Zowasel AML/CFT Policy

The Policy supports, but does not replace, applicable laws such as:

• Securities and Exchange Commissions (Anti-Money Laundering/Combating Financing of Terrorism Regulations for Capital Market Operators), 2013
• Prohibition Act, 2011 (as amended)
• Terrorism Prevention Act, 2011 (as amended)
• Any other relevant laws

• Ensure compliance risks (reputational, legal, and economic) are easily identified and adequately mitigated.
• Prevent the abuse of ZOWASEL resources for Money Laundering (‘ML’) and Terrorism Financing (“TF”).
• Minimize the risks the Company faces from relations or transactions related to ML, TF, or any other illicit activity.
• Protect the integrity of the securities market against all forms of abuse, fraud, and unfair trade practices.
• Guide standards of conduct and practice for implementing KYC and CDD requirements in agriculture and finance.

Compliance Officer

An individual with relevant competence, authority, and independence to implement the AML/CFT compliance policy.

Securities and Exchange Commission

The Securities and Exchange Commission established under the Investments and Securities Act, 2007.

Money Laundering

The concealment of the illegal origin and illegitimate ownership of property and assets derived from criminal activities.

Financing of Terrorism

Activities providing legitimate or illegitimate money, characterized by concealment of the origin or intended criminal use of the funds.

Know Your Customer (KYC)

Due diligence activities involving obtaining and verifying customer identity, preserving customer records, and mandatory transaction disclosures.

Customer Due Diligence (CDD)

Steps taken to identify clients and validate their identities.

Nigeria Financial Intelligence Unit (NFIU)

Analyzes disclosures from reporting organizations and provides financial intelligence to combat financial crimes.

Politically Exposed Persons (PEPs)

Individuals entrusted with prominent public functions in any country, presenting a higher risk for bribery and corruption.

• Formulate and implement internal controls and procedures to deter fraudulent use of its facilities for money laundering and terrorist financing, ensuring compliance with applicable laws and regulations.
• Designate an AML/CFT Chief Compliance Officer at the management level with relevant competence, authority, and independence to implement the compliance program.
• Comply with the Money Laundering (Prohibition) Act, 2011 (as amended), Terrorism (Prevention) Act, 2011 (as amended), and Terrorism Prevention Regulations 2013, including related laws and regulations.
• Comply promptly with requests from the SEC, Nigerian Financial Intelligence Unit (NFIU), and other law enforcement agencies on AML/CFT matters.
• Identify and report suspicious transactions derived from criminal activities to the NFIU.
• Ensure the implementation of AML/CFT requirements is not inhibited by confidentiality agreements or policies.
• Exit relationships that pose heightened money laundering risks and raise staff awareness of AML/CFT issues.

• An entity with a business relationship with Zowasel.
• Any entity connected with a financial transaction posing significant reputational or other risks to Zowasel.

In dealing with clients, Zowasel shall:

• Obtain necessary documents and information from every client.
• Report suspicious transactions to regulatory authorities.
• Update client information frequently.
• Identify clients and beneficial owners, verifying their identity using reliable sources.
• Conduct independent verification of legal status for entities via the Corporate Affairs Commission.
• Refuse to transact with "shell companies" or individuals described in international conventions.
• Perform enhanced due diligence for high-risk clients, relationships, or transactions, including:
  • Politically Exposed Persons (PEPs), cross-border transactions, and relationships.
  • Any other activities prescribed by regulatory or supervisory authorities.

• Transactions belonging to entities considered to be terrorist organizations.
• Transactions structured to avoid reporting and record-keeping requirements.
• Altered or false identification or inconsistent information, or transactions involving criminal activity.

Zowasel shall ensure timely and accurate rendition of all AML/CFT returns as specified in the SEC AML/CFT Rules and Regulations, and other relevant Regulations, Acts, Guidelines, or Circulars issued by government agencies.

• Nature of the customer and their agribusiness: Includes the source of commodities, finances, and agribusiness history.
• Purpose and activity: The size, purpose, and services involved in the relationship.
• Relationship: The nature and duration of Zowasel's relationship with the customer.
• Corporate structure: The organization of the customer's business.
• Public information: Information about the client known or reasonably available to Zowasel.

Board of Directors

• Decision-making based on quarterly AML/CFT reports.
• Ensuring the formulation and review of an operational AML/CFT Policy.
• Ratifying the AML/CFT Policy as approved by the BRRAC.

Board Regulation, Risk, and Audit Committee (BRRAC)

• Approving the AML/CFT Policy.
• Reviewing all periodic AML/CFT reports.
• Guiding the management of AML/CFT compliance risks.

Chief Executive Officer (CEO)

• Ensuring controls mitigate identified compliance risks.
• Developing and managing the AML/CFT Policy.
• Ensuring implementation of Board decisions on compliance matters.

Compliance Officer

• Developing an AML/CFT Compliance Program.
• Coordinating staff training on AML/CFT awareness.
• Ensuring compliance with the Code of Ethics.

Internal Audit

• Incorporating compliance testing into audit programs.
• Reporting independent testing results to the Board via the CEO and BRRAC.

All Staff

• Implementing AML/CFT measures diligently.
• Reporting violations or misconduct in line with Zowasel’s policies.