
monitoring and reporting policies N2million per Bank
Failure to put in place mechanism to ensure
attendance at AML/CFT/CPF trainings N5million per Bank
Dealing in cryptocurrency or virtual assets,
using the Bank's platform N100million per customer
Opening or closing of branches without CBN N5m, and in addition, N100,000 for each day
approval the infraction subsists
Non-display of exchange rates, certificates of N5m, and in addition, N100,000 for each day
incorporation etc the infraction subsists
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Three-Tiered KYC

LEVEL 1 LEVEL 2 LEVEL 3

Description Simplified account Simplified account Standard account

Documentation Basic account opening Basic account documentation Complete KYC

+
Verifiable means of
identification

Single Deposit Limit N50,000 N100,000 No Limit

Cumulative Balance N300.000 N500,000 No Cap limit

Risk Rating Low Low Medium - High

Compliance July 2022

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Managing Money Laundering / Terrorism Financing / Proliferation Financing risks

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MANAGING HIGH RISK CUSTOMERS
 Risk Assessment / Risk Appetite
 Application of Risk Based Approach
 Understand the ML/TF Risks
 Identify / Measure the ML/TF risks
 Enhanced Due Diligence Procedures
 Transaction Monitoring & Watch-listing

25 Render Suspicious Transaction Report
 ML and TF risks can be (a) Inherent (total
amount of risk that can be controlled) or (b)
Residual (remaining risk that may not be
mitigated)
 Available areas of ML and TF risks criteria are:
(1) Customer Business Type
(2) Product / Service Type
(3) Account Type
(4) Transaction Type
(5) Country / Location / Geography/Jurisdiction
(6) Transaction Channel
The hall mark of managing risk is to mitigate them
and file suspicious transaction reporting to
comply with regulations
 High-Risk
Categorization
of Customers:
Product
Channel Product / Service Inherent Risk
Fund Transfer (Domestic & International) High
Electronic Funds Transfer Payment Services High
Transactional accounts (Current a/c’s, Savings a/c’s etc.) Low
Liability-Based investments (savings, time deposits etc. Low
Asset-Based investments (Sukuk) Medium
Trade Services Products High

Compliance March 2022

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 S/N Product / Service Inherent Risk
1 Savings Account Low
2 Domiciliary Account High
3 Current Account SME Low
Risk Categorization 4 Current Account Corporate (Publicly Quoted) Low

of Customers: 5
6
Current Account Individual (Salary)
Salary Account
Low
Low

Product 7 SME Account High

8 Murabaha) Low
9 Lease Financing (Ijarah) High
10 Project Finance (Istisna) High
11 Forward Sales (Salam) High
12 Export Finance High
13 Import Finance High
TREASURY PRODUCTS
14 Mudarabah Term-Deposit High
15 Foreign Exchange High
INTERNATIONAL SETTLEMENT PRODUCTS
E-BANKING PRODUCTS
16 Debit Card High
17 Mobile High
18 Online High
19 Automated Teller Machine (ATM) Medium
20 Point of Sales Terminal (POS) Medium

Compliance March 2022

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 High-Risk Categorization of Customers: Customer
Type
 Politically Exposed Persons (PEPs)
 Designated Non-Financial Business & Professionals
 dealers in Jewelry,
 Cars and Luxury Goods,
 Precious Stones and Metals,
 Hotels, Casinos, Supermarkets, Dealers in Mechanized Farming
Equipment and Machineries
 Real Estate, Estate Developers, Estate Surveyors and Valuers, Estate
Agents, Chartered Accountants, Audit Firms, Tax Consultants,
Clearing and Settlement Companies, On-Governmental
Organizations (NGOs)
 Nominee Share Holders
 Cross-Border Transactions

Compliance March 2022

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 Monitoring
of
Transactions
Transaction Monitoring is
& STR a process of assessment of
customers’
transactions/activities, with
a view to establishing if
customers’ transaction is in
consonance with expected
transaction patterns (in
terms of value, volume and
frequency).
How to Monitor Transactions

• KYC/B
• Records of customers
• Determination of threshold, for monitoring of
transactions.
Compliance March 2022 • Re-assessment of risk profile.
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• File STR/SAR
IDENTIFICATION & REPORTING OF SUSPICIOUS ACTIVITY / TRANSACTION

What is Suspicious Transaction?

