Revision Date: 25th July 2017
Anti-Money Laundering Department ,Blockvila.
All Domestic and International operations.
3years or earlier if required
Anti- money laundering Department , Blockvila.
26th July 2017
27th July 2017
Barr. Sussan Nnorom -Ibitoye
Approved by: Precious Kenneth Wogu
President & CEO
Slogan for Blockvila
”Your satisfaction is our priority”
ABBREVIATIONS USED IN AML/CDD/CFT POLICY.
||Combating Financing of Terrorism
||Financial Action Task Force
||Money Laundering Reporting Officer
||Politically Exposed Person/td>
||Board of Directors
||Office of Foreign Assets Control
||Money Service Business
||Customer Due Diligence
||Enhanced Due Diligence
||Simplified Due Diligence
Blockvila is a Subsidiary of NYXEL TECHNOLOGY LIMITED a company registered with CAC in
Nigeria, Headquartered in Port Harcourt, Rivers state.
Blockvila is a leading and most trusted digital financial service provider; it is an independent ecurrency
service provider in Nigeria with a well-known brand locally with a substantial international
To protect itself from the increasing danger of organized criminal activity, Money Laundering and
Terrorist Financing. It is essential for Blockvila to have a clearly laid down “ Anti- Money
Laundering” (AML) / “Customer Due Diligence” (CDD)/ “ Combating the Financing of Terrorism (CFT)
policy to ensure that e-e-currency exchangers remain protected from the menace of money laundering and
is not used by existing and /or prospective customers for any criminal activity.
1.1 OBJECTIVES OF AML/CDD/CFT POLICY
The objective of this policy is to ensure that the products and services of Blockvila are not
used to launder the proceeds of crime and that all of Blockvila staff is aware of their
obligations and the need to remain vigilant in the fight against money laundering /terrorist
financing. The document also provided a framework to comply with applicable laws. Regulatory
guidelines specially related with detection and reporting of suspicious activities.
In case of any clarification contact AML Department of Blockvila using
The policy is applicable to all domestic and international operations including banks and financial
institutions. Particular attention shall be paid to customers oversea located abroad who do not or
insufficiently comply with FATF recommendation. Furthermore, AML/CFT policies shall be
applied to all customers outside and in Nigeria to the extent that laws and regulations of Nigeria
1.3 ADMENDMENT AND UPDATES
Amendment and updates to this policy shall be approved by the president on pre-facto basis on
the recommendation of the Compliance Officer. All such amendment and updates shall be
subsequently ratified by the Board.
Deferral against procedure requirement can only be allowed by CO under special circumstances.
Respective relationship management and operational staff will be responsible for monitoring and
regulation of the deficiency before expiry of deferrals.
Policy Coverage will include
1.5 MONEY LAUNDERING
- Compliance with AML Act 2010
- Compliance with Regulations on AML/CDD/CFT
- Compliance on AML/CDD/CFT and subsequent updates
- FATF Recommendations
- Standards and guidelines including sanctions as applicable
1.6 STAGES OF MONEY LAUNDERING
Money Laundering is the criminal practice of processing ill-gotten gains or “ dirty “ money,
through a series of transactions ,so that they appear to be the proceed from legal activities , It is
also the process of changing the identity of illegality obtained money by using banking channels
so that it appears to have originated from a legitimate source.
The Global Definition of Money Laundering: It is a process of transforming the profits of crime and
corruption into ostensibly “legitimate “assets …. Some countries define money laundering as obfuscating
sources of money , either intentionally or by merely using financial systems or services that do not
identify or track sources or destinations.
Also Money Laundering is the process of creating the appearance that large amount of money obtained
from serious crimes, such as drug trafficking or terrorism activity, originated from a legitimate source.
Money Laundering can be a diverse and often complex process. The first step in the laundering
process by the criminal is to attempt to get the proceeds of their crimes into a bank or other
financial institution, sometimes using a false identity. The funds can further be transferred to
other accounts, locally or internationally or used to buy goods or services. It eventually appears to
be like legally earned money and become difficult to trace back to its criminal origin. The
criminal can then invest or spend it or as is often the case, used in funding more crimes.
