Herconomy Limited (‘Herconomy’) acknowledges the importance of obviating Money Laundering and Terrorism financing and is committed to the to the highest standards of combating Money Laundering and Terrorist financing in Nigeria.

Herconomy as a Designated Non-Financial Institution (DNFI) is subject to applicable laws designed to the Money Laundering (Prohibition) Act 2011(As amended); Terrorism Prevention Act 2011 and other applicable laws. Herconomy has a zero-tolerance policy towards money laundering, and is committed to the highest level of openness, integrity and accountability, both in letter and in spirit.

To accomplish this obligation, Herconomy has set internal policies and procedures. This Policy establishes standards and guidelines which every community member, user, employee, business partner and investor of Herconomy should observe.

1. Purpose of the Policy.

Money laundering is the process of any activity by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal background. Criminal proceeds may take any form including money or money’s worth, securities, tangible property and intangible property.

Terrorism Financing is defined as providing, depositing, distributing, or collecting funds, directly or indirectly, intended to be used, or knowing that these funds are to be wholly or partially used, for the committing of terrorist acts.

This Policy is aimed to prevent any company or individual from using Herconomy for money laundering or terrorist financing activities.

2. Our Policy

• Customer Due Diligence and Know Your Customer (KYC) 

To prevent Money Laundering, Herconomy will implement processes and procedures in its line of business to conduct appropriate User/Customer due diligence through the Herconomy’s Business Partner Screening Questionnaire, Identifying the User and verifying the User’s identity on the basis of the following “Know Your Customer” principles:

1. Herconomy must be reasonably satisfied as to the identity of User/Customer/Employee and satisfactory evidence of identity must be obtained and retained.
2. User/Customer provide documentation (Verification Checking such as obtaining BVN and valid ID for Nigerian users and for Non-Nigerian Users – Passport Next of Kin);

• Information on the User/Customer obtained from reliable and independent sources (Ownership Checking)

1. Ascertaining and verifying (if appropriate) the identity of the owners of a business/Directors of the Company, if there are any, so that the identity of the ultimate owners or controllers of the business is Known.

Unusual activity during the customer due diligence process or customer engagement should be reported immediately to the designated department of Herconomy.

• Risk-Based Approach

The type of business Herconomy’s User/Customer/Community member carries out will ascertain the threat of being involved in money laundering and terrorist financial activities.

Herconomy will classify its Users/Customers/Community members based on a risk level in its applicable line of business processes and procedures. Identifying the potential risk will help to effectively manage these risks, implementing controls to mitigate the identified risk, if any.

• High Risk Users/Customers 

Herconomy will not deal with the following segments of Users/Customers:

1. Persons included in any official/Public list of sanctions;
2. Persons indicating possible involvement in criminal activities, based on available information about them;

• Persons with businesses in which the legitimacy of activity or source of funds can’t be reasonably verified;

1. Persons with a high level of political exposure;
2. Persons refusing to provide the required information or documentation; or
3. Entities whose shareholding/control structure cannot be determined.

• Record Keeping

User/Customer documentation can either be submitted in physical or electronic form. An appropriate record of the received documentation, steps taken and copies of, or reference to, the documentation of the customer must be kept.

Records should be kept as long as the relationship endures with the User/Customer and for at least five (5) years after the relationship ends. Where the applicable laws impose a longer period, the provision of such law shall be applicable.

• Designation of Anti-Money Laundering Reporting Officer (AMLO)

Herconomy will appoint an Anti-Money Laundering Officer. The Anti-Money Laundering Officer will be responsible for:

1. Considering internal reports of money laundering;
2. Reporting suspicion of money laundering activities to the responsible authorities;

• Acting as key liaison with the money laundering authorities;

1. Training the business and its employees on money laundering;
2. Submitting reports to the Special Control Unit Against Money Laundering (SCUML);
3. Advising on procedure after a report of suspicion on money laundering has been raised; and,

• Designing and implementing Anti-Money Laundering processes and procedures.

3. Reporting Suspicious Activity

Herconomy expects that, if any Employee, User, Customer, Community member, Business partner, investor becomes aware of any suspicion or knowledge of possible Money laundering activity, this should be reported without undue delay to the AMLO. This can either be done contacting directly the AMLO or his/her assistant.

A report on suspicious activity should contain, at least, the following information, which will be confirmed by the AMLO:

1. Identity of the person raising the suspicion;
2. Date of the report;

• Who is suspected of money laundering or terrorist financing activities;

1. Other individuals involved otherwise;
2. Deliverance of facts;
3. What is suspected and why; and

• Any possible involvement of Herconomy.

The AMLO may make reasonable enquiries within Herconomy to confirm these suspicions or obtain additional information to confirm these suspicions. After the assessment, the AMLO will determine whether or not it is necessary to file an official report to the responsible money laundering authority. Details of internal reports will be held by the AMLO separately, excluded from User/Customer files to avoid inadvertent or inappropriate disclosure.

4. Training

Herconomy has a high commitment to compliance and all employees, Users, Customers, business partners and Investors are required to complete mandatory compliance training, including provisions on anti-money laundering on an annual basis.

Job-specific and comprehensive anti-money laundering training should be provided to the relevant employees to help recognize and deal with transactions which may lead to money laundering or terrorist financing.

5. Policy Review and Audits

Regular reviews of the effectiveness of this Policy are carried out in addition to audits periodically undertaken by Herconomy internal audit unit. This provides Executive Management with the necessary assurance and information regarding the operating effectiveness of Herconomy’s controls and processes relating to this Policy.