Introduction

This Know Your Customer (“KYC Policy”) and Anti-Money Laundering (“AML Policy”) is an integral part of the legal procedure of Bingtellar Inc. (“Bingtellar”) and it is an integral part of Bingtellar’s Terms and Conditions. In order to be able to use the services offered by Bingtellar, every user of Bingtellar’s platform and services (“User”) needs to have declared to have read and agreed with these conditions.

Money laundering is the process by which the illegal origin of wealth is disguised to avoid the suspicion of law enforcement authorities. Money Laundering also encompasses the illicit act of funding terrorism. The challenges in the fight against money laundering are vast, and potential threats exist in every corner of the world. Financial services firms, regulators and law enforcement agencies alike work very hard to stay ahead of increasingly sophisticated criminals that seek to exploit the global financial system.

Bingtellar’s mission is to serve as a trusted partner by responsibly providing financial services that enable growth and economic progress. Consistent with this goal, Bingtellar is committed to the fight against money laundering.

Policy description

Money Laundering and financing terrorism are financial crimes with economic effects. This policy is to eradicate the adverse effects of criminal economic activity and promotes integrity and stability in financial markets. Compliance with this policy is also critical to preserving the Company’s corporate integrity, reputation and operational efficiency.

The purpose of this Policy is:

(i). To guide the standard of conduct and practice that Bingtellar must follow in implementing the AML, KYC, and CFT regulations.

(ii). To protect the Company against fraud, reputation and other financial market risks.

(iii). To minimise the risks faced by the Company from proceeds of crime (iv). To prevent money laundering and establish ERM systems to monitor the Company’s exposure to financial crime.

Compliance with policy

The Company shall comply with the following:

(a). Formulate and implement internal controls and other procedures that will deter criminals from using its facilities for money laundering and terrorist financing and ensure that its obligations under Nigerian and subsisting laws and Regulations are met.

(b). Embark on Enterprise Risk Management (ERM) and maintain an ERM register

(c). Designate a Money Laundering Reporting Officer (MLRO) with the relevant competence and independence to implement the Company’s AML/KYC compliance policy. (d). Comply with the Money Laundering (Prohibition) Act, the Money Laundering (Prohibition) (Amendment) Act (together, the Money Laundering Act) and the Economic and Financial Crimes Commission Act.

(e). Identify and report any suspicious transactions from the criminal activities defined in AML/KYC Regulations.

(f). Ensure the implementation of the AML/KYC Act requirements is not inhibited through the Company’s Confidentiality Agreement or Policy.

(g). Effectively communicate and raise staff awareness on AML/KYC issues

(h). Establishing and maintaining a risk-based approach to assessing and managing money laundering and terrorist financing risks.