 Suspicious transaction is one for which there are reasonable grounds to suspect that the transaction is related to a
money laundering offence or a terrorist activity financing offence.

 STR reporting plays a vital role for detecting crime, laundering of criminal proceeds and terrorism financing activities

 All financial Institutions are required by Section 6 of the Money Laundering Prevention and Prohibition Act 2022
(MLPPA 2022) to take appropriate action to prevent the proceeds of the laundering of crimes or any illegal act

 Failure of financial institutions to comply with the reporting requirement of STR (above) attracts fine of
N1,000,000.00 for each day during which the offence continues.

 The value of STR depends on the quality (correctness, completeness, timeliness etc )

 Financial institutions must keep a tight lid on investigations of suspicious account activity, even when transactional
alerts do not merit regulatory reporting. 

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HOW DO YOU TREAT SUSPICIOUS ACTIVITY / TRANSACTION (where it exists)?

 Understand your customer’s source of funds/source of wealth / beneficial ownership & transaction patterns
 Identify deviation(s) for unusual activities / transactions on the account or linked accounts
 Notify your line / supervisor (for buy-in / authorization to file STR report)
 File the SAR / STR (documenting the event, affected and linked accounts, suspicion etc), using the newly developed
portal vide the link address https://forms.office.com/pages/responsepage.aspx?
id=3GAMVaY8SUCnz_cXHZxfWc5dlnQvcRFHpoDCEOK2SqFUMkNBWTdBS1VYR0ZKWVlMVlpLWVZSNEhHMi4u&web
=1&wdLOR=c9B44766B-7711-470F-9895-40AA790D6580
 Send the COMPLETED STR report with attached scanned (AOP) or send a mail to the group mail (
compliance@tajbank.com)
 Preserve the STR report
 Manage the customer after filing STR report on him/her. Avoid tipping-off the customer
 Compliance will conduct further checks and investigations before filing a final report to the Nigerian Financial
Intelligence Unit (NFIU)
 Compliance department has a robust Anti-Money Laundering solution and a crop of AML report analyst to conduct
proper investigation before filing the report to the NFIU
 The final responsibility to report an STR to the NFIU rest on the Bank’s Chief Compliance Officer (CCO)

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 Red Flags &
Suspicious
Activities

Compliance March 2022

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 Red Flags:

Money Laundering
Accounts opened with the names of
the promoters and directors re- Dormant account containing a Dormant account containing a
occurring in several other accounts minimal sum that suddenly receives minimal sum that suddenly receives
Accounts that received periodical
in the bank OR individuals serving a deposit(s) followed by daily cash a deposit(s) followed by daily cash
deposits and are dormant at other
as company directors for multiple withdrawals within a short period of withdrawals within a short period of
periods..
companies headquartered in the time until the deposited sum has time until the deposited sum has
same location or sharing the same been withdrawn. been withdrawn.
office.

The Opening of multiple accounts

Account opened in the name of an
by an individual into which
individual that is involved in Large cash withdrawals made from
numerous small deposits are made A dormant account reactivated with
activities that are directly or accounts not normally associated
that in aggregate are not an unusually large amount.
indirectly related to the activities or with cash transactions.
commensurate with expected
claims of terrorist organizations.
income of the customer..

When opening an account, the customer

refuses to provide information required
Large cash deposits made from
by the financial institution or attempts to
accounts not normally associated
reduce the level of information required
with cash transactions..
to the minimum or provide information
that is misleading or difficult to verify.

Compliance March 2022

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 Red Flags
Cont’d:

Money Laundering
The structuring of deposits through
multiple branches of the same bank
Split cash lodgement that would have
or by groups of individuals who enter
been made in a single transaction
a single branch at the same time
using different tellers.
making deposits into one or separate
but linked accounts.
The deposit of multiple monetary
instruments at amounts which fall
Deposit or withdrawal of cash in
consistently just below reporting
amounts which fall consistently just
threshold especially when the
below reporting thresholds.
instruments are following sequential
order.

