Anti-Money Laundering, Combating the Financing of Terrorism and Combating Proliferation Financing (AML/CFT/CPF) Policy Statements

Starks (‘The Company’) commits to the fight against money laundering (ML), financing of terrorism (FT), proliferation financing (PF) and all other forms of financial crimes. As a compliant body, it continually applies these principles and ensures that all stakeholders comply with AML/CFT/PF laws in all dealings. In line with corporate governance and adherence to regulatory directives, the Bank has established policies to guide against these financial crimes and requires total compliance in all its dealings.

Objectives of the Policies

The objectives of Starks AML policy are as follows:

  • To ensure that Starks fully complies with all AML/CFT-related laws, regulations, and standards.
  • To provide clarity on the prevention of money laundering, financing of terrorist groups and prevention of persons and organizations involved in the proliferation of weapons of mass destruction (WMDs) while facilitating transactions.
  • To guide the identification of suspicious activities and transactions that may be suggestive of money laundering, terrorist financing or proliferation financing and reporting of same to the applicable authorities.

Regulatory Framework

The AML policy of Starks is formulated in compliance with the predominant regulations outlined below:

  • Money Laundering (Prohibition) Act 2022
  • Proceeds of Crime (Recovery and Management) Act, 2022
  • Banks and Other Financial Institutions Act 2020
  • Foreign Exchange Act 1995
  • Corrupt Practices and Other Related Offenses Act 2000
  • Terrorism (Prevention and Prohibition) Act 2022
  • Security and Exchange Commission Code of Corporate Governance for Public Companies.
  • CBN Anti-Money Laundering and Combating the Financing of Terrorism (administrative sanctions) regulations, 2018
  • CBN AML/CFT Regulations 2022 and other extant laws

Policy Statements

  • The company’s Board has a function of oversight of the AML policy. The Company’s designated Head of Compliance is appointed by the Board.
  • Know Your Customer (KYC) and due diligence are well established and conducted during the onboarding stage. While Enhanced Due Diligence (EDD) is conducted for all high-risk accounts (including PEPs and Designated Non-Financial Institutions), Simplified Due Diligence is carried out for all other relationships. An effective risk assessment is conducted during the onboarding stage and at various stages of the customer journey to ensure proper risk profiling.
  • All other parties with an interest in doing business with Starks, such as partners, employees, vendors, and customers, are encouraged to read over the terms of these policies. Reporting any legal infractions or other misconduct is necessary so that appropriate investigations can be conducted.
  • Starks must render all statutory and mandatory regulatory reports

Prohibited Businesses

Starks has no appetite for clients whose businesses are conducted in Prohibited Special Risk Countries (SRCs), Shell businesses, Gambling establishments, Casinos, and Dealers in arms and weapons. Customers are screened against these categories of customers during onboarding and continuously.

Other Controls

In addition, Starks has put in place other measures to safeguard all stakeholders from financial crimes. These include periodic staff regulatory compliance training, record keeping and retention, data protection, designation of the Head of Compliance, board-approved policies, and periodic compliance audits and reviews.