Money laundering is the process of making money earned from criminal activity appear to have a legitimate source. It’s a multi-stage process where the money is accumulated, separated from its original source, mixed with legitimately-earned funds and then funneled back to its original source. Money Laundering empowers corruption and organized crime where corrupt public officials and criminals can launder proceeds from crimes, bribes, kickbacks, public funds and on some occasion, even development loans from international financial institutions. Organized criminal groups want to be able to launder the proceeds of drug trafficking and commodity smuggling through the financial systems without a trace. In the modern-day definition, Money Laundering now covers various predicate offences including child trafficking, prostitution, etc.
TRILBERTECH LIMITED is committed to fighting money laundering and complying fully with anti-money laundering laws in Nigeria. We understand that we have responsibilities to help fight the global battle against money laundering and our commitment will supersede all other privacy obligations contained in our policies. Accordingly, Trilbertech Limited will take all reasonable and appropriate steps to prevent persons engaged in money laundering, fraud, or other financial crimes from utilizing our products and services. Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and FINRA rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business. The AML Policy encompasses, but is not limited to the following activities:
Trilbertech has formulated and implemented 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.
KNOW YOUR CUSTOMER
Establishing and maintaining a risk-based approach to Customer Due Diligence (CDD), including customer identification, verification and KYC procedures. To ensure we meet these standards, our customers are required to provide certain personal details when opening an account and also generate OTP and password for any withdrawal request. The nature, and extent, of what is required is guided by the customer’s deposit and withdrawal limits, account to be used and in some cases, the customer’s country of residence. In certain circumstances,
TRILBERTECH may perform enhanced due diligence procedures for customers presenting a higher risk, such as those transacting large volumes etc. Maintaining appropriate KYC records for the minimum prescribed periods.
AWARENESS AND TRAINING
Trilbertech implements appropriate training and awareness for all its employees on AML/CFT. We provide awareness to our customers through newsletters, flash-news, online and in-person training sessions etc. These trainings and awareness take cognizance of emerging trends, regulations and standards on ML/FT risk.
Transaction monitoring is performed both manually and automatically. The former is carried out by all employees, who are routinely supplied with red flags to watch for, while the latter is handled by the Compliance Unit. All employees are informed that suspicious activities/transactions should be reported immediately to the Compliance Unit. Suspicious Transactions are brought to the Compliance Unit’s notice manually or automatically, with the former via internal suspicious transaction reports filed with the Compliance Unit and the latter via transaction monitoring tools examined by Compliance Officers. If considered necessary, a report is submitted to the appropriate regulatory body. To effectively monitor transactions coming through Bingpay Finance’s systems, the SAS Anti-Money Laundering tool has been fully implemented, representing a significant development in the way transactions are monitored and probed.