The laundering process is often takes place in three(3) stages
At this stage, illegal funds or assets are first brought into the financial system. When illegal funds
are place into the financial system, they become more liquid. there are numerous placement
techniques including but not limited to the following:
- Alternative Remittances
- Electronic Transfers
- Assets Conversion
- Bulk Movement
- Securities Dialing
involves the deposit of small amounts of illegal cash into accounts. Typically, smurfing
deposits are in small amounts in order to avoid Regulatory requirements of reporting cash transactions.
It refers to the transfer of funds through “alternative” or illegal money transfer system. These systems are unregulated and illegal, but they are used to transfer both legitimate and illegal funds. Alternatively, Remittances also go by the names of underground or parallel banking. There is very large network of these system in operation around the World.
In the money laundering context, an electronic transfer involves the transfer of
money through electronic payment systems that do not require sending funds through a bank account. If
the amount is below the CTR (Cash Transaction Reporting) limit then it will not be reported as per
This simply involves the purchase of goods, illegal money is converted into other
assets , such as real estate, diamonds, gold and vehicles, which can then be sold and proceeds can be
deposited in the account.
Bulk Movement :
It involves the physical transportation and smuggling of cash and monetary instrument
/such as money orders and cheques .
Securities Dealing :
Illegal funds are placed with securities firm which are used for buying bearer
securities and other easily transferable instruments.
This is the second stage of money laundering. In this stage, illegal funds or assets are moved,
dispersed and disguised to conceal their illegal origin. There are numerous techniques and
institutions that facilitates layering including the following.
- Offshore Banks
- Shell Corporations
- Walking Accounts
These banks accept deposit from non-resident individuals and Corporations. A number
of countries have well developed offshore banking sectors; in some cases combined with loose antimoney
A shell corporation is a company that is formally established under applicable
corporate laws, but doesn’t actually conduct a business instead, it is used to engage in fictitious
transactions or hold accounts and assets to disguise their actual ownership.
Trusts are legal arrangement for holding specified funds or assets for a specified purpose. These funds or assets are managed by a trustee for the benefit of a specified beneficiary or beneficiaries. Trusts can act as layering tools as they enable creation of false paper trails and transactions. The private nature of trusts make them attractive to money launders.
This is an account for which the account holder has provided standing instructions
that upon receipt, all funds should be immediately transferred into one or more accounts. By setting up a
series of walking accounts, criminals can automatically create several layers as soon as any fund transfer
lawyers, accountants and other professionals may be used as intermediaries or
middlemen between the illegal funds and the criminal. Professionals engage in transaction on behalf of a
criminal client who remains anonymous. The transaction may include use of shall corporations, fictitious
records and complex paper trails.
This is the third stage of money -laundering process. In this stage, illegal funds are successfully
legitimized by mixing with legitimate funds in the financial system.
There are various integration techniques including the following:
Import/ Export Transactions
- Import/Export Transactions
- Business Recycling
- Asset sales and purchases
- Credit and debits cards
- Corporate financings
to bring illegal money into the criminal’s country of residence, the
domestic trading company will export goods to the foreign trading company on an over-invoiced basis.
The illegal funds are remitted and reported as export earnings. The transaction can work in the reverse
direction as well.
legitimate businesses also serve as conduits for money laundering. Cash intensive
retail businesses, real estate. jewelers, and restaurants are some of the most traditional methods of money
laundering. This technique combines the different stages of the money laundering process.
Asset Sales and Purchases:
This technique can be used directly by the criminal or in combination with
shell corporations, corporate financings and other advanced means. The end results is that the criminal
can treat the earnings from the transaction as legitimate profits from the sale of the real estate or other
The use of consultant in money laundering scheme is quite common .The consultant could
be fake as the criminal himself could be the consultant .In this case, the criminal is channeling money
back to himself .This money is declared as income from servicer performed and can be used as legitimate
Credit and Debit Cards :
, This are effective ways for launders to integrate illegal money into the financial system
.By maintaining an account in an offshore jurisdiction through which payments are made , the criminal
ensures there is limited financial trails that leads to his country of residence.
individual first transfer illegal funds into an offshore account and also signs up for a debit card from the bank to utilize the funds.
Corporate financing are typically combined with a number of other techniques,
including use of offshore banks , electronic funds transfers and shell corporations.
