Demtri Anti-Money Laundering (AML) Policy

1. Introduction

Demtri is committed to the highest standards of anti-money laundering (AML) and combating the financing of terrorism (CFT) in accordance with the Money Laundering (Prohibition) Act, 2011 (as amended) of Nigeria. This policy outlines our procedures to prevent, detect, and report any suspicious activities.

2. Objectives

• Prevent the use of Demtri's services for money laundering or terrorist financing.
• Ensure compliance with all relevant AML laws and regulations in Nigeria.
• Promote a culture of compliance and integrity within Demtri.

3. Customer Due Diligence (CDD)

Demtri performs CDD measures in accordance with Nigerian AML regulations to verify the identity of all customers. This includes:

• Collecting valid identification documents such as National ID, Driver’s License, or International Passport.
• Verifying the authenticity of documents provided through government databases where applicable.
• Conducting risk assessments based on customer profiles, nature of transactions, and geographic location.

4. Ongoing Monitoring

We continuously monitor transactions to detect suspicious activities. This involves:

• Reviewing transactions for consistency with the customer's known activities.
• Flagging unusual patterns or large transactions for further investigation.
• Implementing transaction thresholds in line with the Central Bank of Nigeria’s guidelines.

5. Reporting Suspicious Activities

All suspicious transactions are reported to the Nigerian Financial Intelligence Unit (NFIU) in compliance with the Money Laundering (Prohibition) Act. Employees are trained to identify and report such activities promptly.

6. Record Keeping

Demtri maintains detailed records of all transactions, customer identification documents, and reports of suspicious activities for a minimum of five years, as required by Nigerian law.

7. Training and Awareness

Regular AML training is provided to all employees to ensure awareness of the latest regulations, detection methods, and reporting procedures. This includes periodic updates based on changes in Nigerian AML laws.

8. Compliance Officer

A designated AML Compliance Officer oversees the implementation and enforcement of this policy, ensuring adherence to all legal and regulatory requirements as stipulated by Nigerian authorities.

9. Policy Review

This policy is reviewed annually or whenever there are significant regulatory changes in Nigeria to ensure its effectiveness and relevance.

Effective Date: February 10, 2019