Eanvest Ltd ("Eanvest") is committed to preventing the use of its platform for money laundering, terrorism financing, sanctions evasion, fraud, or other financial crime. This Policy sets out the framework we apply, the obligations our customers and staff must meet, and the standards we measure ourselves against.
1. Regulatory Framework
This Policy is designed to comply with:
- The Money Laundering (Prevention and Prohibition) Act 2022.
- The Terrorism (Prevention and Prohibition) Act 2022.
- The Central Bank of Nigeria (Anti-Money Laundering, Combating the Financing of Terrorism and Countering Proliferation Financing of Weapons of Mass Destruction in Financial Institutions) Regulations, as amended.
- The Securities and Exchange Commission Rules on AML/CFT for Capital Market Operators.
- Guidelines issued by the Nigerian Financial Intelligence Unit (NFIU).
- International standards set by the Financial Action Task Force (FATF) where applicable.
2. Governance
Our Compliance Officer (CO) is responsible for the overall implementation of this Policy. The CO reports to the Board of Directors and has direct access to senior management. The CO is:
- Name: Folake Oyakhire
- Title: Head, Legal and Compliance
- Email: compliance@eanvest.com
The Board reviews this Policy at least annually and approves material changes.
3. Customer Identification (KYC)
Before we open an account, and on an ongoing basis during the relationship, we identify and verify each customer. We apply a three-tiered KYC framework, with tier-appropriate transaction and balance limits.
3.1 Tier 1 (Basic)
- Name, date of birth, phone number, residential address.
- Verification through phone number ownership, address proxies, or other low-friction methods.
- Transaction and balance limits as set by the CBN from time to time.
3.2 Tier 2 (Standard)
- All Tier 1 information.
- Bank Verification Number (BVN) and National Identification Number (NIN) verified via NIBSS and NIMC.
- Government-issued identification.
- Verification of a Nigerian bank account in the customer's name.
- Liveness check or selfie verification.
3.3 Tier 3 (Full)
- All Tier 1 and Tier 2 information.
- Proof of residential address (utility bill, bank statement, or equivalent), not older than three months.
- Source of funds and, where appropriate, source of wealth declarations.
- Enhanced due diligence for higher-risk customers (see Section 5).
4. Customer Due Diligence (CDD) and Ongoing Monitoring
We conduct customer due diligence at onboarding and at trigger points during the relationship, including:
- Material change in customer information (employment, address, name).
- Material change in the customer's transaction profile.
- Adverse media or sanctions hits.
- Periodic refresh based on the customer's risk rating (see Section 5).
- Tier upgrades or downgrades.
We monitor transactions on an ongoing basis using a combination of rules-based monitoring and analyst review. Alerts are investigated promptly, and outcomes are documented.
5. Risk-Based Approach
We classify each customer into a risk band (Low, Medium, High) using factors that include:
- Customer profile (occupation, expected income, source of funds).
- Geography (residence, primary economic activity).
- Product usage (volume, velocity, complexity).
- Politically Exposed Person (PEP) status, including domestic and foreign PEPs and their close associates and family.
- Adverse media.
- Prior alerts or filings on the customer.
Higher-risk customers receive Enhanced Due Diligence (EDD), which may include senior management approval to onboard or continue, additional source-of-funds documentation, lower transaction thresholds, and more frequent reviews. Some customers and activities are prohibited regardless of EDD; these are listed in the internal high-risk and prohibited matrix maintained by the CO.
6. Sanctions and PEP Screening
We screen all customers and beneficiaries at onboarding and on a continuous basis against:
- The United Nations consolidated sanctions list.
- Office of Foreign Assets Control (OFAC) lists, where applicable.
- European Union sanctions lists, where applicable.
- United Kingdom Office of Financial Sanctions Implementation lists, where applicable.
- Nigerian sanctions lists and the NFIU watchlist.
- PEP databases.
True matches are escalated to the CO for adjudication. Where required, we will freeze the account, report to the NFIU, and follow regulator instructions.
7. Transaction Monitoring
We monitor transactions for patterns and behaviours that may indicate financial crime, including:
- Structuring (multiple transactions just below reporting thresholds).
- Rapid in-out movement of funds (deposits followed by immediate redemptions).
- Source of funds inconsistent with declared income or profile.
- Use of multiple accounts or beneficiaries with apparent linkage.
- Sudden, unexplained changes in activity.
- High-risk geographies or counterparties.
- Refusal to provide reasonable information or documents.
8. Reporting
Where, after investigation, we have a reasonable suspicion that a transaction or relationship involves the proceeds of crime, terrorism financing, or sanctions breach, we will file a Suspicious Transaction Report (STR) or Suspicious Activity Report (SAR) with the NFIU in line with the Money Laundering (Prevention and Prohibition) Act. We will also make Currency Transaction Reports (CTRs) for transactions above the threshold set by the NFIU. We will not tip off the customer or any other party that a report has been made ("no tipping off").
9. Record-Keeping
We keep records of identification documents, customer due diligence, transactions, internal alerts, investigations, and reports for at least five years from the end of the customer relationship or from the date of the transaction, whichever is later, in line with statutory requirements. Records are stored securely, with access restricted to authorised personnel, in line with our Data Retention Policy and Cybersecurity and Information Security Policy.
10. Training
All staff receive AML/CFT training at induction and at least annually thereafter. Staff in customer-facing and operations roles receive additional role-specific training. Training records are maintained by the CO and reviewed by Management.
11. Customer Obligations
By using Eanvest, you agree to:
- Provide accurate and complete identification information.
- Update your information when it changes.
- Provide additional documentation when requested, including for source-of-funds checks.
- Use the platform only for lawful purposes.
We may decline to open an account, suspend an account, freeze transactions, or close an account where these obligations are not met or where required by law.
12. Independent Review
Our AML/CFT framework is subject to independent review at intervals determined by the Compliance Committee and at least annually. Findings are reported to the Board.
13. Updates
We update this Policy when regulations change or when our risk environment changes. The current version is available on request.