Access Bank AML Compliance Program
- It is the policy of Access Bank Plc to comply with all applicable laws, regulations and corporate ethical standards and policies in the conduct of our businesses.
- The protection of our franchise and the sustainable growth of our business as well as delivering on our business goals are dependent on conducting our operations within the letters and spirit of all laws, regulations and policies that apply to and govern our activities.
- It is imperative that every one of our staff focuses on compliance as an integral part of our business responsibilities.
- Access Bank Management will continue to maintain the trust and confidence of its customers, and all stakeholders through its AML/CTF policy.
- The Chief Compliance Officer of our bank is a Senior Management staff.
- The bank takes an extra mile in ensuring that only credible customers are maintained as clients in the bank’s books.
- Access Bank will not establish any relationship with any customer until the identity of the potential customer is fully known. The forms of identity can be an international passport, national driver’s license, national identity card or third party proxy.
- Once identified, fraudulent customers will be reported to the appropriate authorities.
- There is constant review of customers profile and mandate files in order to update our customers’ records
- Continuous review of customers accounts transactions to identify cheque offenders and reporting them to the appropriate authority.
- Special caution is taken when Politically Exposed Person(s) (PEP) approach the bank to open account(s). Such account(s) are placed on surveillance and approvals restricted to Executive Management.
- In response to the recent focus on terrorist financing, NGO accounts are flagged as High Risk and placed on special surveillance.
- Regular, high quality and timely rendition of returns are done to the Nigerian Financial Intelligence Unit (NFIU) which is the only central, national agency responsible for receiving, analyzing and disseminating to the competent authorities, disclosures of financial information.
- A weekly review of reportable transactions is done in order to identify suspicious ones. If found, they are reported to the NFIU through Suspicious Transaction Reports (STRs)
- Staff are constantly trained bank wide on issues relating to KYC, Anti-Money Laundering activities, Terrorist financing, identifying suspicious transactions etc. Compliance Unit staff are encouraged to belong to professional bodies like Association of Certified Anti Money Laundering Specialists (ACAMS).
- Trainings are facilitated by professionals in money laundering monitoring including very senior staff of the regulatory bodies.
- Internal and External audit of the compliance unit is carried out regularly at least once every quarter by an Internal Audit unit, External Auditors and competent regulators including the NFIU.
- The Bank has installed the world renowned ACI Worldwide Proactive Risk Manager (PRM, a rule-based Anti-Money Laundering/Counter Terrorist Financing solution) for tracking, analyzing and reporting suspicious activities and other AML/CTF alerts.
- In terms of monitoring of transactions, any transaction that is within the reporting threshold ($10,000 and above) has to be approved by a senior management staff after proper scrutiny.
- Customers are required to fill a KYC “Customer Profile” form which gives details of the type of business and transactions that will be seen on their accounts. New accounts documentation are reviewed by designated officers for compliance with AML/CTF requirements before they are opened.
- Accounts with outstanding documentations are placed on “No debit” restrictions.
- An officer of the bank must visit the premises of the prospective customer and provide a clean visitation report before the account is opened.
- The bank takes extra effort to know and identify the shareholders of the business in addition to the directors as enhanced due diligence for High Risk accounts.
- We do not hesitate to make a report of suspicious accounts to NFIU and Economic and Financial Crimes Commission (EFCC) as they arise.
- All transactions within the reportable threshold amounts in all currencies are flagged by the system for reporting to the NFIU on a periodic basis and as requested.
- Details of special transactions e.g. Letters of credit cannot be amended on the system except by authorization.
- All transactions are reviewed against a blacklist like the OFAC, EU, UN lists of SDN’s and the PEP list to ensure that transactions are not done for known terrorists and money launderers.
- We have also developed an in-house name checking system for checking names of customers against the OFAC, UN, BOE and EU lists before on-boarding customers.
- We carry out Enhanced Due Diligence on all deposit taking financial institutions i.e. Micro- Finance Banks, who maintain accounts with us through periodic AML/CTF compliance questionnaires and checks. We also assist them with their AML/CTF training needs.
Our relationship with many international correspondent banks has made it imperative for us to comply significantly with the requirements of the U.S Patriot Act and other international AML/CFT regulations and recommendations like:
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