Project Challenging story

AMPLE MICRO FINANCE BANK LTD with RC No: was reserved with the Corporate Affairs Commission on 26th March and the proposed bank is expected to operate from the Owode Market in Eruku, Ekiti Local Government Area of Kwara State to provide the finest financial services through products that put the customer first. Our premium aim is to bridge the growing wide gap that exists among potential customers in Nigeria growing economy and effective financial solutions. We provide lending services that give new direction and solutions to micro lending in the Nigerian market. We shall be a customer-focused Bank established to solve financial challenges, three Ps define our services: PROMPTNESS, PEOPLE and POSSIBILITIES. Our lending decision is faster because we believe in our customers and the possibilities. As a Micro Finance Bank, Ample will strive within first five years by registering its footprint in the micro lending business with a remarkable presence in various communities within the local government and beyond.
TERMS USED IN ANTI-MONEY LAUNDRY

• AML/CFT - Anti-Money Laundering & Combating the Financing of Terrorism
• CDD - Customer Due Diligence
• CCO – Chief Compliance Officer
• CRT – Currency Transaction Report
• EDD - Enhanced Due Diligence
• EFTs - Electronic Funds Transfers
• FATF - Financial Actions Task Force
• HOC - Head of Compliance
• KYC - Know Your Customer
• ML/TF - Money Laundering and Terrorism Financing
• MIS - Management Information System
• MLPA - Money Laundering Prohibition Act
• NFIU - Nigeria Financial Intelligence Unit
• OFIs - Other Financial Institutions
• PEPs – Politically Exposed Persons
• STR – Suspicious Transaction Report
• TF - Terrorist Financing

AMPLE MICRO FINANCE BANK LTD is committed to the highest standards of the Anti-Money Laundering (AML) and Counter-Terrorists Financing (CFT), and requires the management, and employees to follow the clearly defined standards.
AMPLE MICRO FINANCE BANK LTD examines its AML strategies and objectives on an ongoing basis, and maintains an effective AML policy that reflects its best practices as a domestic financial services provider. AMPLE MICRO FINANCE BANK LTD AML program includes appropriate KYC and Customer Acceptance policies, including establishing the identity of the truebeneficial owners of all Entities, adherence to to all legal and regulatory requirements imposed by the government and its regulators.
Money laundering - is the process of converting funds, received from illegal activities (such asfraud, corruption, terrorism, etc.) into other funds or investments that look legitimate to hide or distort the real source of funds.

MONEY LAUNDERING (What, Why and How) WHAT? The process used to disguise the true source and/or ownership of money or assets derived fromcriminal and fraudulent activities.
WHY? In order to conceal the identity, source and /or destination of money; maintain control over theproceeds in the guise of legitimate business.
HOW? By creating the appearance that large amounts of money obtained from crimes, such as drugtrafficking or terrorist activities, originated from a legitimate source.
The process of money laundering can be divided into three sequential stages:
Placement:-
At this stage funds are converted into financial instruments, such as cheques, Fixed deposits, bank products accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once; this form of placement is called smurfing.
Layering:-
Funds are transferred or moved to other accounts and other financial instruments. It isperformed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes itcomplicated to trace the Money being laundered.
Integration:-
Funds get back into circulation as legitimate funds to purchase goods and services.
LIMITATION ON CASH TRANSACTIONS
Except in a transaction through a financial institution, no person shall make or accept cashpayment of a sum exceeding
- N1 million (or its equivalent) in the case of an individual; or
- N3 million (or its equivalent) in the case of a corporate body

AML POLICY AMPLE MICRO FINANCE BANK LTD will provide services on the financial market adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing of illegally gained funds. AML policy means preventing the use of the company's services by criminals, with the aim of money laundering, terrorist financing or other criminal activity. For this purpose, a strict policy on the detection, prevention and warning of the corresponding bodies of any suspicious activities was introduced by the company. The company reserves theright to suspend any client's operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.
COMPANY'S PROCEDURES
AMPLE MICRO FINANCE BANK LTD will make sure that it is dealing with a real person or legal entity. AMPLE MICRO FINANCE BANK LTD also performs all the required measures in accordance with applicable law and regulations, issued by monetary authorities.
The AML policy is being fulfilled within AMPLE MICRO FINANCE BANK LTD by means of the following: - Know your customer policy and - due diligenceMonitoring of client activity - Record keeping KNOW YOUR CUSTOMER AND CUSTOMER DUE DILIGENCE PROCESS
Because of the company's commitment to the AML and KYC policies, each client of the company has to finish a verification procedure. Prior to the Bank commencing any relationship with the customer, the Bank ensures that satisfactory evidence is produced to reveal the identityof any customer. Individual Clients:
During the process of registration, each client provides personal information, specifically: full name; date of birth; origin; complete address, including phone number and city code. In additionand subject to the type of Account, information in line with the regulatory Guidelines for each Tier level is obtained. The customer submits all the required documents of the KYC and verification to confirm the information is undertaken by the Bank. Corporate Clients:
In case the applicant company is listed on a recognized or approved stock exchange or whenthere is independent evidence to show that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps to verify identity will normallybe required. In case the company is unquoted and none of the principal directors or shareholders already has an account with AMPLE MICRO FINANCE BANK LTD, the Company’s official provides the following documents because of the requirements of KYC:
- A copy of the certificate of incorporation/certificate
- A copy of the Trading License.
- Names and addresses of all office, directors and beneficial owners of the corporate entity.
- A copy of Memorandum and Articles of Association or equivalent documents duly recorded withthe competent registry;
- Description and nature of business (including the date of commencement of the business,products or services provided; and the location of principal business).
- Tax Identification Number of the Company.
This procedure is performed to establish the identity of the client and to help AMPLE MICRO FINANCE BANK LTD know/understand the clients and their financial dealings to be able to provide the best servicesin the Industry.
1. Acceptable Customer ID’s are:-
2. Driver’s License
3. International Passports
4. Permanent Voter’s card
5. National ID