Use of multiple personal and business

Wire Transfer ordered in small accounts or the accounts of Non- Transactions involving foreign
Unrealistic business proceeds or
amounts in apparent efforts to avoid Profit Organizations or charities to currency exchange that is followed
unusual inflows compared to
triggering identification or reporting collect and then transfer funds within a short time by wire transfers
customer's business.
requirements. immediately or shortly after to a from areas of concern.
small number of foreign beneficiaries.

A business account through which a When opening an account, the

large in-coming and out-going wire
transfers take place and for which
there appears to be no logical
business or other economic purpose,
especially when such transfers are
from or to places of concern.
Stated occupation of the customers is
not commensurate with the level or
type of activity.
customer refuses to provide
information required by the financial
institution or attempts to reduce the
level of information required to the
minimum or provide information that
is misleading or difficult to verify.

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Compliance March 2022

 Red Flags
Cont’d
Terrorism-
• Persons involved in currency transactions share an address or phone number, particularly when the
Related address is also a business location or does not seem to correspond to the stated occupation (e.g.,
  student, unemployed, or self-employed).
• Financial transaction by a non-profit or charitable organisation, for which there appears to be no
logical economic purposes or for which there appears to be no link between the stated activity of the
  organisation and other parties in the transaction.
• A safe deposit box opened on behalf of a commercial entity when the business activity of the
  customer is not known or such activity does not appear to justify the use of a safe deposit box.
• Large number of incoming or outgoing funds transfers takes place through a business account, and
there appears to be no logical business or other economic purpose for the transfers, particularly
  when this activity involves designated high- risk locations.
•  The stated occupation of the customer is inconsistent with the type and level of account activity.
• Funds transfer does not include information on the originator, or the person on whose behalf the
  transaction is conducted, the inclusion of which should ordinarily be expected.
• Multiple personal and business accounts or the accounts of non-profit Organizations or charities are
  used to collect and funnel funds to a small number of foreign beneficiaries.
• Foreign exchange transactions are performed on behalf of a customer by a third party, followed by
funds transfers to locations having no apparent business connection with the customer or to high-
  risk countries.
• Funds generated by a business owned by persons of the same origin or by a business that involves
persons of the same origin from designated high-risk countries
Compliance March 2022
35
 Red Flags
Cont’d
Terrorism- •  Split cash lodgement that would have been made in a single transaction using different tellers.
Related • The structuring of deposits through multiple branches of the same bank or by groups of individuals
who enter a single branch at the same time making deposits into one or separate but linked
  accounts.
•  Deposit or withdrawal of cash in amounts which fall consistently just below reporting thresholds.
• The deposit of multiple monetary instruments at amounts which fall consistently just below
reporting threshold especially when the instruments are following sequential order.
•  Unrealistic business proceeds or unusual inflows compared to customer's business.
• Wire Transfer ordered in small amounts in apparent efforts to avoid triggering identification or
  reporting requirements.
• Use of multiple personal and business accounts or the accounts of Non-Profit Organizations or
charities to collect and then transfer funds immediately or shortly after to a small number of
  foreign beneficiaries.
• Transactions involving foreign currency exchange that is followed within a short time by wire
  transfers from areas of concern.
• A business account through which a large in-coming and out-going wire transfers take place and
for which there appears to be no logical business or other economic purpose, especially when such
  transfers are from or to places of concern.
•  Stated occupation of the customers is not commensurate with the level or type of activity.
• When opening an account, the customer refuses to provide information required by the financial
institution or attempts to reduce the level of information required to the minimum or provide
information that is misleading or difficult to verify.

Compliance March 2022

36
 Politically
Exposed Persons
(PEPs)
•PEPs “individuals who are or have been entrusted with
prominent public functions in Nigeria and/or foreign
countries and people/entities associated with them”.

