Anti-Money Laundering (AML) Policy

The Fxvault AML Policy is designed to prevent money laundering by meeting the Nigerian AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML legislations can be found at http://www.cbn.gov.ng/out/2012/ccd/cbn%20approved%20framework.pdf and http://www.cbn.gov.ng/out/2014/fprd/aml%20act%202013

This AML Policy sets out the minimum standards which must be complied with and includes:

1. The appointment of a compliance Officer who has sufficient level of knowledge, seniority and independence. This compliance officer has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
2. Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
3. Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
4. Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
5. Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
6. The maintenance of appropriate records for the minimum prescribed periods;
7. Training and awareness for all relevant employees