The three basic stages may occur as separate and distinct phases. They may also occur simultaneously or,
more commonly, may overlap.
1.7 SOURCES OF MONEY LAUNDERING
Money Laundering may not just involve wealth related to Drug Trafficking / Terrorism Financing. List of
crimes identified by financing Action Task Force (FATF) as generators of criminal wealth also included:
1. Illegal arms sale
2. Gun running
3. Organized crimes including drug trafficking and prostitution
5. Smuggling (including movement of nuclear materials)
6. Counterfeiting (including making of imitation and copies of original products/goods)
7. Fraud, especially computer-supported fraud
8. Benefiting from insider trading
9. Bribery and kickbacks
10. Tax evasion
11. Under and over – invoicing of trade transactions
12. Bogus trade transactions to launder money through round -tripping
13. Facilitating illegal immigration
14. Real Estate transactions
1.7 TERRORIST FINANCING
1.8 THE NEED TO COMBAT MONEY LAUNDERING (ML) AND TERRORIST FINANCING (TF)
Terrorist Financing can be defined as the financial support, in any form, to terrorism or of those
who encourage, plan, or engage in terrorism. A terrorist group, like any other criminal
organization, builds and maintains an infrastructure to develop sources of funds and channel them
to those who provide materials and or services to the terrorist organization.
The prevention of ML and TF from the point of view of the Bank has three dimensions:
- Ethical - Taking part in the prevention of crime
- Professional – ensuring that the Bank is not involved in recycling the proceeds of
crime that would call into question its reputation, integrity and, if fraud is
involved, its solvency.
- Legal - Complying with laws and Regulations that impose a series of specific
obligations on financial institutions and their employees.
The need also arises due to the severe nature of consequences of ML and TF. The
following are some examples:
-Unexplained changes in supply and demand for money
-Volatility of capital flows and exchange rates due to un-anticipated cross border
-Contamination of legal financial transactions,
-Threat to the functioning of economy’s financial system,
-Unlawful enrichment by perpetrators of crime,
-Dampening effect on foreign direct investment,
-Weakening of the social, collective ethical standards,
-Drug trafficking, Human Trafficking
-Terrorism crimes cause a great deal of human misery,
-Prudential risks to bank soundness arising from these developments.
1.9 REGULATORY OVERSIGHT & COMPLIANCE RISKS
Blockvila has used guidelines and International Regulatory guidelines/ standards as
applicable to formulate its own AML/CDD/CFT policy. The consequences of contravening the
Regulations or failing to comply can be significant and include disciplinary measures,
imprisonment or fine or both under local laws as well as the loss of reputation for the bank.
Notwithstanding the statutory and regulatory penalties, increased vigilance by management and
staff will protect Blockvila from the following risks:
The reputation of a business is usually at the core of its success. The ability
to attract good employees, customers, funders, funding and business is dependent on reputation.
Even if the business is otherwise doing all the right things, if customers are permitted to
undertake illegal transactions through that business, Its reputation could be irreparably damaged.
A strong AML/CDD/CFT policy helps to prevent a business from being used as a vehicle for
This is the risk of direct or indirect loss from faulty or failed internal
processes, management and systems. In today’s competitive environment, operational excellence
is critical for competitive advantage. If AML/CDD/CFT policy is faulty or poorly implemented,
then operational resources are wasted, there is an increased chance of being used by criminal for
illegal purposes, time and money is then spent on legal and investigative actions and the business
can be viewed as operational unsound.
If a vehicle is used as a vehicle for illegal activity by customers, its faces the risk of
fines, penalties, injunctions and even forced discontinuance of operations.
If a business does not adequately identify and verify customers, it may run the
risk of unwittingly allowing a customer to pose as someone he/she is not. The consequences of
this may be far reaching. If a business does not know the true identity of its customers, it will
also be difficult to retrieve money that the customer owes.
LEGAL AND REGULATORY OBLIGATION
2. LEGAL/ REGULATORY OBLIGATIONS
2.1 LEGAL OBLIGATIONS
Blockvila is obligated to comply with the requirements of the AML law and with the
relevant provisions of Financial service/ Banking Act as and when they are promulgated.
