AML/CFT/CPF Policy
Lagos Building Investment Company commits to the fight against money laundering (ML), financing of terrorism (FT), proliferation financing (PF) and all other forms of financial crimes. As a compliant body, it continually applies these principles and ensures that all stakeholders comply with AML/CFT/PF laws in all dealings. In line with corporate governance and adherence to regulatory directives, the Bank has established policies to guide against these financial crimes and requires total compliance in all its dealings..
Objectives of the Policies
The objectives of LBIC’s AML policy are as follows:
- Establish clear roles and responsibilities to manage money laundering risks.
- Formulate a risk-based approach to Customer Due Diligence (CDD) at on boarding and ongoing monitoring of customer activities with the Bank.
- Initiate procedures to ensure that suspicious activity is reported in accordance with requirements prescribed by local laws and regulations and shared, where legally permissible and relevant, within the Bank.
- Serve as a reference guide for all AML/CFT/CPF related issues.
Regulatory Framework
The AML policy of LBIC is formulated in compliance with the predominant regulations outlined below:
- Money Laundering (Prevention and Prohibition) Act 2022
- Terrorism (Prevention and Prohibition) Act 2022
- CBN AML/CFT/CPF Regulations 2022
- Central Bank of Nigeria Act, 2007
- SEC Rules and Regulations 2011
- Advanced Fee Fraud Act 2006
- Banks and Other Financial Institutions Act 2020 as amended
- Corrupt Practices and Other Related Offences Act 2000
- Economic and Financial Crimes Commission (Establishment) Act 2004
- NDLEA Act 2004
Policy Statement
- The company’s Board has a function of oversight of the AML policy. The Company’s designated Head of Compliance is appointed by the Board.
- Know Your Customer (KYC) and due diligence are well established and conducted during the onboarding stage. While Enhanced Due Diligence (EDD) is conducted for all high-risk accounts, Simplified Due Diligence is carried out for all other relationships. An effective risk assessment is conducted during the onboarding stage and at various stages of the customer journey to ensure proper risk profiling.
- All other parties with an interest in doing business with LBIC, such as employees, vendors, and customers, are encouraged to read over the terms of these policies. Reporting any legal infractions or other misconduct is necessary so that appropriate investigations can be conducted.
- LBIC must render all statutory and mandatory regulatory reports
Prohibited Businesses
LBIC has no appetite for clients whose businesses are conducted in Prohibited Special Risk Countries (SRCs), Shell businesses and Dealers in arms and weapons. Customers are screened against these categories of customers during onboarding and continuously.
Other Controls
In addition, LBIC has put in place other measures to safeguard all stakeholders from financial crimes. These include periodic staff regulatory compliance training, record keeping and retention, data protection, designation of the Head of Compliance, board approved policies, and periodic compliance audits.