Definition

Money laundering is the act of converting money or other material values gained from illegal activity (terrorism, drug dealing, illegal arms trade, corruption, human traffic, etc) into money or investments that appear to be legitimate. Such activity is used to hide the illegal source of money so that the material values cannot be traced.

Main Purpose

The main purpose of the Policy is to establish the essential standards designed to prevent OkwaIfugo Integrated Services Nig Ltd (hereinafter called " NairaOmm, Company") from being used for money laundering and terrorism financing. Other objectives pursued by this Policy are as follows: • Promote a "Know Your Customer" policy as a cornerstone principle for the Company business ethics and practices; • Introduce a controlled environment where no business with a Customer is transacted until all essential information concerning the Customer has been obtained; • Conduct self-assessments of compliance with AML policy and procedures.

Identification

Identification of the money laundering risks of customers and transactions allows us to determine and implement proportionate measures and controls to mitigate these risks. Some of the used risk criteria are the following: - Country risk, in conjunction with other risk factors, provides useful information as to potential money laundering risks. Factors that may result in a determination that a country poses a higher risk include: • Countries subject to sanctions, embargoes or similar measures; • Countries identified by the Financial Action Task Force ("FATF") as non-cooperative in the fight against money laundering or identified by credible sources as lacking appropriate money laundering laws and regulations; • Countries identified by credible sources as providing funding or support for terrorist activities.

Customer Risk

Customer risk - there is no universal consensus as to which customers pose a higher risk, but the below listed characteristics of customers have been identified with potentially higher money laundering risks: • Armament manufactures, • cash intensive business; • unregulated charities and other unregulated "non profit" organizations.

Regulatory Requirement

REGULATORY REQUIREMENTS INTENDED TO FORESTALL AND PREVENT MONEY LAUNDERING. These include: Customer Due Diligence and Know Your Customer • We verify and document the true identity of customers and obtain background information on customers as well as purpose and intended nature of the business; • We obtain and document any additional customer information, commensurate with the assessment of the money laundering risk using Risk Based Approach; • We establish whether the Customer is acting on behalf of another natural person or legal entity as trustee, nominee or professional intermediary. In such cases a necessary precondition for Customer acceptance is receipt of satisfactory evidence of the identity of any intermediaries and of the persons upon whose behalf they are acting, as well as the nature of the trust arrangements in place.

Our Records

Record keeping • Records must be kept of all documents obtained for the purpose of identification and all transaction data as well as other information related to money laundering matters in accordance with the applicable anti-money laundering laws/regulations; • All records must be kept for at least 3 years. Monitoring and reporting of suspicious transactions/activity • All personnel must be diligent in monitoring for any unusual or suspicious transactions/activity basing on the relevant criteria applicable in the jurisdiction where the Company operates. • The reporting of suspicious transactions/activity must comply with the laws/regulations of the respective jurisdiction.

Notice

Please note that NairaOmm under the aforementioned laws has the right to refuse a transaction at any time should suspicion arise that it may be connected to money laundering or any other criminal activity. In addition, NairaOmm will be obliged to report this suspicious activity in order to comply with said regulations, and internationally accepted laws and customs which also prohibits NairaOmm from disclosing this information. Providing NairaOmm with false identification or contact details will be deem as a misuse of our Terms of Service. NairaOmm is legally bound to report such misdemeanors to the Nigeria authorities, and as such you may be the subject to a criminal investigation. NairaOmm will NOT do business with anyone suspected of, or directly involved in Money Laundering, or where funds have been sourced by any illegal activity. I have read NairaOmm's Privacy Policy and understand and accept all terms and conditions contain herein, specially I accept and understand that NairaOmm is authorized to finalize the contractual relationship with myself and/or the firm I represent, lawfully and immediately, with no responsibility whatsoever, If I violate any of the clauses of this privacy policy and/or regulations of the law or any other applicable laws and regulations.