In addition, Blockvila under the Anti-Terrorism Act 1997 and control of Narcotics
Substance Act 1997 is obligated to take prompt and immediate notice of all unusual or
large transactions in customer account, which apparently have no genuine economic or
lawful purpose. Oversea customers should follow regulations of the host country under
2.2 REGULATORY OBLIGATIONS
Under Financial Monitoring Unit (FMU) and International Regulations there are personal
obligations on every member and staffs to report suspicious activities. If a person is
aware or suspects that a transaction or instructions is related to any crime, he/she must
report the transaction to Blockvila compliance even if he /she is not directly handling
the transaction, instruction or funds in question.
Blockvila itself Has Similar Obligations.
It is a regulatory requirement for a financial service / institution to have in place policy
and procedures to combat money laundering /terrorist financing. The policy/ procedures
as a minimum must include:
- Setup a compliance Unit with a full time CCO/CO
- The verification of new client’s identification, CDD (Know Your Customers)
profiling, update customer’s information and record at reasonable intervals
- Risk- based controls
- Awareness arising and training of staff members
- Recognition and Reporting suspicions of money laundering / terrorist financing.
- Retention of records
- Independent testing (Internal/ external Audits):
- CCD Measures for Occasional Customers/ walk -in customers
- Handling wire transfers/ funds transfers
- ML/CFT threats that may arise from the use of new or developing of new
products and technologies.
Oversea customers and subsidiaries of Blockvila should follow the host
country /state regulatory requirement. Moreover, if their host country requirement
conflicts with the AML/CFT requirements of Blockvila, the subsidiaries
branch of Blockvilas shall report to the Head office which will comply with
such further directions as may be issued.
It is criminal offence if management or staff:
1. Acquire proceeds of a crime or assist anyone whom they know or suspect has
committed, or benefited from any criminal conduct. (Acquire, possess &
2. Prejudice an investigation by informing the suspect of a suspicion, or any
third party that a disclosure has been made either internally or externally ,or
that the authorities may act or propose to act or investigate .(Tip off)
3. Acquire knowledge or a suspicion, or has reasonable grounds to know or
suspect, that benefit has been gained from criminal conduct or that the
proceeds of crime have been laundered, and have not reported the same as
soon as possible. (Failure to Report)
4. Have not implemented effective systems, controls and procedures to guard
against money laundering. (System &Controls)
2.3 NOTES ABOUT MONEYLAUNDERING ACT 2011
The Nigerian Government has put massive focus on the anti- corruption fight ,
and the Money laundering ( prohibition )Act 2011 ( and the amendment to the
act in 2012) is a big part of this fight .
CAP ON CASH TRANSACTIONS
The money laundering (Prohibition) Act 2011 makes it illegal for any individual
to accept or make cash payment that exceeds N5M (Five Million Naira). This
means that every cash transaction over N5m must be done via a financial
Any person guilty of contravening is liable to imprisonment for
the term of not less than 3years or a fine of N10m (Ten Million Naira) or to both.
DECLARATION WHEN TRANSPORTING CASH OVERSEAS
The Money Laundering (prohibition) Act 2011 states that any individual who is
transporting cash or negotiable instrument in excess of US$10,000 or its
equivalent must be declared to the Nigerian Custom Service.
The penalties: Non- declaration of funds or false declaration is an offence that is
punishable upon conviction by the individual forfeiting the funds in question or to
imprisonment of not less than 2years or to both.
DATA RETENTION BY FINANCIAL INSTITUTIONS AND DESIGNATED NON- FINANCIAL INSTITUTIONS
The Act provides that the above institutions shall keep record of a customer’s
identification for a period of at least 5 years after the closure of the account or the
severance of relations with the customer.
This therefore means irrespective of the fact that you have closed your account or
dealings with the above institutions, they are still obliged by law to keep a record
of your details.
Blockvila’S POLICY FOR AML/CDD/CFT
3. Blockvila’S POLICY FOR AML/CDD/CFT
Keeping in view the Global threat, Blockvila has taking various steps to counter
the menace of money laundering and terrorist financing. Blockvila is stringently
focusing on core compliance functions and has adopted a robust policy across the
network to remain compliant with AML/CFT regimes in all jurisdictions.
