The Anti-Money Laundering & Combating the Financing of Terrorism Policy (“AMF/CFT Policy”) sets out the guidelines for Boundless Nexus Limited’s (the Company) compliance with AML/CFT obligations under the law, as well as regulatory directives, and actively prevents any transaction that facilitates criminal activities and other related matters.

1.1 Description

Money laundering and financing terrorism are financial crimes with economic effects. It requires an underlying primary profit-making crime such as corruption, drug trafficking, market manipulation, fraud, tax evasion, etc., with the intent to conceal the proceeds of the crime and to further the criminal enterprise. AML/CFT compliance programmer helps mitigate the adverse effects of criminal economic activity and promote integrity and stability in financial markets. It is also critical to preserving the Company’s corporate integrity, reputation and operational efficiency.

1.2 Definition of Key Words

▪ Money Laundering –

Money laundering (ML) has been defined as the process whereby criminals attempt to conceal the illegal origin and/ or illegitimate ownership of property and assets that are the proceeds of their criminal activities. It is, thus, a derivative crime.

▪ Terrorism Financing –

includes both legitimate and illegitimate money characterized by concealment of the origin or intended criminal use of the funds.

▪ Know Your Customer –

This entails obtaining and verifying customer identity, preservation of records of customers, mandatory disclosure of transactions to authorized statutory bodies.

▪ Customer Due Diligence –

This covers steps taken by Boundless Nexus Limited to identify its clients and validate their identities.

▪ Nigeria Financial Intelligence Unit –

Money laundering (ML) has been defined as the process whereby criminals attempt to conceal the illegal origin and/ or illegitimate ownership of property and assets that are the proceeds of their criminal activities. It is, thus, a derivative crime.

▪ Politically Exposed Persons –

Individuals who are or have been entrusted with prominent public functions in any country; generally presenting a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold.

1.3 Purpose

The purpose of this Policy manual is to:
  • Provide guidance on the standards of conduct and practice that must be followed in the implementation of Know Your Customer (KYC) and Customer Due Diligence (CDD) requirements;
  • Protect the Company against fraud, reputational and other financial market risks;
  • Minimize the risks faced by the Company from proceeds of crime; and
  • Protect the integrity of the Company against all forms of abuse, fraudulent and unfair trade practices.

1.4 Policy Statement

The following statements shall guide the principles and procedures for AML/CFT compliance programmer. The Company shall:
  • Formulate and implement internal controls and other procedures that will deter criminals from using its facilities for money laundering and terrorist financing and to ensure that its obligations under subsisting laws and regulations are met;
  • Designate AML/CFT Chief Compliance Officer at the Management level, with the relevant competence, authority and independence to implement the Company’s AML/CFT compliance programmer;
  • Comply with the requirements of the Money Laundering (Prohibition) Act, 2011, Terrorism (Prevention) Act, 2011 and Terrorism Prevention (Freezing of International Terrorists Funds and other Related Measures) Regulations 2013, and other extant laws and Regulations;
  • Comply promptly with all the requests made pursuant to subsisting laws and Regulations and shall provide relevant information to the Securities and Exchange Commission (SEC), the Nigerian Financial Intelligence Unit (NFIU) and other relevant law enforcement agencies on AML/CFT matters;
  • Identify and report to the NFIU, in the course of its business, any suspicious transactions derived from the criminal activities defined in AML/CFT SEC Regulations;
  • Ensure the implementation of the requirements of the AML/CFT Act are not inhibited through the Company’s Confidentiality Agreement or Policy;
  • Exit relationships which pose heightened money laundering risks to the Company; and,
  • Effectively communicate this Policy to raise the level of staff awareness on AML/CFT issues.


KYC is the due diligence that Financial Institutions, Financial Market Operators, Financial Market Infrastructures and other regulated companies must perform to identify their clients and ascertain relevant information before carrying- out any financial businesses with them. A client for the purposes of KYC policy is defined as:
  • An entity that has a business relationship with the Company, and/or,
  • Any entity connected with a financial transaction, which can pose a significant reputational or other risk to the Company.
  • Obtaining the necessary documents and information from every client (anyone who the Company receives money from to provide a business);
  • Obligation to report to the regulatory authorities on suspicious transactions, which may ultimately have a bearing on money laundering activities;
  • Updating client information as frequently as practicable;
  • Identifying the client as well as their beneficial owners and verifying such client’s identity using reliable, independent source documents, data or information;
  • Independent verification of legal status of incorporated entities and sole proprietorships with the Corporate Affairs Commission, in writing; and,

    Performing enhanced due diligence for higher risk clients, business relationships or transactions including:

  • Politically Exposed Persons ( PEP) , cross border transactions and business relationships.
  • Any other businesses, activities or professions as may be prescribed by regulatory, supervisory and competent authorities.

