Financial Crime World

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FMDQ Exchange Fights Money Laundering and Terrorist Financing with Robust Compliance Culture

In a bid to ensure timely and accurate rendition of all Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) returns, FMDQ Exchange has restructured its reporting and record-keeping requirements.

Politically Exposed Persons Pose Reputation Risks

FMDQ Exchange is aware that business relationships with family members or close associates of Politically Exposed Persons (PEPs) pose similar reputation risks to those associated with PEPs themselves. As such, the exchange shall evaluate the risks to its business operations when dealing with clients who have a connection to PEPs.

Board of Directors and Management Take Lead

  • The Board of Directors is responsible for ensuring an operational AML/CFT policy is formulated by management and reviewed as may be required.
  • The board also ratifies the AML/CFT policy approved by the Board Regulation, Risk and Audit Committee (BRRAC).
  • The Managing Director ensures that adequate controls are in place to mitigate identified compliance risks and develops an AML/CFT policy.

Compliance Officer Coordinates Compliance Efforts

  • The Compliance Officer is responsible for developing an AML/CFT compliance program.
  • Rendering returns on foreign exchange transactions to the Securities and Exchange Commission (SEC).
  • Reporting with the Nigerian Financial Intelligence Unit (NFIU) as necessary.
  • Ensuring that the Capital Market Operators’ compliance program is implemented.
  • Coordinating staff training in AML/CFT awareness, detection methods, and reporting requirements.

Internal Audit Conducts Independent Reviews

  • The Internal Audit department incorporates compliance testing into their normal audit program.
  • Reporting results to the board through the Managing Director and BRRAC.
  • Carrying out independent reviews of the policy, providing assurance to the Board, BRRAC, and management.

Staff Responsibilities

  • All FMDQ staff are responsible for implementing measures and approaches diligently.
  • Familiarizing themselves with guidelines, policies, and best practices relating to their respective areas of responsibility.
  • Reporting any legal violations or other forms of misconduct in accordance with FMDQ’s policies and procedures.

Annual Reviews and Assessments

  • The Compliance Officer undertakes an annual review of the AML/CFT policy, except in situations where new regulations necessitate an earlier review/update.
  • The Board of Directors approves the AML/CFT policy and any updates or amendments after consideration by the BRRAC.

Governance and Independence

  • The Compliance Officer establishes the requisite compliance tools that are independent of operational departments and management.
  • FMDQ staff are responsible for reporting all compliance issues to the Compliance Officer.

Consequences of Non-Compliance

  • A breach of AML/CFT laws is a serious offense, punishable by lengthy investigations, significant fines, and criminal sanctions, including imprisonment of employees.

Policy Alignment

FMDQ Exchange’s policy is in line with the requirements of the SEC regulations on Capital Market Operators’ anti-money laundering and combating the financing of terrorism.