It is the policy of Blockvila that:
3.2 CUSTOMERS DUE DELIGENCE (CDD)
- Statutory, regulatory and legal obligations to prevent ML and TF are fully
- Systems and controls are implemented and reviewed on set frequency in other to
minimize the risk of Blockvila’s services being abused for the purposes of ML
- A money laundering risk assessment of Blockvila’s services and customer
base including correspondent banks and MSBs (Money Service Businesses) are
undertaken and appropriate policies, procedures and due diligence controls are
applied proportionate to that risk.
- Blockvila would not do business with :
- Individuals /entities subject to UN sanctions
- Individuals /entities under Nigeria’s sanction as applicable
- Unauthorized Money changers/prize bond dealers
- Anonymous Customers
- Customers hiding beneficial ownership of account
- Client or business segment black listed by Blockvila, banks, or by
- Shell banks and offshore corporate clients
- Government officials willing to open government accounts in their own
- To carry out enhanced due diligent before establishing relationships with
the following High risks customers
- Trusts, NGOs, NPOs, Foundations, Welfare Association, Religious
Entities, Clubs, Societies, Financial Institution, Authorized Money
Exchange Companies , controversial entity, jewelers ,Arms Dealers.
- Politically Exposed Persons (PEPs)
- Correspondent Relationship
- Customers using their personal accounts for business transactions
- Private Banking customers
- Institutions/individuals whose association could be considered
- Any individual or entity that that has caused or has been related to a
credit, operational or reputational loss.
- Account of foreign nationals belonging to sanctioned countries
- Non- face to face / online customers,
- Walk in customers
- Non-resident customers
- Customers in cash based business
- High risk geographies
- Customers reportedly having previous unsatisfactory/suspicious social
- High net worth customers with no clearly identifiable source of
- Legal persons or arrangements that are personal asset holding vehicles
- There is a doubt about the veracity or adequacy of available
identification data on the customer
- Any customer relationship where the customer’s conduct gives
Blockvila reasonable cause to believe or suspect involvement with
illegal activities is required to be reported to the Regulators or relevant
- In countries like Nigeria where local regulators all for a money laundering
compliance reports, respective country MLROs are responsible for
preparation and submission of these reports, CCO, CO would submit a
quarterly compliance report (including significant AML/CFT issues) to
Board Audit Committee
- Management shall establish criteria of identifying and assessing ML/FT
risks that may arise in relation to new products, services, business practices and delivery mechanics including the review of existing products
and services on on-going basis.
CDD is closely associated with the fight against money- laundering. Supervisors around
the World are increasingly recognizing the importance of ensuring that their financial
service have adequate controls and procedures in place so that they know the customers
with whom they are dealing. Adequate due diligence on new and existing customers is a
key part of these controls. Without this due diligence, financial service /banks can be
exposed to reputational, operational, legal and financial risks.
It is a policy of Blockvila that:
3.3 AML/CDD/CFT ASSOCIATED POLICIES.
- Prior to establishing a relationship with a new customer , basic background
information about the customer should be obtained including identifying the
customer and verifying the customer’s identity on the basis of documents, data or
information obtained from customer and /or from reliable and independent
sources, furthermore , understanding and , as appropriate , obtaining information
on the purpose and intended nature of the business relationship, information
related with customer’s business and source/ utilization of funds and the expected
level of activity.
- Blockvila shall take reasonable measures to identity and verify identities of
beneficial owner(s) in relation to a customer. Furthermore, in case of a legal
person , trust or similar legal arrangement , measures shall be taken to understand
the ownership and control structure of the legal person or entity.
- Customer’s profile must be updated periodically based on the risk profiling of the
customer. Customer activity must be monitored against a pre- determined profile
on ongoing basis , paying special attention to higher risk customers or activities,
furthermore , to take prompt action when there is material departure from usual
and expected activity through regular matching with information already available
with a financial service as Blockvila.
Following associated policies form an integral part of the AML/CDD/CFT policy and
have been developed specifically to achieve the objectives outlined in Blockvila’s
policy and the regulatory requirements of the Financial Monitoring Unit.
3.5.1 Internal Control Compliance and Audit.
It is a policy of Blockvila:
3.5.2 Recognition and Reporting of Suspicion
- To design and implement processes, systems, and controls to comply with all
applicable AML/CFT Laws and regulations.