•Due to their position or influence, they may be

susceptible to money laundering and related predicate
offences. As a result, they are designated as high risk for
risk-based monitoring by financial institutions. PEPs
include
• Heads of State or Governments
• State Governors
• Local Government Chairmen
• Senior politicians
• Senior Government officials
• Judicial or Military officers
• Senior executives of State-owned Corporations
• Important Party officials
• Family members or close associates of PEPs
• Members of royal families etc

Compliance July 2022

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 Law
Enforcement
Enquiries What are Law Enforcement Agencies’ enquiries?

These are request from agencies like the Nigeria Police Force,
Economic and Financial Crimes Commission, Directorate of State
Security, Nigeria Drug Law Enforcement Agencies, Court etc, from
financial institutions about items in their custody. Such items
include account opening documentations of customers, transaction
instruments and other items that the Bank used to process
transactions.

 In line with Regulation 4 of the CBN(AML/CFT) Regulations

2013 (as amended), all enquiries from Law Enforcement
Agencies must be promptly responded to, which may
include invitation of staff.
 Section 24 – MLPPA 2022 – Power to demand and obtain
records
Compliance July 2022
38  Section 25 – MLPPA 2022 - Obstruction of authorized officers
 LEAs &
Regulators
Expectations of
CPC & CPC
Managers

Compliance July 2022

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MANAGING PEPs, UBOs & HIGH-RISK CUSTOMERS

A “Politically Exposed Person” or “PEP” as defined  Senior Government officials

by the Financial Action Task Force (FATF) is an  Judicial or Military officers
individual who is or has been entrusted with a  Senior executives of State-owned Corporations
prominent public function  Important Party officials
Due to their position or influence they may be  Family members or close associates of PEPs
susceptible to money laundering and related  Members of royal families etc
predicate offences. As a result, they are designated
as high risk for ease of monitoring by financial
institutions.
They include
 Heads of State or Governments
 State Governors
 Local Government Chairmen
 Senior politicians
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ULTIMATE BENEFICIAL OWNERSHIPs OF CORPORATE
ACCOUNTS
 In 2003, the FATF became the first international body Diligence (CDD).
to set the best standards on beneficial ownership.  Section 55 of the CBN AML/CFT/CPF Regulation 2022
 In 2012, it updated its standards and clearly request financial Institutions to identify its directors
distinguished between basic ownership information and all Signatories to an account.
(about the immediate legal owners of a company or
trust) and beneficial ownership information (about
the natural persons who ultimately own or control it)
 As part of FATF Recommendation 24 on Transparency
and beneficial ownership of legal persons and
arrangements, the standard setter expects countries
to ensure that there is adequate, accurate and timely
information on the beneficial ownership and control
of legal persons that can be obtained or accused in a
timely fashion by competent authorizes.
 Countries are expected to ensure that there are
measures to facilitate access to beneficial ownership
41 and control information by FIs and DNFBPs
undertaking the requirements for Customer Due
 CAMA 2020 & UBO
REFORMS
 Section 119 – indicate to the  Section 120 - Obligation of disclosure by substantial
Disclosure of company in shareholders in public company.
capacity by writing the  A person who is a substantial shareholders in a
Share-holders. particulars of public company shall give notice in writing to the
Every person with such control company stating his name, address and full
significant control particulars of the shares held by him or his nominee
over a company (naming the nominee) by virtue of which he is a
shall within 7 substantial shareholder.
days of becoming  The substantial shareholders of a public company is
such a person, defined as a person who holds himself or through

his nominees 5% of the unrestricted voting rights at

general meetings.
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CAMA 2020 & UBO REFORMS …
CONT’D
• Section 320 - Register of
Directors’ residential
addresses.
• Every company shall keep a
register of director’
residential address
• The register shall state the
usual residential address of
each of the company’s
directors.
• If default is made in
complying within this
section, the company and
each officer of the company
are each liable to a penalty
43
in such amount as the
commission shall specify in
its regulation.
• Section 43(2) company shall
not have or exercise power
either directly or indirectly
to make a donation or gift
of any of its property or
funds to a political party or
political association, or for
any political purpose
 Conclusion

• Make conscious / intentional

efforts to comply with ALL
existing regulations in the
industry.

• Compliance with regulations

is the responsibility of every
staff.

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 THANK YOU!!!

Compliance July 2022

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