Board and Management Responsibilities
The Board of Directors is our naught line of defence and assumes overall responsibility for the
AML/CFT risk management framework in the bank.
The Board reviews and approves the policies on an annual basis to ensure that they are fully
aligned with the bank's strategic vision.
The Board ensures that the Bank's Management and all employees conform
strictly with all regulatory and internal procedures relating to AML/CFT and that the Bank
maintains a zero tolerance to regulatory infraction.
Reports to the Board and Senior Management
AML & CFT reports are submitted periodically to Board and senior management respectively.
These reports provide the Board and senior management with information to enable them to assess
the Bank's compliance with its regulatory obligations.
The reports also ensure that Directors and senior management are kept
abreast on current trends and developments in the financial industry, particularly in the area
of AML/CFT risk management.
Customer Identification and Verification
Globus Bank has put in place a strict Know Your Customer (KYC) program to
ensure all categories of customers (natural or legal persons or legal structures) are subject to
adequate identification, verification and risk rating.
KYC includes not only knowing the customers and entities the Bank deals with (either as a single
transaction or ongoing relationship), or renders services to, but also the Ultimate Beneficial
Owners (UBOs), legal representatives, directors and authorized signatories as appropriate.
The program includes strict identification requirements, name screening procedures and the
ongoing monitoring and regular review of all existing business relationships.
Financial Crimes Surveillance
Globus Bank monitors all customer transactions, applying a risk-based approach. Adequate notice
and justification are taken on frequency, volume and size of transactions, in the context of the
assessed customer and product risks.
There are four aspects to the monitoring of transactions:
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Pre-execution transaction monitoring to identify transactions which would if executed result
in a breach of applicable sanctions or embargos
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Post-execution transaction monitoring to identify transactions which are considered
suspicious and required to be reported to the relevant authorities
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Based on the result of the initial Customer Due Diligence (CDD) assessment, risk-based
approach ongoing monitoring of customer activity will be carried out using appropriate
software.
This monitoring process will also ensure that the KYC information held about the customer is
up-to-date
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Ad-hoc monitoring to identify suspicious activity, but as implied, it is an activity which
is undertaken on a more informal basis.
It is a procedure which should be undertaken by all members of staff of Globus Bank, and can
be one of the most effective means of identifying suspicious activity.
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Employees are protected if they report, in good faith, any suspicious activity.
Reporting Obligations
The bank is obligated to make certain reports and returns to regulatory and intelligence bodies
under the Money Laundering (Prohibition) Act 2011 as amended ('The Act') and the CBN AML/CFT
Regulations 2013.
Threshold reports are covered under Section 2 and Section 10 of the Act. Section 2 provides that
financial institutions must submit a report on all international transfer of funds and
securities of a sum exceeding ten thousand dollars ($10,000) or its equivalent in other foreign
currencies
Similarly, Section 10 of the Act provides that any lodgement or transfer of funds in excess of
N5 million and above for individuals and N10 million and above for corporate customers must be
reported.
On the other hand, Section 6 of the Act provides that a financial institution must submit a
report on all unusual and suspicious transactions.
International Sanctions
The bank prohibits the use or access of its products and services by or for the benefit of any
person named on a sanctioned list.
All new/existing customers will be screened against publicly available sanctions lists
(including the bank's internal watch list) and against updates to any applicable lists within a
reasonable time of these updates being made available.
Customer transactions are also screened to ensure that they are not made to sanctioned
individuals and entities.
All staff are required, as part of the Bank's policy, to refrain from any relationship and/or
transaction which yield a true or positive match and follow the escalation procedure.
Politically Exposed Persons (PEPs)
To a certain degree, holders of public functions and those holding senior, prominent or
important positions with substantial authority over policy, operations or the use or allocation
of government own resources are exposed to the possibility of corruption or the abuse of their
position.
This set of people and the entities beneficially owned by them are considered as posing greater
risk to a bank and are accordingly categorized as Politically Exposed Persons for the purposes
of AML control and oversight.
In dealing with PEPs, Globus Bank will undertake enhanced due diligence to satisfy itself of the
legitimacy of the customer's source of wealth as well as funds and nature of the business.
Senior management approvals are required before such customers are on-boarded and when any
existing customer becomes PEP.
The bank will also consider the requirement for ongoing transaction monitoring for potentially
suspicious behaviour.
Relationship with Correspondent Banks
Correspondent banking relationships are subject to appropriate customer due diligence and review
which includes, among other things, confirmation that the entity has the appropriate licences to
operate in its country of origin and due diligence to avoid working with or through shell banks.
Awareness and Training
Globus bank has implemented a comprehensive AML/CFT training program to ensure that all Board
members, Senior Management and staff (in particular individuals responsible for transaction
processing and/or initiating and/or establishing business relationships,) undergo AML/CFT
awareness training
Globus Bank's training is tailored to the business to ensure that staff
are aware of different possible patterns and techniques of money laundering which may occur in
their everyday business.
Training also covers the general duties arising from applicable
external (legal and regulatory), internal requirements and the resulting individual duties which
must be adhered to in everyday business as well as typologies to recognise money laundering or
financial crime activities
Anti-Bribery and Corruption
Globus Bank has strict prohibitions against bribery and corruption when dealing with both
clients and suppliers.
The use of position/office and taking advantage of the institution to enrich oneself is
prohibited.
Offering/acceptance of gratification to/from customers/potential customers/suppliers/vendors to
do business is prohibited.
Bribery and corruption are also offences that attract well known consequences such as warning,
suspension, termination or dismissal, depending on the gravity of the offence.
Record Keeping and Retention
As provided for in the Act, customer identification documents are
retained throughout the life of the account and for five (5) years after the cessation of the
banking relationship, except in cases of litigation and/or regulatory investigations. In the
case of the latter, the records will be kept for as long as they are required.
Upon request by a regulatory or law enforcement agency, Globus Bank
shall make available records related to AML/CFT compliance or its customers as soon as possible
from the date of the request.
Cooperation with Regulators, Law Enforcement and
Intelligence Agencies
Globus Bank gives full cooperation to law enforcement and intelligence agencies within the
limits of the rules governing confidentiality.
In full understanding of the crucial role financial institutions play in the fight against money
laundering and terrorism financing,
the bank promptly complies with all requests validly made pursuant to extant laws and provides
necessary information to authorized agencies.
Where the bank becomes aware of facts which lead to the reasonable presumption that money held
on deposit derives from criminal activity or that transactions entered into are themselves
criminal in purpose,
appropriate measures, consistent with the law, are taken, for example, to deny assistance, sever
relations with the customer, close or freeze accounts and give full disclosure to the regulatory
and intelligence agencies.
Independent Assessment of AML/CFT Compliance program
Adherence to the requirements of Globus Bank's AML program is subject to independent testing by
the bank's Internal Audit function on a biannual basis.
The report and findings of the audit are circulated to various levels of senior management.
A follow-up to the audits takes place to ensure that the relevant issues are closed out and
highlighted recommendations have been implemented.