- To conduct risk assessment and develop risk profiles of Blockvila’s
customers, products and services and to apply appropriate policies and
procedures to manage such risks.
- To undertake due diligent of high risk customers
- AML/CFT policy duly approved by their Board of Directors shall be
circulated down the line to each and every business location and concerned
employees for meticulous compliance. The detailed procedures and controls
shall be developed by the financial service in the light of policy approved by
To conduct risk assessment and develop risk profile of Blockvila’s
customers, products and services and apply appropriate policies and procedure
to manage such risk. Risk profiling of customer shall be based on various
factors including customer, product and services, delivery channel and
It is a policy of Blockvila :
3.6 AWARENESS ARISING FROM TRAINING
- To establish and follow procedures that require employees to report promptly
any suspicious activity to Blockvila for further review.
- To act competently and honestly when assessing information and
circumstances that may give reasonable grounds to suspect Ml and TF.
- To provide MLROs with its request access to all customers information that
are within the possession of Blockvilas.
- To co-operate with law enforcement authorities to investigate possible ML
and TF within the conflicts or the applicable laws, and in consultation with
- To comply with provisions AML/ CFT Act, rules and regulations issued there
under transactions in the context of Money Laundering or financing of
- Not to alert or provide any information to any person regarding suspicious or
inquiry on his/her account or transactional activities or any indication of being
reported to Regulators.
It is a policy of Blockvila:
3.6 RECORD KEEPING
- To make all management and staff aware of what is expected of them to prevent
money laundering and terrorist financing and to advise them of the consequences
for them and for Blockvila if they fall short of that expectation.
- To chalk out and implement suitable training programs for relevant employees, in
other to effective implement the regulatory requirement and Blockvila own
policies and procedures relating to AML/CFT. Furthermore, management shall
pay special attention to comprehensive AML/CFT computer -based / online
- The management and staffs are required to sign a memorandum confirming they
have read and understood Blockvilas’s AML/CDD/CFT policy and
procedures. Changes made on set frequencies or on adhoc basis to this policy
should be communicated to staffs.
It is the policy of Blockvila :
3.7 NON-COMPLIANCE OF Blockvila’S POLICY
- To retain identification and transaction documents for the minimum period as
required by applicable laws and regulations.
- To be in position to retrieve record that are required by law enforcement agencies for
- To keep record of AML/CDD/CFT training provided to the employees, nature of the
training and the names of staffs who received such trainings.
Failure to abide by the policy set by Blockvila to prevent money laundering and
terrorist financing will be treated as a disciplinary issue. Any deliberate breach will be
regarded as Gross misconduct. Such case will be referred to HR which could lead to
termination of employment and also result to criminal prosecution and imprisonment
for the concerned staff.
3.8 ACCOUNTABILITY AND RESPONSIBILTY
3.8.1 The Board of Blockvila is Responsible for :
3.8.2 Blockvila’s Compliance/ MLRO are responsible for :
- To ensure that adequate system and control are in place to deter criminal
activity, money laundering and terrorism financing.
- Approval of appropriate policy of AML/CDD/CFT on recommendation
with management along with periodic reviews of the same with necessary
3.8.3 ALL Employees Are Responsible for:
- Developing and maintaining policy in line with evolving statutory and
- Undertaking the required money laundering/ terrorist financing risk
assessment for customers, products and services.
- Developing and ensuring that the internal procedure stays up to date at all
- Monitoring and identifying transactions of suspicious nature and making
sure to report such transactions to the Regulators on a timely manner.
- Ensuring that staffs are aware of the specific obligations and adequate
training in prevention of ML/TF.
- Preparing quarterly report of AML compliance for onward submission to
the Board Audit Committee.
- Remain vigilant to the possibility of money laundering and terrorist
financing through use of Blockvila’s products and services.
- Complying with all AML/CFT policies and procedures in respect of
customers identification, record keeping, reporting and account
- Employees who violate all the regulations of AML/CDD/CFT procedures
and policies will be subject to disciplinary actions.
If you have any questions or comments about these our policy as outlined above, you can contact us at:[email protected]
20 Mbonu street, Dline, Port Harcourt, Rivers State, Nigeria.