MONITORING CLIENT ACTIVITY In addition to gathering information from the clients, AMPLE MICRO FINANCE BANK LTD continues to monitor theactivity of every client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the client's legitimate business orthe usual client's transaction history known from client activity monitoring. AMPLE MICRO FINANCE BANK LTD has implemented the system of monitoring the named transactions (manually) to prevent using the company's services by criminals. The Bank’s Compliance Officers will always cross check the daily transaction report regularly.
Record Keeping
All customer ID’s, supporting documents which include Trading License copy, Invoice detailsetc. to be filed and keep it in safe place. All record keeping and reporting documentation required by the CBN and financial regulatory authority will be maintained for a minimum of Seven (7) years and they will be made readily available upon legitimate request.
Consumer Privacy
In accordance with the Privacy Act, the company must protect consumers’ personal and privateinformation. All documents that contain consumer’s private and personal information will be stored in a secure location and Access is restricted on various Access level Protocols with Audittrail security to monitor unauthorized attempt to Access.
COMPLIANCE OFFICER JOB RESPONSIBILITIES:-
- Develops initiates, maintains, and revises policies and procedures for the general operation ofthe Compliance Program and its related activities to prevent illegal, unethical, or improper conduct.
- Manages day-to-day operation of the Program.
- Develops and periodically reviews and updates Standards of Conduct to ensure continuingcurrency and relevance in providing guidance to management and employees.
- Collaborates with other departments to direct compliance issues to appropriate existingchannels for investigation and resolution.
- Consults with the MD as needed to resolve difficult legal compliance issues.
- Responds to alleged violations of rules, regulations, policies, procedures, and Standards ofConduct by evaluating or recommending the initiation of investigative procedures.
- Acts as an independent review and evaluation body to ensure that compliance Issues/concerns within the organization are being appropriately evaluated, investigated and resolved.
- Identifies potential areas of compliance vulnerability and risk; develops/implements correctiveaction plans for resolution of problematic issues, and provides general guidance on how to avoid or deal with similar situations in the future.
- Ensures proper reporting of violations or potential violations to duly authorized enforcement agencies (EFCC, NFIU) as appropriate and/or required.
- Monitors the performance of the Compliance Program and relates activities on a continuingbasis, taking appropriate steps to improve its effectiveness.
- Developing an AML/CFT Compliance Programme.
- Receiving and vetting suspicious transaction reports from staff
- Filing suspicious transaction reports with the NFIU.
- Ensuring that the financial institution’s compliance Programme is implemented.
- Co-coordinating the training of staff in AML/CFT awareness, detection methods and reportingrequirements.

EMPLOYEE TRAINING REQUIREMENTS AMPLE MICRO FINANCE BANK LTD follows a rigid recruitment process, part of it being the mechanism of understanding any relationship of potential employees with any kind of crime/criminal activities. Within our induction program, which consists of a number of intensive and handson training sessions, AMPLE MICRO FINANCE BANK LTD trains the newly recruits in the principles, methodologies, policies andprocedures of AML/KYC. Training is to be provided to all employees (new and existing) on a periodical basis must include:-
- Review of all requirements in this AML Compliance Program.
- Verification of customer identification.
- All relevant transaction processing requirements
- Identifying suspicious activity and structured transactions. Reporting requirements related to alltransactions. Recordkeeping requirements. - Additional training will be provided regularly to all employees based on, but not limited to,changes in government regulations.
- Periodically monitor the staff performance in compliance.
- Prepare compliance related check list and to be filled by all employees in operations.
All training will be documented and retained in employee personnel files, other related AML files, or with the training Log in the TRAINING RECORDS section of the Compliance TrainingResource.

STATEMENT OF POLICY 1. The company supports the fight against money laundering and terrorism by adopting this AML Compliance Policy to prevent the Agent’s financial services from being used to promotesuch criminal activity.
2. Cooperate with all the authorities, to the extent that is permitted by applicable Laws, so as tohelp them in their efforts to prevent or fight money laundering, and the financing of terrorism proliferation.
3. The company will fully comply with both the intent and letter of all laws and regulationsrelating to AML, the prevention of terrorist financing and economic sanctions
4. The Agent will train its employees to comply with these laws and regulations.
5. Every employee of the company who conducts or is involved in a Financial Service operationis required to understand and comply with the contents of this document.
6. A copy of this AML Compliance Policy will be kept at each location conducting financial services, in a place that is accessible to all employees conducting financial Services.
7. Maintain all customer/transactions related records for at least 10 years or for longer period ifthe Law in the country requires so.

MONEY LAUNDERING – CONCLUSION Compliance is the responsibility of each and every employee. Strict compliance is very much necessary with all laws and regulations. Non-compliance with the law is not worth the risk Ignorance of the law is not self-defensive hence no excuse before the law. In case of doubt in conducting a transaction, please always refer to our AML Policy &Procedures or contact the Compliance Officer/management team.