1.4.2 Record Keeping and Retention Requirements.

The Company shall maintain all necessary records of transactions, both domestic and international for at least five (5) years after completion of the transactions or such a longer period as may be required by NFIU. Records of all suspicious transactions shall be kept for the same period.

1.4.3 Requests for AML Records By Regulatory and Law Enforcement Agencies

Upon request by a regulatory or law enforcement agency, the Company shall make available records related to AML/CFT compliance or its clients as soon as possible from the date of the request.

1.4.4 Transaction Reporting

The Company shall exercise due diligence in identifying and reporting suspicious transactions. Suspicious transactions include:
  • Transactions which are structured to avoid reporting and record keeping requirements;
  • Altered or false identification or inconsistent information or any transaction involving criminal activity in the Company’s view; and,
  • Entity that belongs to a person or organization considered as terrorist.
  • The Company shall ensure timely and accurate rendition of all AML/CFT returns as specified in the CBN AML/CFT Rules and Regulations as well as other relevant Regulations/ Act/ Guidelines/ Circulars that may be issued from time to time by relevant government agencies.

1.4.5 Awareness and Training

The Company shall create awareness amongst its employees on AML/CFT through a robust training program that will include courses, workshops and newsletters. Such trainings shall incorporate current developments and changes to relevant guidelines as well as internal Policies, procedures, processes and monitoring systems. The Company shall also utilize other avenues such as e-mails, display screens, posters etc. to disseminate compliance issues arising from new rules and regulations to all Staff members.

1.4.6 Politically Exposed Persons (PEPs)

Business relationships with family members or close associates of PEPs involve reputation risks similar to those of the PEPs themselves. The Company shall evaluate the risks to its business operations when dealing with PEPs. The following factors shall guide identification of PEPs’ risk characteristics:

  • Nature of the client and the client’s businesses – The source of the client’s wealth, the nature of the client’s business and the extent to which the client’s business history presents an increased risk for money-laundering and terrorist financing;
  • Purpose and activity – The size, purpose, services involved in the relationship;
  • Relationship – The nature and duration of the Company’s relationship with the client;
  • Client’s corporate structure; and,
  • Public information – Information is known or reasonably available to the Company about the client.

1.5 Responsibilities

I. Board of Directors The roles and responsibilities of the Board of Directors with respect to AML/CFT compliance include, but are not limited to:

  • Ensuring that a comprehensive operational AML/CFT Compliance Policy is formulated by Management;
  • Ratifying the AML/CFT Compliance Policy as approved by the Board Regulation and Risk Management Committee (BRRMC).
  • Decision-making based on quarterly reports received on AML/CFT matters.

II. Board Regulation and Risk Management Committee (BRRMC). BBRMC is tasked with the responsibility of:

  • Approving the AML/CFT Compliance Policy.
  • Reviewing all periodic report on AML/CFT matters.
  • Ensuring that Management forwards all required periodic reports to the relevant regulatory authorities.
  • Providing guidelines regarding the management of AML/CFT compliance risks.

III. Chief Executive Officer (CEO) The duties of the CEO in Boundless Nexus Limited include:

  • Developing an AML/CFT Compliance Programme;
  • Informing the Board of AML/CFT compliance efforts, compliance failures and the status of corrective actions;
  • Ensuring implementation of Board decisions on compliance matters;
  • Ensuring that regulatory changes are highlighted to the Board and effectively implemented by the Company;
  • Ensuring that compliance requirements are integrated into the day-to-day activities of the Company and that processes are efficient and in accordance with applicable laws and policies; and,
  • Coordinating the development of staff in AML/CFT awareness, detection methods and reporting requirements.

V. Compliance Officer

  • Coordinating and monitoring day-to-day compliance with applicable money laundering laws and regulations;
  • Monitoring transactions to detect unusual suspicious activities;
  • Prompt preparation and delivery of all relevant returns to the regulatory bodies in line with SEC and FIU Rules and Regulations; and,
  • Communicating AML/CFT issues to all stakeholders.

VII. All Staff Members

  • Familiarizing themselves with guidelines, policies and best practices relating to their respective areas of responsibility;
  • Implementing the measures and approaches diligently and to the best of their ability; and,
  • Implementing the measures and approaches diligently and to the best of their ability; and,

1.6 Consequences

A breach of the anti-money laundering and combating the financing of terrorism laws is a serious offense and could result in lengthy investigations, significant fines and criminal sanctions (including imprisonment of employees)